The U.S. Army Corps of Engineers (USACE) Safety and Health Requirements Manual, otherwise known as the EM 385-1-1, is being revised. The current release date is 15 March 2024 with a new name, “Safety and Occupational Health Requirements”.
The USACE EM 385-1-1 applies to all construction contract work awarded under the provisions of FAR Clause 52.236-13. Interestingly, all new contracts for maintenance, service, research and development, and supply, as well as, contracting actions for hazardous, toxic, and radioactive waste site investigation, design, or remediation activities are now required to follow the safety requirements of the EM 385-1-1.
Contractors must comply with the version of this manual (including interim changes) that was/is in effect at the date of solicitation. All existing contracts will continue to apply the provisions of the previous EM 385-1-1 edition until contract completion.
The implementation of the new EM 385-1-1 is designed to supplement existing Safety and Occupational Health manuals and requirements as described in the preamble of the new manual, including the 29 CFR 1910 and 1926 plus seven others. In addition, each Chapter features its own dedicated reference list.
Contractors are also being encouraged to adopt a performance-based safety management system within their organizations, although it is not mandatory.
Activity Hazard Analysis
Along with a completely overhauled EM 385-1-1, are new formatting requirements for all Activity Hazard Analyses, which now require reference number for each step, hazard, and control; and in most cases, each control must display its corresponding references separately.
Although this is much more work and seemingly more complicated than previous requirements, Gadzoom has developed unique features to make this much easier than it sounds. In fact, we have found that the new changes being implemented actually create a clearer and more comprehensive AHA than ever before.
Accident Prevention Plans
Changes to the Accident Prevention Plan, as well as additional supplemental safety plans, are also being implemented. Although the 2024 EM 385-1-1 only contains somewhat broad rules for an APP outline, a new eight-page APP cover sheet, CESO ENG Form 6293, provides new direction in relation to formatting of APPs and inclusion of supplemental safety plans. The new cover sheet is not a replacement for the APP but is supplemental and a guide and checklist for properly assembling the safety documentation for the project. It also provides an easy and straightforward synopsis of the APP, with its most significant and relevant information, for both reviewers and field personnel.
Another new form, ENG Form 6282, is being required in addition to each SSHO appointment letter to designate the SSHO’s level of experience, provide a summary of training, and to provide certification of the correctness of both by signature of the SSHO appointee and their respective company Safety and Occupational Health Official.
The changes to the APP, as well as existing and new plans, are substantial and complex. Gadzoom’s entire team is working on incorporating these changes along with additional new and innovative features for release this month, in hopes of beating any applicable contract awards.
Safety is everyone’s responsibility.
The Corps of Engineers requires each employee on site to be responsible for implementation and compliance with the SOH program in the workplace and mandates that the approved APP and AHAs be always readily available to every employee. The ability to have unfettered access to these documents and the information contained within is key to a safe workplace. Gadzoom firmly believes in this concept, is embracing it, and is working to make the free flow of information occur in ways never imagined before!
About Gadzoom
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