What constitutes significant with respect to submitting WH&S Program updates? Is annual measured from approval date or submission date?
Response: Significant is elaborated on in the Draft Implementation Guide for 851. Section 3.2.2.2 of the draft guide states: A change should be submitted to DOE if a hazard associated with a change in the worksite or processes, or any newly recognized hazards, is not effectively controlled by the measures in the currently approved worker safety and health program. Annual is measured from the Approved date of the WSHP.
