P.O. Box 29939 tf >} a 405184 ky OO] & ef Mahlon E. Gates Manager, NV ik Is WE mp NOL WNT Mm Sf} 9 A og* & A FEB 21 1978 Honolulu, Hawaii 96820 ~ QI} ~NI™. PRIVACY ACT MATERIAL REMOVED Department of Energy Pacific Area Support Office be 0 “ FOR MR. GATES EYES ONLY oF BS 5 o 9 4 6 z « w a 8 5 3 NV SAFETY POLICY AND IMPLEMENTATION THEREOF For the past two plus years, I have felt a growing concern that there is a wide gap, in the subject area, between the lessons we learned, or Should have learned, from the past history of nuclear testing at NV, and the actions we are taking currently in the area of employee safety. I have expressed this concern to appropriate members of the NV staff, but have been largely unsuccessful in getting anything done to eliminate what I perceive as a serious problem. To me, it is incomprehensible in today's world of abundant handy-dandy legal actions against anything nuclear, or OSHA related, that it is not only possible, but is specifically permitted, by NV personnel regulations, to hire an employee, and put him or her to work in any environment without some kind of a pre-employment physical. Yet that is the case. Had I not insisted, when was hired, that he receive a physical examination because of his proposed assignments at Enewetak and Johnston, he would not have received an examination. Euphemistically we had to call this a "periodic" fitness for duty examination, because otherwise the’ cost thereof would not have been allowable. This, in my opinion, is not only a ridiculous situation, it is downright dangerous. Nuclear matters aside, under current procedures, NV could hire an employee with tuberculosis, syphilis, or you name it, and the only way the employee (and those he may have infected) would know it, would be when he or she was called in to REECO for the periodic physical (which is not mandatory). So much for direct NV employees. The following pertains to both direct Government and NV contractor employees who are assigned to Enewetak or Johnston Atoll. As you are aware, NV operations at Johnston and Enewetak are, in the main, funded by DNA. As a direct consequence of this funding situation, NV contractor activities at these sites are not subject to the same review, safety-wise, as they would if these activities were DOE funded. I can not distinguish between your responsibility, and mine, for the safety of an NV employee at Enewetak simply because of the "color of the money". The rationale for this policy, is that since neither PASO nor NV has the economic FOR MR. GATES EYES ONLY PRIVACY ACT MATERIAL: RE MOVED