NIST S 7101.05 (Uncontrolled Copy in Print) Page 1

1

2

3 Management Observation Process

4

5 NIST S 7101.05

6 Issue Date: 08/08/2019

Effective Date17 : 04/01/2020

8

9

10 1. PURPOSE

11 The purpose of this suborder is to establish the requirements and associated responsibilities 

12 for a Management Observation Process (MOP) to help prevent workplace injuries, illnesses,

13 and other incidents to improve safety of operations and the workplace.

14

15

16 2. BACKGROUND

17 The Management Observation Process (MOP) is an element of the NIST safety management 

18 system designed to promote safe operations and continual improvement by facilitating an

19 ongoing and frequently occurring conversation about safety between staff and line 

20 management. The purpose of the MOP is to: (1) help prevent injuries, illnesses, and incidents 

21 by increasing dialogue with workers on creating a safe workplace; (2) observe workers’ 

22 behaviors without threat of punishment; and (3) provide positive reinforcement of safe work 

23 practices and behavior. The MOP also provides an opportunity for managers to demonstrate 

24 commitment to safety by regularly engaging staff in conversations about safety and by 

25 supporting improvements to workplace safety.

26

27

28 3. APPLICABILITY

29 The provisions of this suborder apply to all OU Directors and subordinate managers at all 

30 NIST workplaces.

31

32

33 4. REFERENCES

34 a. Public Law 91‐596, (Williams‐Steiger) Occupational Safety and Health Act of 1970;

35

36 b. Executive Order 12196, Occupational Safety and Health Programs for Federal Employees;

37

1 For revision history, see Appendix A.
NIST S 7101.05 (Uncontrolled Copy in Print) Page 2

38 c. 29 Code of Federal Regulations (C.F.R.) Part 1910, Occupational Safety and Health 

39 Standards;

40

41 d. 29 C.F.R. Part 1926, Safety and Health Regulations for Construction; and

42

43 e. 29 C.F.R. Part 1960, Basic Program Elements for Federal Employee Occupational Safety and 

44 Health Programs and Related Matters.

45

46

47 5. APPLICABLE NIST DIRECTIVES

48 a. NIST O 7100.00: Occupational Safety and Health Management System; and

49

50 b. NIST S 7101.20: Work and Worker Authorization Based on Hazard Reviews.

51

52

53 6. REQUIREMENTS

54 a. All NIST managers shall participate in the OU’s MOP program.

55

56 b. Each OU shall develop a MOP program that specifies: 

57

58 (1) The frequency of annual MOP visits for each level of manager;

59

60 (a) The following should be considered in determining the frequency of visits:

61

62 i. The nature of work conducted and, specifically, the hazards present; 

63

64 ii. Rate of change in the type of work, procedures used, materials used, people 

65 performing work; and 

66

67 iii. Level of engagement required for managers to maintain an appropriate level 

68 of knowledge concerning safe work practices, including hazard mitigation 

69 strategies and controls used, and of safety improvement needs.

70

71 (2) The plan for coverage with respect to locations, activities, and staff including supervisors; 

72

73 Note: Managers should strive to ensure that MOP interactions with all staff occur within 

74 a reasonable timeframe. Priority should be given to more hazardous activities and 

75 work locations.

76

77

78
NIST S 7101.05 (Uncontrolled Copy in Print) Page 3

79 (3) The process for:

80

81 (a) Tracking to completion any recommended or required improvement(s) as well as any 

82 corrective action(s) identified; and 

83

84 (b) Communicating the results of those actions to MOP participants; and

85

86 (4) The requirement for line management accountability. 

87

88 c. The MOP shall be conducted in a manner that:

89

90 (1) Promotes open discussion without fear of reprisal among staff and managers regarding 

91 safety of operations and workspaces; and

92

93 (2) Leads to better understanding of the safety aspects of the specific work being conducted 

94 and the workplace in which the work is conducted. 

95

96 d. The MOP shall be performed in work locations where managers can observe and discuss 

97 work practices and workplace conditions.

98

99 (1) In locations where the conduct of work is covered by an approved hazard review or JHA, 

100 managers should:

101

102 (a) Ensure the hazardous work is covered by a hazard review or JHA; and 

103

104 (b) Discuss the adequacy of the controls used to mitigate hazards.

105

106 (2) Where work is primarily office-based, managers should discuss implementation of office 

107 safety and general safety requirements.

108

109 e. Managers shall work with staff to identify opportunities for improving workplace safety by 

110 identifying preventive actions that focus on hazard reduction and risk mitigation and provide 

111 support for these improvements. 

