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Lesson 13 esoh_jan_2015
1. Learn. Perform. Succeed
Aug 11
Environment, Safety, and
Occupational Health (ESOH)
PQM-301
https://www.youtube.com/watch?v=N03Uoj6p9QA
2. 2Aug 11
ESOH Learning Objectives
Given student lecture, and classroom discussion will explain how
Environmental, Safety and Occupational Health (ESOH)
considerations are incorporated into the Systems Engineering
Process and Acquisition Lifecycle.
• Enabling Learning Objectives:
1. Describe the five major considerations for ensuring DoD’s compliance
with ESOH requirements.
2. Explain the aspects of Programmatic Evaluation of ESOH
considerations as documented by the Program Manager (PESHE).
3. Identify and discuss methods, tools and techniques used to manage and
mitigate ESOH risks.
Risk Management
3. 3Aug 11
It’s the
Law!
It’s about
energy
conservation.
It’s about
prevention.
.
It’s about
cleaning up.
It’s about
better designs
It’s about
safety and
health.
Each person saw the elephant from their own point of view.
In turn, each student will see this course from a different perspective.
What is ESOH?
4. 4Aug 11
Lesson Overview
• ESOH is a Materials and Processes Issue – not just
an Environmental Issue
• Our PQM field is impacted by these issues
• ESOH risk management should include:
• Laws like CAA / CWA / TSCA, etc.
• PESHE and NEPA
• System Safety Program – Mil-Std-882
• Hazardous Material Management Planning – NAS 411
• Pollution Prevention Program
• Goal to integrate ESOH considerations throughout
the Systems Engineering process, rather than after.
• ESOH ultimately benefits the User
5. 5Aug 11
Why Worry?
• Estimated cost to clean up DoD’s current mess:
$25 - $150 billion
• 8,000 potentially contaminated sites
at 900 military installations
• DoD produces nearly 1 M tons of hazardous waste
each year…more than top 5 industrial producers
combined
• 80% of DoD’s hazardous wastes are from weapon
systems operational support activities
• Cost of hazardous material versus cost to handle,
treat, & dispose of waste is 1:80
6. 6Aug 11
6
ESOH Considerations
• Environmental, Safety and Occupational Health
Compliance should include:
• NEPA & NEPA Compliance Schedule
• Pollution Prevention Program
• Systems Safety (Mil-Std-882C)
• Hazardous Material Management Program – NAS 411
• Programmatic Environmental Safety and Health Evaluation
(PESHE)
Risk Management
DAG Chapter 4: https://acc.dau.mil/CommunityBrowser.aspx?id=638356
7. 7Aug 11
1900…………………………..1960 1970 1980 1990 2000 2010
RHA – Rivers and Harbors Act (1899)
CAA – Clean Air Act (1963)
NEPA – National Environmental Policy Act (1969)
OSHA – Occupational Safety and Health Act (1970)
CWA - Clean Water Act (1972)
TSCA – Toxic Substance Control Act (1976)
RCRA - Resource Conservation and Recovery Act (1976)
CERCLA – Comprehensive Environmental Response, Compensation and
Liability Act (1980)
EPCRA – Emergency Planning and Community Right-to-Know Act
(1986)
PPA – Pollution Prevention Act (1990)
FFCA – Federal Facilities Compliance Act (1992)
RoHS – Restriction of Hazardous Substances (2003)
REACH – Regulation of Registration, Evaluation,
Authorization and Restriction of Chemicals (2007)
Environmental Protection Laws
Clean Air Act (1970):
• Requires EPA to list pollutants and set standards
• Establishes National Ambient Air Quality Standards
• Requires State Implementation Plans to meet NAAQS
• Established Operating Permit Program
• Criminal act for the “senior official” at the site
• Established a bounty for finding violators
Clean Water Act (1972):
• Requires EPA to list pollutants and set standards
• Cannot discharge from a point source into navigable
waters without a permit
• Law now addresses non-point sources
• Sets civil, criminal and administrative enforcement
provisions
Toxic Substances Control Act (1976):
• Requires record-keeping on over 83,000 chemicals
(PCBs, Asbestos, Mercury, etc.)
