Information Notice No. 88-100:Memorandum of Understanding Between NRC and OSHA Relating to NRC-Licensed Facilities (53 FR 43950, October 31, 1988)
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
WASHINGTON, D. C. 20555
December 23, 1988
Information Notice No. 88-100: MEMORANDUM OF UNDERSTANDING BETWEEN NRC
AND OSHA RELATING TO NRC-LICENSED
FACILITIES (53 FR 43950, OCTOBER 31, 1988)
Addressees:
All major nuclear materials licensees and utilities holding construction
permits and operating licenses.
Purpose:
This notice is intended to inform all licensees of a new Memorandum of
Understanding (MOU) between NRC and the U.S. Occupational Safety and Health
Administration (OSHA) that provides guidelines for coordination of interface
activities between the two Agencies. It is expected that licensees will
review this information, and distribute the notice to responsible radiation
safety and industrial hygiene staffs. However, suggestions contained in this
information notice do not constitute new NRC requirements, and no written
response is required.
Discussion:
Both NRC and OSHA have jurisdiction over occupational safety and health at
NRC-licensed facilities. Because it is not always practical to sharply
identify boundaries between the nuclear and radiological safety that NRC
regulates and industrial safety that OSHA regulates, a coordinated interagency
effort can ensure against gaps in the protection of workers, and at the same
time, avoid duplication of effort. The new MOU replaces an existing procedure
which outlined the NRC's and OSHA's interagency activities.
Although NRC does not specifically examine industrial safety during inspec-
tions of radiological and nuclear safety, NRC personnel may identify safety
concerns within the area of OSHA responsibility, or may receive complaints
from an employee about OSHA-covered working conditions. In such instances,
NRC will bring the matter to the attention of licensee management or monitor
corrective action when appropriate. If significant safety concerns are
identified, or if the licensee demonstrates a pattern of unresponsiveness to
identified concerns, the NRC regional office will inform the appropriate OSHA
regional office. Also, when known, NRC inspectors will encourage licensees to
report to OSHA accidents resulting in a fatality or multiple hospitalizations.
It is not the intent of the Commission that NRC inspectors perform the role of
OSHA inspectors; however, they are to elevate OSHA safety issues to the
attention of OSHA Regional management when appropriate.
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. IN 88-100
December 23, 1988
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Similarly, OSHA Regional Offices will inform the appropriate NRC Regional
Office of matters which are in the purview of NRC, when these matters come to
their attention during Federal or State safety and health inspections or
through complaints.
The Memorandum of Understanding between NRC and OSHA is enclosed for your
information.
No written response is required by this notice. If you have any questions
about this information notice, please contact the appropriate NRC regional
office or this office.
Richard E. Cunningham, Director
Division of Industrial and
Medical Nuclear Safety
Office of Nuclear Material
Safety and Safeguards
Technical Contacts: Glen L. Sjoblom, NMSS
(301) 492-3430
Frederick J. Hebdon, NRR
(301) 492-1243
Attachments: 1. Memorandum of Understanding from the Federal
Register Dated October 31, 1988
2. List of Recently Issued NRC Information Notices
. Attachment 2
IN 88-100
December 23, 1988
Page 1 of 1
LIST OF RECENTLY ISSUED
NRC INFORMATION NOTICES
_____________________________________________________________________________
Information Date of
Notice No._____Subject_______________________Issuance_______Issued to________
88-99 Detection and Monitoring 12/20/88 All holders of OLs
of Sudden and/or Rapidly or CPs for PWRs.
Increasing Primary-to-
Secondary Leakage
88-98 Electrical Relay Degradation 12/19/88 All holders of OLs
Caused by Oxidation of or CPs for nuclear
Contact Surfaces power reactors.
88-97 Potentially Substandard 12/16/88 All holders of OLs
Valve Replacement Parts or CPs for nuclear
power reactors.
88-96 Electrical Shock Fatalities 12/14/88 All holders of OLs
at Nuclear Power Plants or CPs for nuclear
power reactors.
88-95 Inadequate Procurement 12/8/88 All holders of OLs
Requirements Imposed by or CPs for nuclear
Licensees on Vendors power reactors.
88-94 Potentially Undersized 12/2/88 All holders of OLs
Valve Actuators or CPs for nuclear
power reactors.
88-93 Teletherapy Events 12/2/88 All NRC medical
licensees.
88-92 Potential for Spent Fuel 11/22/88 All holders of OLs
Pool Draindown or CPs for nuclear
power reactors.
88-91 Improper Administration 11/22/88 All holders of OLs
and Control of or CPs for nuclear
Psychological Tests power reactors and
all fuel cycle
facility licensees
who possess, use,
import, export, or
transport formula
quantities of
strategic special
nuclear material.
_____________________________________________________________________________
OL = Operating License
CP = Construction Permit
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