After nearly 3 years in its revision, the United States Army Corp of Engineers (USACE) EM 385-1-1, Safety and Health Requirements Manual, 2014 version is in final vetting status. It is awaiting signature to be sent for publication by the US Government Printing Office (GPO). The planned date for signature was August–September 2014; however, these dates are rapidly coming to a close without a final signature as yet from senior command at the USACE.

The final version, reportedly the version to be signed, is posted at: www.usace.army.mil/SafetyandOccupationalHealth/EM38511,2008BeingRevised.aspx

The revised EM 385-1-1 2014 will be approximately 950 pages (vs. 1,100 pages in the 2008 version). Many of the revisions were in response to the over 750 comments submitted to the USACE and the focus of the revisions are the result of extensive collaboration with industry, government, and the public.

Compliance with the EM 385-1-1 is required by nearly all contractors working on military contracts. This includes those contractors working on Naval Facilities Engineering Command (NAVFAC), U.S. Army Corps of Engineers (USACE), Department of Defense (DoD), or other government agency contracts. Contractors need to be keenly aware of the requirements and associated revisions.

Although the USACE’s “Safety and Health Requirements Manual” has been in place nearly 30 years prior to the enactment of OSHA and adoption of the OSHA standards, several revisions have occurred throughout the years. What has triggered the need for the recent revisions? The USACE has reported that “poor planning, increased injuries, and lack of proper documentation” were the driving elements for the latest changes.

Some of the many section revisions in EM 385-1-1 2014 include:

  • Section 1: Program Management. Revisions to this section include edits to the written, site-specific Accident Prevention Plans (APP’s) requirements and detailed Activity Hazard Analyses (AHA’s) that identify tasks, potential hazards, and control strategies. The APP is a detailed, site-specific written plan that describes the management processes to prevent accidents. Elements include Signature Sheet, Background Information, Statement of Safety and Health Policy, Responsibilities and Lines of Authority, Subcontractors and Suppliers, Training, Safety and Health Inspections, Accident Reporting, Plans required by the Safety Manual, Risk Management Processes, and Abbreviated APP for Limited Scope Service. AHA’s shall define the activities being performed and identify the work sequences, the specific anticipated hazards, site conditions, equipment, materials, and the control measures to be implemented to eliminate or reduce each hazard to an acceptable level of risk. Site Safety and Health Officers (SSHOs), experienced with 5 years continuous experience, will be a “full time” responsibility, with the SSHO present at the project site, located that they have full mobility and reasonable access to all major work operations during the shift. The SSHO shall also be an employee other than the supervisor unless otherwise specified by contract or coordination with the local USACE. Revisions surrounding an SSHO’s education and experience are also included in the EM 385-1-1, 2014. The SSHO’s training requirements include 30-hour OSHA Construction or General Industry safety class or equivalent (may be web-based training if the student is able to directly ask questions of the instructor by chat or phone),  or as an equivalent, formal construction or industry safety and health training covering the subjects of the OSHA 30-hour course and the EM 385-1-1. There is also the annual 8-hour refresher training requirement.
    A unique revision to the EM 385-1-1, Program Management Section 1 is the addition of requirements for “Fatigue Management” planning. A Fatigue Management Plan must identify affected workers, management responsibility, training, and controls established at the worksite.
  • Section 5: Personal Protective and Safety Equipment. Several revisions have occurred to hearing protection and noise control, as well as hand protection.
  • Section 6: Hazardous and Toxic Agents or Environments. One will recognize familiar Globally Harmonized System (GHS) and OSHA HAZCOM wording. Heat and Cold Stress Management is another important section that will be enforced on both CONUS (Cont. U.S.) and OCONUS (Outside U.S.) locations.
  • Section 15: Rigging/Section 16: Load Handling Equipment. Those familiar with OSHA’s Subpart CC Crane regulations will recognize new requirements for riggers, signal persons, and crane operators experience and credentials, as well as documented and approved lift plans.
  • Section 21: Fall Protection. Pay careful attention to the new training requirements which include a minimum of 24 hours, with a combination of at least 16 hours of formal classroom training and 8 hours of practical application, and performed by a Competent Person (CP) trainer or a Qualified Person (QP) trainer conforming to the requirements of ANSI/ASSE Z490.1, Criteria for Accepted Practices in Safety, Health and Environmental Training.
  • Section Removals and Migrations. Most notably: Section 28 Hazardous Waste Operations and Emergency Response is now Section 29. Steel Erection is now Section 28, extracted from Section 27 Concrete, Masonry, Steel Erection and Residential Construction. Section 29 Blasting, Section 30 Diving Operations, Section 33 Munitions and Explosives of Concern are slated to be removed in their entirety. Section 34 Confined Space Entry is now Section 33 with 4 additional pages, and includes a Decision Flow Chart and Entry Permit.
  • Appendices. Many helpful document templates can be found in the appendices including Accident Prevention Plan (APP’s), Mishap Reports, and Crane Lift Plans.

The new EM 385-1-1 can be reviewed online at the following link:
www.usace.army.mil/SafetyandOccupationalHealth/EM38511,2008BeingRevised.aspx

You can also access a new iTunes App for $9.99 at:
itunes.apple.com/us/app/em-385-1-1/id396131219?mt=8
The US Army Corps of Engineers has a long and proud tradition supporting our nation’s work efforts. Elements of EM 385-1-1 can be useful to even a non-government type of safety programs to promote compliance with OSHA regulations as there is overlap.

There are significant revisions to the EM 385-1-1. Knowledge and training on these new revisions will promote compliance within your organization to prevent injury, illness, mishaps, related risk, and the potential for job shutdowns.

For information on the new EM 385-1-1 8-hour online course available through ClickSafety.com, contact www.clicksafety.com, or email Paul Colangelo at paul.colangelo@clicksafety.com. ■

About The Author:

Paul J. Colangelo, STS, CHST, CET currently serves as the national director of compliance programs for ClickSafety.com. Mr. Colangelo is a 14-year accredited OSHA Outreach 10- and 30-hour construction program trainer and certified AHA, ECSI CPR instruction. He has 24 years of experience as an EHS director, manager, and consultant to the Construction, Telecommunications, and Utility and Renewable Energy sectors. His services include establishing written safety programs, record keeping, site safety auditing, incident investigation, communication techniques, subcontractor management, and training. He has created and delivered hundreds of OSHA Outreach and specialized safety training programs.

Modern Contractor Solutions, October 2014
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