NASA Procedural Requirements

NPR 8715.1B Effective Date: February 01, 2021 Expiration Date: February 01, 2026

Subject: NASA Safety and Health Programs

Responsible Office: Office of Safety and Mission Assurance

Chapter 3. Management of Institutional Safety Requirements and Request for Relief from Agency Institutional Safety Requirements

3.1 Management of Institutional Safety Requirements

3.1.1 Institutional Safety Authority

3.1.1.1 NASA's governance framework is designed to include a comprehensive system of independent authorities. Institutional Safety Authority, the implementation of which is overseen by the Chief, Safety and Mission Assurance, ensures Agency compliance with safety requirements to protect the safety of the workforce, public, and high-value assets established by law, NASA policy, or other external or internal authority.

3.1.1.2 Institutional Safety Authority at Centers and Facilities resides with the Center Directors. They serve as the designated Agency-level "official voice" for institutional safety and the associated requirements established by NASA policy, law, and other external mandate aimed at protecting the public, NASA workforce, and high-value assets from potential harm.

3.1.1.3 SMA Directors assist Center Directors with the implementation of the Institutional Safety Authority and serve as the Center focal point for Institutional Safety Authority providing independent oversight and communication lines to both the Center Director and Chief, SMA.

3.1.1.4 Centers may designate additional positions within their organization as members of the Institutional Safety Authority. Centers shall document all such positions.

3.1.2 Institutional Safety Discipline Leads

3.1.2.1 Centers shall appoint Institutional Safety Discipline Leads as defined in section 2.6.

3.1.2.2 Institutional safety discipline leads support the implementation of the Institutional Safety Authority by serving as subject-matter experts for the safety discipline they oversee. Common duties include the development of policies, requirements, process, and procedures to manage their discipline area at the Center and Facilities, and the determination of requirements applicability, compliance, and equivalent levels of safety.

3.1.2.3 In case of disagreement with determinations by Institutional Safety Discipline Leads, organizations may appeal such determinations to the SMA Director or Center Director.

3.1.2.4 Authority to conduct Center operations once a determination of noncompliance has been made can only be provided in accordance with section 3.2.

Note: If a determination of noncompliance has been made for a project operation that does not impact the public, NASA workforce, or NASA facility, the institutional safety authority may allow the request for relief to be obtaining using the projects process.

3.1.2.5 Regardless of the organization in which Institutional Safety Discipline Leads reside, Centers shall maintain independent communication paths between those leads and the SMA Director, then to the Center Director, to avoid undue influence on their functioning.

3.2 Request for Relief from Agency Institutional Safety Requirements

3.2.1 Overview

3.2.1.1 It is NASA policy that all requirements are complied with unless relief is formally granted. An approved request for relief is a documented authorization releasing a responsible party from meeting a requirement. All documented authorizations of relief become part of the organization's records.

Note: Requests for relief are frequently referred to as either waivers or deviations.

3.2.1.2 Policy and responsibilities cannot be relieved. The only way to make a change or alteration to a policy is to formally and universally change the policy. Responsibilities can only be reassigned.

3.2.1.3 NASA cannot authorize relief from external requirements, such as Federal, state, or local regulations, voluntary consensus standards incorporated by reference in Federal regulations, or NASA standards approved as alternate or as supplementary to a Federal standard. Requests for relief from a Federal, state, or local safety regulation are reviewed by the NASA Headquarters Office of Safety and Mission Assurance and submitted by the Designated Agency Safety and Health Official to the appropriate Federal, state, or local agency for approval.

Note: State and Local regulations and standards do not apply to Federal activities and installations, except as otherwise provided by Federal law or express agreement.

3.2.1.4 This chapter is only for relief to Agency institutional safety requirements for which Office of Safety and Mission Assurance (OSMA) is the Office of Primary Responsibility. Relief from Agency institutional health requirements can only be granted by OCHMO.

Note: Relief from Agency institutional health requirements can only be granted by OCHMO. If Submitting Authority's request includes institutional health requirements, contact Center health officials.

3.2.2 Approving Authority for Requests for Relief

3.2.2.1 As defined in NPR 1400.1, NASA Directives and Charters Procedural Requirements, the Approving Authority is the person or organization responsible for oversight of the requirement and authorized to grant relief from the requirement.

