USACE EM 385-1-1 Safety Manual
If you work on a U.S. Army Corps of Engineers (USACE) project, such as a dam, levee, lock, harbor, military base or federal building, your contract probably requires compliance with the Safety and Health Requirements Manual, EM 385-1-1. It goes beyond OSHA in many areas and carries contract consequences, such as stop-work orders, if it is not followed.
- Federal Contractors
- Site Safety & Health Officers
- Supervisors
- Subcontractors
- Project Managers
What EM 385-1-1 is
- EM 385-1-1 is the USACE manual of safety and health requirements for USACE employees and contractors on its construction, dredging, demolition, environmental and other projects. It's included in contracts through specification clauses.
- It covers general program requirements, medical support, fire protection, electrical, rigging, cranes, excavation, fall protection, confined spaces, hazardous energy, diving, floating plant and many other topics in a long series of sections.
- It's revised periodically. Use the edition named in your contract (check with the contracting officer), and read any changes between editions.
- It does not replace OSHA. OSHA's requirements still apply, and when both address the same topic, the more stringent rule generally governs. Many EM 385 requirements are stricter than OSHA, such as in training, fall protection and crane operations.
- Other agencies may have their own requirements, such as the Navy or the Department of Energy. See MSHA vs. OSHA for how rules differ by workplace type, and ANSI Standards.
Key program requirements
- Accident Prevention Plan (APP): a written plan for the project, describing management, responsibilities, hazards, training, inspections and emergency procedures. It must be submitted and accepted by USACE before work starts.
- Activity Hazard Analysis (AHA): a written analysis for each definable feature of work, listing the steps, hazards, controls, equipment, training and inspection requirements, reviewed and updated as work changes. Workers must be briefed on the AHA before starting. This is similar to a job hazard analysis. See Safety Programs.
- Site Safety and Health Officer (SSHO): a qualified person who is on site and responsible for the safety program, with training and experience requirements. The SSHO is typically required to be on site whenever work is going on, and has stop-work authority.
- Competent persons and qualified persons must be designated for tasks such as scaffolds, excavations, cranes and fall protection. See Competent & Qualified Persons.
- Training: required hazard training, first aid and CPR, and, for many projects, OSHA 30-hour and USACE-specific training such as the 30-hour construction course for supervisors and the 40-hour or other courses for SSHOs. Records must be kept. See OSHA Training Requirements.
- Safety meetings, inspections and reporting: regular toolbox talks and meetings, documented inspections, incident reporting and investigation, and monthly exposure reports to USACE.
- Phase and pre-work meetings to review the plan, hazards and controls before each phase of work.
Examples of stricter or specific requirements
- Fall protection is generally required at 6 feet, with some work needing protection at lower heights, and a written fall protection plan. See Fall Protection Plans.
- Cranes and rigging: detailed requirements for crane operators, inspections, load testing and critical lifts. See Crane Basics and ASME B30.
- Electrical safety: GFCI protection and lockout/tagout programs, and requirements for qualified electricians. See Lockout/Tagout.
- Confined spaces and excavation programs, with permits and competent person inspections.
- Water-related work such as personal flotation devices and diving or dredging requirements. See Water Rescue.
- Hazardous energy control and other programs must be written and followed.
Enforcement and working with USACE
- USACE safety specialists inspect projects, review APPs and AHAs, and can issue findings, notices, stop-work orders and deductions. Deficiencies are rated by risk. Repeated problems can affect performance evaluations and future contracts.
- USACE doesn't replace OSHA enforcement. OSHA may also inspect contractor sites, and OSHA rules apply to contractors. See OSHA Inspections.
- The prime contractor is responsible for subcontractors meeting EM 385 requirements. Flow requirements down in subcontracts. See Multi-Employer Worksites.
- Workers keep their rights to report hazards and to be free from retaliation. See Worker Rights and Whistleblower Protection.
Getting ready
- Read your contract's safety clauses and the edition of EM 385-1-1 named in it. The manual is free to download from the USACE website.
- Write the APP early and make sure the SSHO is qualified. Prepare AHAs for each phase and update them as conditions change.
- Make sure training and certifications are current for the crew and kept in records.
- Check each requirement against OSHA and adopt the stricter rule. See Construction Standards (1926).
- Ask your USACE representative if requirements are unclear. Document decisions in writing.
EM 385-1-1 checklist
- I know the edition of EM 385-1-1 in my contract
- The Accident Prevention Plan is accepted and a qualified SSHO is on site
- Activity Hazard Analyses exist for each phase and workers are briefed on them
- Training records and competent persons are documented
- I follow the stricter of EM 385-1-1 and OSHA, and flow requirements to subcontractors
Standards & references
Last updated: