# Presentation: 476122

## Compliance Verification Workshop

**Al Ford (SEA 07QB)**
**Deputy Director of Submarine Safety & Quality Assurance**

## Why does the Navy Submarine Community Care About Compliance Verification?

## USS THRESHER

**Notes:**
Because of this submarine

## WE WILL NEVER FORGET

**WE WILL NEVER FORGET**

## Submarine Safety Fundamentals

**Work Discipline**
- Knowledge of the requirements
- Compliance with the requirements
**Material Control**
- Correct Material Installed Correctly
**Documentation**
- Design Products (Specs, Dwgs, Maintenance Standards, etc.)
- Objective Quality Evidence (OQE)
**Compliance Verification**

**Notes:**
Work Discipline requires knowledge of the requirements, compliance with the requirements, and personal accountability.

Material control involves technical requirements, administrative requirements, and objective quality evidence requirements.

## SUBSAFE Compliance Verification

**Multi-layered approach**
- Contractor/Shipyard responsibilities
- Inspections, Surveillances, Document Reviews, Audits
- Local government oversight authority responsibilities
- Inspections, Surveillances, Document Reviews, Audits
- Headquarters responsibilities
- Document Reviews, Audits
**Multi-faceted approach**
- Facility Functional Audits
- Ship Specific Audits

**Notes:**
Compliance verification is a process, not just a step in a process or program.  We demand that each of our facilities participate fully in the process, including the use of inspection, surveillance and audits to confirm their own compliance.  We use our  audits to confirm that this process is working.

Contractor/Shipyard Responsibilities:
	Implement Specified Requirements
	Establish Processes For Controlling Work
	Establish Processes To Verify Compliance and Certify Its Work:
		Quality management system
		Surveillances
		Inspections
		Contractor QA witness critical work
		Internal audits
	Certify work to local government oversight authority

Local government oversight authority responsibilities:
	Surveillances
	Inspections
	QA witness critical contractor work
	Audits of the contractor
	Certify work of the contractor to Headquarters

Headquarters Responsibilities
Establish and specify SUBSAFE requirements
Verify Compliance
Functional (Institutional) Audits
Certification (Programmatic) Audits
Provide final SUBSAFE certification for each submarine

## SUBSAFE Audit Philosophy

**We Focus on Audits as a Constructive Experience**
**The Objective is Make Our Submarines Safer**
**We Assume Policies, Procedures, and Practices are in Compliance**
- The Audit Confirms Compliance

## SUBSAFE Audit Philosophy

**The Most Effective Audit is a Team Effort**
- Audit Team & Facility Personnel
- Continuous Communication is Key to Success
- And to Full Understanding of Identified Problems
**Audit is a Peer Review – 80% of Auditors Come From Other SUBSAFE Facilities and Live and Work in the SUBSAFE Program Every Day**

## SUBSAFE Compliance Verification

**Why does the Submarine Navy invest so much in Compliance Verification?****  **
- Because the consequences of failure are unacceptable.
**Our view is “Trust everybody but check up, because an honest mistake can kill you just as dead as malpractice.”**

## QUALITY ASSURANCE AND THE SINKING OF THE LARGEST OFFSHOREOIL PLATFORM

**QUALITY ASSURANCE AND THE SINKING OF THE LARGEST OFFSHORE****OIL PLATFORM**
**March 2001**

## For those of you who are subject to project schedule and cost pressures (at whatever level), 

**For those of you who are subject to project schedule and cost pressures (at whatever level), **

## please read this quote from a Petrobras executive, 

**please read this quote from a Petrobras executive, **

## extolling the benefits of cutting quality assurance and inspection costs, 

**extolling the benefits of cutting quality assurance and inspection costs, **

## on the project that sunk into the Atlantic Ocean off the coast of Brazil in March 2001. 

**on the project that sunk into the Atlantic Ocean off the coast of Brazil in March 2001.**** **

## "Petrobras has established new global benchmarks for the generation of exceptional shareholder wealth 

**"Petrobras has established new global benchmarks for the generation of exceptional shareholder wealth **

## through an aggressive and innovative program of cost cutting on its P36 production facility. 

**through an aggressive and innovative program of cost cutting on its P36 production facility. **

## Conventional constraints have been successfully challenged 

**Conventional constraints have been successfully challenged **

## and replaced with new paradigms appropriate to the globalized corporate market place. 

**and replaced with new paradigms appropriate to the globalized corporate market place. **

## Through an integrated network of facilitated workshops, 

**Through an integrated network of facilitated workshops, **

## the project successfully rejected the established constricting and negative influences of prescriptive engineering, 

**the project successfully rejected the established constricting and negative influences of prescriptive engineering, **

## onerous quality requirements, and outdated concepts of inspection and client control. 

**onerous quality requirements, and outdated concepts of inspection and client control. **

## Elimination of these unnecessary straitjackets has empowered the project's suppliers and contractors to propose highly economical solutions, 

**Elimination of these unnecessary straitjackets has empowered the project's suppliers and contractors to propose highly economical solutions, **

## with the win-win bonus of enhanced profitability margins for themselves. 

**with the win-win bonus of enhanced profitability margins for themselves. **

## The P36 platform shows the shape of things to come 

**The P36 platform shows the shape of things to come **

##  in unregulated global market economy of the 21st Century.”

** ****in unregulated global market economy of the 21st Century.”**

## And now you have seen the final result of this proud achievement by Petrobras. 

**And now you have seen the final result of this proud achievement by Petrobras.**** **

## Organizational Interrelationships

## The SUBSAFE

- SSGN

- In Service

- Deep
- Submergence

- SUBSAFE Director

- the four
- Naval Shipyards

- Supervisors
- of
- Shipbuilding

- Other SUBSAFE Activities:
- SUBMEPP, NAVICP, etc.