3.2.2.2 The Approving Authority shall elevate requests for relief exceeding his or her authority. The Approving Authority cannot authorize relief from externally mandated requirements (e.g., Federal statutes and regulations) or from NASA requirements not under its purview.

3.2.2.3 The Chief, SMA delegates approving authority to the applicable Center Director except as stated in 3.2.2.4.

3.2.2.4 The Approving Authority for granting relief is the Chief, SMA when the relief is for:

a. An entire standard or substantial portion of a standard incorporated by reference in this directive or a substantial portion of this directive.

b. Relief from requirements in section 3.1 of this document.

c. A request for relief that requires coordination between centers or impacts the public not located near the Center.

Note: For a request for relief that impacts the public not located near the Center, the Chief, SMA may need to elevate granting the relief to the Administrator in accordance with NPD 8700.1.

3.2.2.5 Center Directors may delegate their authority to grant relief from requirements to the Deputy Director, Associate Director, or SMA Director with the following stipulations:

a. The Center Director remains responsible for the relief granted and for the impact of the relief.

b. Center Directors shall not delegate the authority below the Deputy Director or Associate Director if after risk reduction measures are taken the risk of noncompliance is assessed by the appropriate Institutional Safety Discipline Lead to be more than a minor increase to personnel injury or a significant risk to property.

3.2.3 The Submitting Authority for Requests for Relief

3.2.3.1 The Submitting Authority is the person or organization seeking relief. The Submitting Authority shall document the following information:

a. Identify the requirement(s) for which relief is being sought.

b. Describe the request for relief (i.e., the nature of the proposed departure from the requirement).

c. Justify the reasons for the relief, why it is not possible, or desirable, to comply with the requirement within the specified delivery schedule.

d. Determine the initial and residual risk and document the acceptability of the resulting change in risk.

e. Confirm the relief does not conflict with applicable Federal statutes or regulations, or with Agency policy.

f. Indicate when compliance will be achieved or indicate that the request is permanent if compliance is not planned or not possible.

g. Describe alternate actions to be taken for managing the risk.

h. Describe conclusions and recommendations from the Center Institutional Safety Discipline Lead, resolution of recommendations, and if a recommendation to not approve is made by an Institutional Safety Authority, an explanation why it was made.

3.2.3.2 The Submitting Authority accepts the risk associated with the relief when submitting the request for relief. Relief is not granted until the request has been fully processed and approved by the Approving Authority.

3.2.3.3 Regardless of whether the Center Director is the Submitting or Approving Authority, the Center Director is and remains accountable for the safety of people and property at the Center and for the impact of hazards created or controlled by the Center, including accountability for accepting risks associated with the relief from requirements.

3.2.3.4 Appendix D provides an example Request for Relief (RFR) form. This form is not mandatory. Centers may use other methods of documentation provided relevant information to shown compliance with this NPR is captured.

3.2.4 The appropriate Institutional Safety Authorities and Institutional Safety Discipline Leads shall review and provide a recommendation to approve or disapprove, with appropriate comments, for the Approving Authority to consider when making a final decision to approve or disapprove the request for relief.

3.2.5 Any Institutional Safety Authority or Institutional Safety Discipline Lead may request the addition of an OSMA assessment for the Approving Authority to consider when making a final decision to approve or disapprove the request for relief.

3.2.6 Institutional Safety Authorities shall ensure substantive disagreements are handled through the formal dissent process outlined in NPD 1000.0.

3.2.7 Reporting Authorized Relief

3.2.7.1 For relief authorized at the Center, the Approving Authority shall inform OSMA of any granted relief to Agency requirements with more than a minor increase to personnel injury or a significant risk to property.

3.2.7.2 Center SMA Director shall provide request for relief information upon request from OSMA.

3.2.7.3 Center Institutional Safety Discipline Leads shall report annually to the Center Director and OSMA all active granted reliefs from requirement in their area of responsibility.

3.2.7.4 The Center does not need to report relief from requirements in standards adopted voluntarily by the Center. The Center shall provide these requests for relief upon request. This is to evaluate the Center's safety and health management, quality assurance, and risk management processes.

3.2.8 Records of Relief

Centers shall maintain records of requests for relief according to the NRRS 1441.1, NASA Records Retention Schedules.

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