112

113 (1) When a weakness or poor practice is observed, managers should recommend or require, 

114 as appropriate, safety improvements without taking punitive measures.

115

116 f. Managers shall recognize and promote best safety practices and safe behaviors observed or 

117 discussed during MOP visits by:

118

119 (1) Providing positive feedback to MOP participants; and
NIST S 7101.05 (Uncontrolled Copy in Print) Page 4

120 (2) Where appropriate, communicating support for the observed practices and behaviors 

121 more widely (e.g., at staff meetings, via emails, through newsletters).

122

123

124 7. DEFINITIONS 

125 There are no definitions specific to this suborder. Please see NIST O 7100.00 for other 

126 definitions.

127

128

129 8. ACRONYMS 

130 a. MOP – Management Observation Process 

131

132

133 9. ROLES AND RESPONSIBILITES

134 a. OU Directors:

135

136 (1) Ensure MOP is implemented within their OU.

137

138 (2) Ensure line managers are accountable for implementing MOP in their areas.

139

140 b. Line management:

141

142 (1) Implements MOP according to OU requirements.

143

144 c. NIST employees and covered associates:

145

146 (1) Actively participate in MOPs conducted in their workspaces.

147

148

149 10. AUTHORITIES

150 None required

151

152

153 11. DIRECTIVE OWNER

154 Chief Safety Officer

155

156

157 12. APPENDICES

158 A. Appendix A. Revision History

159 B. Examples of Implementation

160

161
NIST S 7101.05 (Uncontrolled Copy in Print) Page 5

162 Appendix A. Revision History

163

Revision

No.

Approval

Date

Effective

Date Brief Description of Change; Rationale

0 08/08/19 04/01/20 Revision of NIST Administrative Manual 

Subchapter 12.07 

164
NIST S 7101.05 (Uncontrolled Copy in Print) Page 6

165 APPENDIX B. EXAMPLES OF IMPLEMENTATION OF MANAGEMENT OBSERVATION 

166 PROCESSES. 

167

168 There can be substantial variation in how each OU implements the MOP in its organization.

169 One model is that used by Oak Ridge National Laboratory. Four observations are conducted

170 quarterly by the organization directors, typically lasting about one hour (a half hour is more

171 typical of an office operation). The managers focus on the work and ongoing processes during

172 the conversation. No notes are taken during the conversation to emphasize the listening

173 process. Summaries of the MOP (typically 100 to 200 words) are written after the conversation

174 and entered into a database. The information gathered should reflect the quality and depth of

175 the conversation.

176

177 Examples of safety‐related discussion points include the following:

178

179 ▪ Personal safety expectations and how they relate to the work being performed;

180 ▪ How well workers understand hazards of their work and controls necessary to work safely;

181 ▪ The most common injuries and what the workers can do to prevent them;

182 ▪ Suggestions that the workers have to improve safe operations in their work environment;

183 ▪ The need for additional management support to resolve a safety concern;

184 ▪ The comfort level of workers to report minor safety incidents and near‐accidents;

185 ▪ The process that workers can use to resolve safety issues.

186

187 A second model for opening lines of communication with the staff on issues like safe research

188 operations and safe behaviors in the workplace, is through a regular, unforced, on‐going

189 dialogue. A popular and effective tool that line managers frequently use is management‐by190 walking‐around (MBWA). The characteristics of MBWA are personal involvement and good 

191 listening skills. This activity typically involves each line manager setting aside enough time each 

192 day to engage staff and subordinate managers in a dialogue involving many different topics 

193 including—but not limited to—questions about their particular work, their work environment, 

194 security, safety, even updating them on current NIST news & events, and any other staff 

195 concerns. This is also an excellent opportunity for making positive comments and getting 

196 feedback.

197

198 This model is easily adaptable to meet the NIST requirements. In this case, the MOP involves all

199 line managers in the OU. Documentation of follow‐on actions is required where specific

200 corrective actions are necessary and formal documentation is warranted to ensure that the

201 corrective measures are executed. Each line manager is accountable for active participation in the 

202 MOP, and this accountability is reflected in the performance plan. OU Directors, OU

203 Deputies, Division Chiefs, Group Leaders, and Team/Project Leaders cover the entire work

204 environment, engaging the staff in each setting in active discussions regarding work‐related

205 topics including safe research operations and work behaviors. This does not mean that any one

206 line manager is required to cover all of this space or engage all staff. As a rule of thumb, the

207 collective line management team should cover all work areas at a frequency commensurate

208 with the level of hazards and changing conditions, which could translate to a frequency as often

209 as weekly.