• Authorizes the EPA to require reporting and testing of
chemical substances and mixtures
• Addresses the production, importation, use, and
disposal of specific chemicals
• Annual Toxic Release Inventory (TRI)
• Material Safety Data Sheet (MSDS) requirements
• (see Love Canal)
8. 8Aug 11
Environmental Protection Laws
1900…………………………..1960 1970 1980 1990 2000 2010
RHA – Rivers and Harbors Act (1899
CAA – Clean Air Act (1963)
NEPA – National Environmental Policy Act (1969)
OSHA – Occupational Safety and Health Act (1970)
CWA - Clean Water Act (1972)
TSCA – Toxic Substance Control Act (1976)
RCRA - Resource Conservation and Recovery Act (1976)
CERCLA – Comprehensive Environmental Response, Compensation and
Liability Act (1980)
EPCRA – Emergency Planning and Community Right-to-Know Act
(1986)
PPA – Pollution Prevention Act (1990)
FFCA – Federal Facilities Compliance Act (1992)
RoHS – Restriction of Hazardous Substances (2003)
REACH – Regulation of Registration, Evaluation,
Authorization and Restriction of Chemicals (2007)
Comprehensive Environmental Response, Compensation
and Liability Act (1980):
• Requires the EPA to designate substances as harmful
• Requires the immediate notification of the release of a
hazardous material to the National Response Center
• Grants the EPA extensive authority to require cleanup
• Assigns cleanup cost to the responsible parties
EMERGENCY PLANNING & COMMUNITY
RIGHT-TO-KNOW ACT (1986):
• Requires states to develop programs for responding to
hazardous chemical releases
• Requires industry to report/notify the public of the
release or potential release of hazardous substances
• Sets State Emergency Response Commission and
Local Emergency Planning Coordinator
Resource Conservation & Recovery Act (1977):
• Authorizations EPA to identify Hazardous Waste
(Ignitable, Corrosive, Reactive, and/or Toxic)
• Regulates the generation, transportation, treatment,
storage, and disposal through permits and records
• Sets extensive liabilities
9. 9Aug 11
Environmental Protection Laws
1900…………………………..1960 1970 1980 1990 2000 2010
RHA – Rivers and Harbors Act (1899
CAA – Clean Air Act (1963)
NEPA – National Environmental Policy Act (1969)
OSHA – Occupational Safety and Health Act (1970)
CWA - Clean Water Act (1972)
TSCA – Toxic Substance Control Act (1976)
RCRA - Resource Conservation and Recovery Act (1976)
CERCLA – Comprehensive Environmental Response, Compensation and
Liability Act (1980)
EPCRA – Emergency Planning and Community Right-to-Know Act
(1986)
PPA – Pollution Prevention Act (1990)
FFCA – Federal Facilities Compliance Act (1992)
RoHS – Restriction of Hazardous Substances (2003)
REACH – Regulation of Registration, Evaluation,
Authorization and Restriction of Chemicals (2007)
Federal Facilities Compliance Act (1992):
• Directs EPA to conduct annual inspections of federal
facilities
• Requires the agency to pay for the inspection
• Empowers EPA to fine federal agencies
• Empowers states to fine federal agencies
• Federal Agencies are exempt from criminal actions but
not their employees
•
RoHS (2003):
• A directive on the restriction of the use of hazardous
substances in electrical and electronic equipment
• Closely linked with the Waste Electrical and Electronic
Equipment Directive (WEEE) 2002/96/EC
REACH (2007):
• Requires anyone producing or importing chemicals
into the European Union to register these chemicals
with the European Chemicals Agency
• This includes over 143,000 listed chemicals
• Requires sharing information up and down the supply
chain
• Considered the “strictest law to date in the entire
world
10. 10Aug 11
Occupational Health
• Physical Injuries
• Repetitive Motion
Disorders
• Hearing Loss
• Vision & Blindness
• Illness by Ingesting
Unsafe Substances
• Illness by Exposure to
Germs / Viruses
• Radiation Sickness
• Psychosocial Issues
Safety
Engineering
Chemistry
Industrial
Hygiene
Public
Health
Health
Physics
Occupational
Medicine
Laws &
Enforcement
4,405
11. 11Aug 11
Typical DoD Violations
• Air Force agrees to clean up groundwater at Air Force Plant 44, Tucson
The Air Force has signed an agreement to clean up Air Force-owned property at Air
Force Plant 44, part of the Tucson International Airport Area Superfund Site. Under the
terms of the federal facility agreement, the Air Force will work with the EPA to clean up
areas impacted by Air Force Plant 44. Groundwater at the site is contaminated with
volatile organic compounds and other chemicals.
