As an LBNL employee, how do I know I’m performing work within the requirements of the Prime Contract C31?
Lab employees have various understandings of what the Prime Contract is and how it applies to them. The Prime Contract 31 (Prime Contract or Contract) is the Contract between the DOE and UC which establishes the requirements that LBNL must meet.
Just like Lab employees must perform their work within applicable federal and state regulations, employees must also perform their work, so the Lab is in compliance with the Prime Contract requirements. However, that doesn’t mean that each employee needs to memorize the Prime Contract in order to ensure compliance with each of the Prime Contract requirements. So how does LBNL ensure that the Prime Contract requirements are met? There are many methods used to ensure compliance with the Prime Contract requirements, such as the institutional assessment process. However, assurance that we meet the Prime Contract requirements begins before a new or revised requirement is implemented into the Prime Contract.
ICAO’s Contract Assurance program begins working with division leads, assurance leads, and subject matter experts from relevant divisions before a new or revised requirement is implemented into the Prime Contract to ensure that a complete impact analysis is completed to adequately assess the impact to the Lab, which may include, but is not limited to the cost, resource requirements, and the time required to implement the requirement. Once the requirement is implemented into the Contract an implementation analysis is performed to determine the appropriate implementation actions that must be performed in order to ensure compliance with the requirement by the Lab.
The implementation efforts may include actions such as creating or revising training programs, new or upgraded IT systems to accommodate actions required by the requirements, new or revised institutional documentation, or hiring additional employees or contractors to perform the work required by the requirement. This is not a complete list of implementation actions that may have to be completed but there are some common actions. These actions are how we ensure we are meeting the Prime Contract requirements and why each employee is not responsible for memorizing the Contract requirements. Prime Contract requirements flow down to our institutional documentation such as LBNL policies and procedures. By ensuring that our policies and procedures are in accordance with the Prime Contract and by providing adequate training to employees on these policies and procedures, employees can ensure they are following the Prime Contract requirements by completing work in accordance with the LBNL policies and procedures.
