General Counsel Letter Regarding Use of DOE-STD-1212-2012 in Compliance with 10 CFR 851

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August 24, 2012

Office of General Counsel Guidance on the Effect of Replacement of DOE M 440.1-1A, DOE Explosives Safety Manual, with DOE-STD-1212-2012, Explosives Safety

Title 10 C.F.R. Part 851, Appendix A, § 3, Explosives Safety, at Subsection (b) requires that DOE contractors, including subcontractors at any tier, performing work at a DOE site "comply with the policy and requirements specified in the DOE Manual 440.1-1A, DOE Explosives Safety Manual, Contractor Requirements Document [CRD] (Attachment 2), January 9, 2006 (incorporated by reference, see § 851.27)." Section 3(b) also provides that, as an alternative, DOE contractors "may choose a successor version [of the Manual’s CRD], if approved by DOE."