• Army research facility agrees to pay penalty for hazardous waste violations
The U.S. Army Cold Regions Research and Engineering Laboratory in Hanover, N.H. will
pay for violations of federal and state hazardous waste management laws. The facility
failed to determine whether several containers held hazardous wastes, failed to properly
label hazardous wastes containers, and accumulated hazardous waste in an area with a
floor drain without taking measures to prevent a leaks.
• Former Coast Guard Officer sentenced for lying about vessel pollution
David G. Williams, a former Chief Warrant Officer in the U.S. Coast Guard and main
propulsion assistant for the Coast Guard Cutter Rush, was sentenced in U.S. District
Court in Hawaii for making a false statement to federal criminal agents investigating
allegations of potential discharges of oil-contaminated waste from the cutter into the
Honolulu Harbor. Williams was sentenced to pay a $5,000 fine, serve 200 hours of
community service and serve two years of probation.
12. 12Aug 11
Current Issue
(What Laws?)
On Jan. 9, a clear, licorice-smelling chemical leaked from a storage
tank into the Elk River in West Virginia, contaminating the drinking
water for much of the state, including the capital, Charleston. Two
weeks later it was disclosed that a second chemical was involved:
• MCHM (methylcyclohexanemethanol)
• The 15-page MSDS uses the phrase “no data available” 152 times:
FREEDOM INDUSTRIES
• Repeated dose toxicity: “No data available.”
• Carcinogenicity: “No data available.”
• Reproductive toxicity: “No data available.”
• Specific target organ toxicity, repeated
exposure: “No data available.”
EPA
Army Corps of Engrs.
13. 13Aug 11
The NEPA affects virtually every proposed action on military installations
and for many acquisition programs. NEPA requires federal agencies
to document their consideration of environmental factors by writing
environmental impact statements (EIS) during their decision-making
processes.
National Environmental Policy
Act (NEPA)
2010
14. 14Aug 11
Pollution Prevention Program
• Rules and Laws:
• DoD 5000.02 tasking to PM
• FAR 11.002 – Energy Efficiency/Preferred Materials
• E.O. 13101 – Green Gov.
• DODI 4715.4
• ISO 14000 Series
• Identify & Quantify
• ESOH risks of system
• Minimize system impacts
Land
Ground
Water
Surface Water
Air
15. 15Aug 11
• Prevent or reduce at source
• Recycle
• Treat
• Dispose only as last resort
• “Action-forcing” provisions
• Release of Environmental Information to Public,
before decisions / actions
Pollution Prevention Act
Risk Management
Hierarchy
17. 17Aug 11
• Explosives Safety
• LASER Safety
• Noise Pollution
• Greenhouse gases
• Nanomaterials
• Human Systems Integration
• MANPRINT
• NAVPRINT
• Sustainable Manufacturing
Recent ESOH Concerns
x 100,000
Single-Walled
Carbon Nanotube
Strand of
Human Hair
AMPEC Facility, Henderson, NV
18. 18Aug 11
System Safety
• System Safety
• Software Safety
• Explosives Safety
• Laser Safety
• Occupational Safety
• Accident Avoidance
• Safety Hazard Avoidance
• Health Hazard Avoidance
• Public Safety
• Cradle to Grave
MIL-STD-882 Gold Standard
Proven risk management
techniques and principles
Provides common approach
across program and contractors
Provides common approach
across other functional areas
19. 19Aug 11
Risk Mitigation
1. Eliminate through design
2. Reduce to acceptable level
through design
3. Reduce to acceptable level
through external devices
4. Reduce to acceptable level
through warning devices
5. Reduce to acceptable level
through procedures and
training
Systems Engineering
20. 20Aug 11
Hazardous Material
• DoD 5000.02 tasking to PM
• NAS 411: HMMP
• Hazardous Material Management Plan
Identification / Evaluation
Specifications / Standards
Specialized Training & Documentation
• Identify & Quantify
• HAZMAT in > HAZWASTE out
• Manufacture - Operations
• NEPA Hierarchy
21. 21Aug 11
Material Safety Data Sheets
• Detailed descriptions of material
• Hazards and precautions
• Personal Protective Equipment required
• Procedures for handling and mishaps
• B-2 Program: Over 6000 MSDS
• Reduce / Reuse provisions
• MSDS for items not considered HAZMAT
• Unknown Hazards?