- Submarine **PROGRAM MANAGERS**

- COMSUBLANT
- &
- COMSUBPAC

- Shipbuilders
- EB & NGNN

***The ******SUBSAFE***
***Working Group***

**TECHNICAL AUTHORITY**
- NAVSEA 05

- Director Sub HM&E

- VIRGINIA

- the Fleet

**Technical Warrant**

- Senior Navy Officers oversee the Program

**Notes:**
SSOC - Provides independent command level oversight to ensure objectives of SUBSAFE Program are met

SSSTG - Provides guidance and direction for the SUBSAFE Program
READ THE GREEN BOOK – PAGE 97 - bottom

Submarine Program Mangers - Execute SUBSAFE Program for assigned ships

Tech Codes - Technical assistance to Program Managers and 07Q
	 -  SEA 05 final authority for tech requirements of SUBSAFE program

07Q - Administers the program and enforces compliance

The SSWG formally meets twice per year, but daily communications take place among its members

Ultimately, the purpose of the SUBSAFE Organization is to support the Fleet

## Organizational Interrelationships

- Program
- Manager

- Technical
- Authority

- SUBSAFE (SEA 07Q)

**SUBSAFE**
**Certification Authority**
- (PEO-SUB/SEA07)

- <date/time>10/16/03

**Notes:**
Each organization is separate with separate responsibility and authority for SUBSAFE Program requirements and compliance.

Our technical authority managers are empowered and accountable to make disciplined technical decisions.  They are formally given the authority, responsibility, and accountability to establish, monitor,and approve technical products and policy.

The Program Managers are responsible for executing the SUBSAFE Program for assigned submarines in new construction and major depot availabilities [0010].  

They have the authority, responsibility, and accountability to ensure compliance with technical policy and standards established by cognizant technical authority [5400.95].

SEA 07Q, The Director, Submarine Safety & QA Division, is responsible and accountable for implementation and management of the SUBSAFE Program, and for ensuring compliance with SUBSAFE Program requirements.

Ultimate certification authority is the Program Executive Officer for Submarines (PEO SUB) for new construction and the Deputy Commander for Submarines (SEA 07) for major depot availabilities.

The Program Manager, with the concurrence of and in the presence of the technical authority and the SUBSAFE office, presents the certification package to the certification authority.  When the certification authority accepts the certification package, he certifies that the SUBSAFE material condition of the submarine is satisfactory for sea trials or for unrestricted operation.

Requirements are clearly documented and achievable with minimal use of deviations & waivers.  There are formal procedures involving SEA 05 and 07Q for changes or departures from the requirements. 

## Technical Authority

**What is Technical Authority?**
- “The exercise of Technical Authority is a process that establishes and assures adherence to technical standards and policy...a range of technically acceptable alternatives with risk and value assessments....”
**Responsibilities of Technical Authority**
- Setting and enforcing technical standards
- Maintaining subject matter expertise
- Assuring safe and reliable operations
- Ensuring effective and efficient systems engineering
- Making unbiased independent technical decisions
- Providing stewardship of technical and engineering capabilities
- Being held accountable

## USS SAN FRANCISCO (SSN 711)		A Success Story

- USS SAN FRANCISCO (SSN 711)		A Success Story

## SSN 711 – A Success Story

- On 8 January 2005 at 1142 Guam time, the USS SAN FRANCISCO (SSN 711) crashed head-on into an underwater sea mountain.
- Major damage occurred to the front of the ship.
- Many crew members injured.  One died.
**The damaged ship was able to emergency blow to the surface and make it to Guam under its own power.**

## Slide 33

## Slide 34

## Slide 35

## Some Lessons Learned As Our Compliance Verification Processes Matured

## Lessons Learned

- Ship Certification Audits Alone Were Not Adequate
- Functional Audits of Facilities Were Needed
- Not Just Anybody Can Do SUBSAFE Work
- NAVSEANOTE 5000

**Notes:**
Prior to 1986 SUBSAFE Certification Audits were the only audits conducted.
SEA 04XQ periodically did quality audits (QPR – Quality Performance Reviews), but due to lack of funding that program died out. 
SSCAs were not rigorous and it was the opinion of team leaders that once an audit was completed, there would be no findings found if a follow-up audit was completed. BOTTOM LINE: WE GOT COMPLACENT!

Detailed independent process reviews were deemed necessary - hence the initiation of biannual functional audits for public and private yards. 
SUBMEPP, NUWC, NAVSEALOGCEN, and NAVSESS were later worked into Functional Audits as the importance of their roles to the integrity of the SUBSAFE Program became more appreciated. 

Since April 1987,  SUBSAFE Working Group (SSWG) membership has increased from 13 to 23.

In 1987 SEA 07, 05, Q, Submarine Platform Program Managers (PMSs), NAVSUP, and the two Submarine Type Commanders were members.  

Since then we have added SEA 07T, SEA 04X, both Private Yards, DLA/DCMA, SUBMEPP, NSWCCD-SSES, NUWC, and NAVSEALOGCEN

## Lessons Learned

- The Compliance Verification Organization Must Be an Equal With the Program Managers and the Technical Authority
- Headquarters Must Be Willing to Accept and Resolve Audit Findings Just Like Any Other Member of the Community
- You Cannot “Audit In” Requirements

## Lessons Learned

- Clear Ground Rules for Audits Must Be Established, Communicated, and Adhered to
- The Best Audit Teams Are Made up of Personnel Who Have a “Day Job” Working in the Business

## SUBSAFE

**A Requirement**
**An Attitude**
**A Responsibility**

## Slide 41