22. 22Aug 11
General Information
Product: Coffee, Columbian
Intended Use: Jump start students
Chemical Family: Beanus Alertis
Physical Data
Boiling Point: 100 Degrees C
Appearance: Dark Brown
Odor: Vanilla
pH Levels: 4.5 to 5.0
Flash Point: N/A
Health & Hazard Information
May cause trembling & headaches.
Some students have been found awake
during a lecture!
Emergency First Aid
Give students large quantities of viewgraphs
and flush with lots of cold water.
Reactivity Data
Stability: Stable under normal conditions.
Cream & sugar will cause pH to increase.
Special Precautions
Protective Equipment: Tums
Applicable Laws
CWA TSCA CERCLA
SuperFund & CoffeeFund
Example MSDS
23. 23Aug 11
Integration of ESOH in
Systems Engineering
• PESHE
• Trade Studies
• Total Life Cycle Cost
• Preplanned Product
Improvement
• Knowledge
Management
• Technical Reviews
Interoperability
Disposal
Software
ESOH
Corrosion
Prevention
Quality
Manufacturing
Capability
Open
Systems
HSI RAM
Defense Acquisition Guidebook 4.4
Design Considerations
24. 24Aug 11
PESHE
Program Managers (PMs) must prepare a Programmatic
ESOH Evaluation (PESHE) regardless of the program's
acquisition category designation. A current PESHE
document is required at:
• Milestone B,
• Milestone C, and the
• Full Rate Production Decision Review.
25. 25Aug 11
PESHE
The PESHE should include:
• Identification, assessment, mitigation, and acceptance of ESOH risks
• Ongoing evaluation of mitigation effectiveness
• A Compliance Schedule for National Environmental Policy Act (NEPA) and
Executive Order (E.O.) 12114, "Environmental Effects Abroad of Major
Federal Actions," documentation.
• The PESHE communicates the status of ESOH efforts and risk management
for the system. The Acquisition Strategy (AS) must also include a summary
of the PESHE and the NEPA/EO 12114 Compliance Schedule.
• The Systems Engineering Plan (SEP) should also include a reference to the
strategy for integrating ESOH into the systems engineering process, as
documented in the PESHE.
26. 26Aug 11
5000.2 Requirements
• The PM shall integrate ESOH risk management into
the overall systems engineering process.
• The PM shall eliminate ESOH hazards where
possible, and manage ESOH risks where hazards
cannot be eliminated using MIL-STD-882D.
• PMs shall report on the status of ESOH risks and
acceptance decisions at technical reviews. The PM
shall document that the associated risks have been
accepted by the following acceptance authorities:
• CAE for high risks,
• PEO-level for serious risks, and
• PM for medium and low risks.
• The user shall provide formal concurrence prior to all serious-
and high-risk acceptance decisions.
28. 28Aug 11
https://acc.dau.mil/adl/en-US/385750/file/56276/ESOH_in%20Acquisition_Guide_4-24-09.pdf
ESOH Acquisition Guide
Initial ESOH Planning
Tech. Dev. Strategy
Contract Language
ESOH / SE Integration
PESHE Process
Acquisition Strategy
Contract Language
ESOH / SE Integration
ESOH/System Safety
Risk Management
ESOH / NEPA
Compliance
Hazmat Planning
ManTech Investments
PESHE Process
Acquisition Strategy
Contract Language
ESOH / SE Integration
ESOH/System Safety
Risk Management
ESOH / NEPA
Compliance
Hazmat Planning
ManTech Investments
PESHE Process
Acquisition Strategy
Contract Language
ESOH / SE Integration
ESOH/System Safety
Risk Management
ESOH / NEPA
Compliance
Hazmat Planning
ManTech Investments
ESOH in Sustainment
and Operations
ESOH Planning for
Modifications
29. 29Aug 11
ESOH in Acquisition Guide
http://www.wpafb.af.mil/shared/media/document/AFD-080402-030.pdf
30. 30Aug 11
Functional Analysis Events
The PESHE & Program Management
ACQUISITION STRATEGY
Test &
Evaluation
Strategy
Systems
Engineering
Plan
Technology
Development
Strategy
Manufacturing
Plan
Integrated
Logistics
Support Plan
Human
Systems
Integration
Risk Management Issues
Programmatic:
Total Ownership Cost
Schedule
Performance
Environment:
Compliance
Pollution
Prevention
HAZMAT/
HAZWASTE
Safety:
Hazard ID,
Documenting,
Training,
Devices,
Risk Reduct.
Occupational
Health:
Ergonomics,
MWR,
Community
Relations
Planning:
Technical Issues
PPBE
Customer Feedback
Documentation
31. 31Aug 11
ESOH Factors in Source Selection
• SOO/SOW
• HMMP (NAS 411)
• Compliance History
• HAZMAT habits (TRI)
• Safety Plan (MIL-STD-882)
• RFP
• HMMP / PPP
• Compliance History
• HAZMAT Habits (TRI)
• Health & Safety Plans
• Integration of ESOH in S.E.P.
• Design
• Test
• Manufacturing
• Operations & Maintenance
• Disposal
Possible Evaluation Criteria
Does the offeror understand how to
manage ESOH risks?
Does the offeror have an existing
safety plan?
Does the offeror have a staff,
organization, and methodology
supporting responsible ESOH habits?
Does the offeror understand what
makes a good HMMP?
Does the offeror show proper
integration of ESOH considerations in
its System Engineering Plan?
Does the offeror make ESOH
decisions based on sound practices?
32. 32Aug 11
Technical Reviews
• Identify pollution prevention opportunities and
document in program documentation
• Review HMM efforts
• Identify HAZMAT use (baseline) and alternatives
• Define ESOH impacts from system
• Review waste disposal requirements
• Verify technical documentation changes
Coordinate with test,
users, engineers, and
logistics during reviews
to determine ESOH
requirements early and
throughout the process.
PESHE UpdatesPESHE
Post
PDR / CDR
33. 33Aug 11
Trade-off Studies
• Determine whether the material or
process is critical to performance
requirements or if an alternative can
be used.
• Based on whether new material:
• is a valid need
• is being used already
• is available in supply system
• Or if the existing material:
• has no acceptable alternative
• has an operational impact
• has regulatory impacts – O&S
Requirements Management &
Logical Analysis
Test & Evaluation of Alternatives
• Performance Testing
• Bench Test / Laboratory
• Process Prototype
• Field Test by User
• Prove Alternative Works
Alternative meets performance
New materials are compatible
New materials are not worse
than previous materials
Operator / User buy-in for new
process & materials
34. 34Aug 11
Environmental Cost
Factors
The spider diagram is a useful
tool to display the various
environmental factors in a way
that provides you some insight
into their relative cost
compared to other options.
The resulting diagram will help
you to identify the best
alternative. In this case the
smaller the area of impact, the
better the option. Option A
has the least negative impact
and given other factors are
equal (cost, schedule, and
performance) then you should
select this option.
Water
Use
Mission
Impacts
Ergonomics
Health
Impacts
Energy
UseAcquisition
Impacts
Option A
Option B
Option C
Option D
Land Use
HazMat
Management
Pollution
Prevention
Design for
Environment
Conservation
NEPA
Compliance
Demilitarization
Disposal
HazMat
Management
Restoration
Remediation
Medical
Bills
Health
Insurance
Sick
Leave
Hospitalization
Rehabilitation
35. 35Aug 11
35
ESOH Impacts to the Program
• Cost
- Personal Protective Equipment
- Hazard Communication
- Medical Surveillance
- Toxicity Assessment
- Monitoring
- Record Keeping
• Schedule
- ESOH Acceptance and
Approvals may delay or
stop program during
reviews.
- NEPA Reporting and
compliance delays
- Environmental Assessment
- Environmental Impact
Statement & Review
- Production Line Delays
- EPA Shutdown
- Supply Chain Impacts
- Justification of existing
process
- Implementation of NEW
process or materials
• System Safety
- Damage/Loss due to accidents
- Equipment unavailable
- Lost business due to cleanup
- Lost work days due to injury
- Worker / User / Bystander
fatality
- Litigation
• Performance
- Existing Process or Material
- O & S Impacts down the line
- New Process or Material
- Reduced capability
- Reduced availability
- Technological Maturity
- Availability in quantity?
- Operationally viable?
- Sustainable?
36. 36Aug 11
Knowledge Management
(Document Your Actions & Decisions)
• PM should:
• Perform post-deployment
evaluations
• Validate training material
• Document lessons learned
• Assess measures of quality
• Capture lessons learned from
other programs / legacy systems
• Apply CPI tools and lean
concepts to process areas
• Market Research & Studies to
introduce new technologies
when practicable
Change System/Component to
Eliminate Need for HAZMAT
Change System Documentation to
Specify Alternative
Change System Documentation to
Implement Alternative
Material/Process
Continue Using Existing HAZMAT
• Justify Why...
• Describe How...
• Ensure Controls Meet
Compliance Standards
• Implement HMMP
Decision Support & Business Intelligence Record of Decision > POA&M
37. 37Aug 11
Sustainable Manufacturing
Initiative (SMI)
• Sustainable Manufacturing: the creation of manufactured
products using processes that minimize negative environmental impacts,
conserve energy and natural resources, are safe for employees,
communities, and consumers and are economically sound. - DoC
Sustainable Manufacturing is based on three precepts:
• Limit Usage
• Use Renewable Resources when possible
• Manage Non-Renewable Resources
Sustainable manufacturing “meets the needs of the present without compromising the ability of
future generations to meet their own needs.” United Nations
Sustainable Manufacturing builds on several
life cycle considerations as outlined in the
graphic.
38. 38Aug 11
NIST on SM
Sustainable
Manufacturing:
“Ensuring a sustainable
future requires an integrated
system of systems approach.
Using a VSM, ACS, a New
Mexico company, was able
to eliminate excess
movement, materials, and
tooling to help create a
more streamlined product
flow. The company reduced
costs by 65%, increased production from 20 units per shift to 45 units
per shift, reduced its production facility size by 73%, and reduced
scrap rates from 24% to 1.8%.
39. 39Aug 11
DoD & Sustainable Manufacturing
• Defense Acquisition Guidebook highlighting SMfg:
• Acquisition Strategy element
• Component in EMD Phase as a production concept
• Source Selection factor for selecting manufacturer
• Corporate Social Responsibility
• Improve public perception of DoD
• Mitigate potential liability
• Cost Savings
• Process efficiencies
• Conservation of materials
• Balance – but mission comes first!
Executive Order 13423 - JAN 2007
• Reduce Greenhouse Gas emissions
• Use renewable energy
• Reduce water consumption
• Reduce HAZMAT
• Increase energy efficiency in buildings
• Procure energy efficient equipment
DAU CLM on Sustainable Manufacturing
41. 41Aug 11
ESOH and Lean
• Henry Ford: Was Lean before Lean was cool.
• TMMK: benchmarks energy consumption against
the rest of the industry using the ENERGY STAR
automobile assembly Energy Performance Indicator
(EPI). The results have been a reduction in energy
consumption per vehicle from from 6.3 MMBtu per
vehicle in 2004 to less than 4.53 MMBtu per vehicle
in 2008 for Plant 2.
• TIMWOOD + creativity
42. 42Aug 11
ESOH Benefits the User
• ESOH elements
• NEPA
• Safety
• Occupational Health
• Hazardous Material
Management
• Pollution Prevention
• Explosives Safety
43. 43Aug 11
ESOH Module Summary
• Assess ESOH risk early and often:
• PESHE
• NEPA
• System Safety
• Hazardous Material Program NAS 411
• Understand how hazardous materials impact cost, schedule &
performance
• Document results – use SEP, PESHE, TEMP as management
tools to document your ESOH program
• Conduct trade studies and use risk management to focus on
ESOH issues throughout the life cycle
• Influence the procurement process – in RFP/SOO/etc.
• Ask your service/program office ESOH representatives for help
44. 44Aug 11
ESOH Learning Objectives
Given student lecture, and classroom discussion will explain how
Environmental, Safety and Occupational Health (ESOH)
considerations are incorporated into the Systems Engineering
Process and Acquisition Lifecycle.
• Enabling Learning Objectives:
1. Describe the five major considerations for ensuring DoD’s compliance
with ESOH requirements.
2. Explain the aspects of Programmatic Evaluation of ESOH
considerations as documented by the Program Manager (PESHE).
3. Identify and discuss methods, tools and techniques used to manage and
mitigate ESOH risks.
Risk Management