USACE EM 385-1-1: Safety and Health Requirements for Construction

EM 385-1-1 requires contractors develop and implement comprehensive safety and health programs integrated throughout their organization. The safety program serves as foundational framework for all project-level safety activities. Written safety and health policies establish management's commitment to safety and communicate organizational values regarding worker protection. Policies address responsibility assignment, management accountability, and organizational commitment to compliance with applicable safety regulations and standards. Organizational structure and responsibilities define lines of authority, reporting relationships, and responsibility assignments ensuring all personnel understand their role in the safety program. Management accountability and metrics establish performance expectations and measurement systems tracking safety performance through lagging indicators like incident rates and leading indicators like near-miss reporting and hazard identification rates. Employee participation programs engage workers in safety decision-making, hazard identification, corrective action development, and program evaluation, recognizing that workers possess firsthand knowledge of job hazards. Hazard identification procedures establish systematic processes for identifying workplace hazards during planning, design, and execution phases. Control measures and safe work practices describe the specific actions, procedures, and safeguards used to eliminate or minimize identified hazards. Training and competency verification ensures all personnel receive appropriate training and demonstrate competency in their assigned tasks and safety responsibilities. Program evaluation and improvement establishes processes for periodic assessment of program effectiveness and implementation of continuous improvement actions. Contractors prepare safety manuals documenting their policies, procedures, and programs, distributing these to all project personnel. Management demonstrates commitment through policy endorsement, resource allocation including dedicated safety personnel, and active participation in safety activities including safety meetings and incident investigations.

EM 385-1-1 mandates development of comprehensive Accident Prevention Plans addressing all project-specific hazards and controls. The APP is living document customized to specific project activities, site conditions, environmental factors, and identified hazards throughout project execution. APP development begins during planning phases and continues as project scope changes, environmental conditions change, or new hazards are identified. The APP includes activity hazard analyses systematically examining each construction task and identifying associated hazards. Control measures specify engineering controls (such as guardrails), administrative controls (such as work procedures), and personal protective equipment (such as hard hats) addressing identified hazards. Responsible personnel assignments ensure all workers know their responsibilities and requirements. Training requirements identify training needed for all project personnel. Emergency procedures address response to injuries, medical emergencies, environmental spills, fires, and other foreseeable emergency situations. APP development is collaborative process involving project managers, safety professionals, supervisors, and workers. The APP serves as operational reference document guiding daily safety activities throughout project execution.

Each construction activity requires systematic hazard analysis identifying potential injuries and developing corresponding control measures. Activity hazard analysis begins with detailed description of the specific work task including task sequence, equipment used, materials handled, environmental conditions, and worker interactions. Work breakdown structure development identifies individual tasks requiring hazard analysis. For each task, hazard identification examines all potential injuries or illnesses that could occur: struck-by injuries from falling objects or moving equipment, caught-between injuries from machinery or collapsing materials, fall injuries from elevated work, electrical injuries from contact with energized equipment, burn injuries from hot materials or flames, chemical injuries from exposure to hazardous substances, and environmental injuries from heat, cold, or noise exposure. Injury severity assessment evaluates consequences of each hazard ranging from minor injuries requiring first aid through catastrophic injuries resulting in fatalities. Control measure selection applies hierarchy of controls prioritizing elimination of hazards, substitution of hazardous materials or processes, engineering controls such as guards and barriers, administrative controls such as work procedures and training, and personal protective equipment as last resort. Control effectiveness verification ensures selected controls actually prevent or reduce injuries through inspection, testing, and performance monitoring. Safe work procedure development documents the specific procedures required to perform tasks safely. Equipment and tool requirements specify tools and equipment needed for safe work execution. Personnel qualification requirements identify training and certifications required for workers to safely perform the task.

EM 385-1-1 requires documented training for all personnel with clear documentation of training content, attendance, and competency verification. Site orientation training provided to all personnel establishes baseline understanding of site hazards, safety rules, emergency procedures, and project-specific requirements. New employees receive comprehensive orientation before beginning work. Hazard-specific training addresses particular hazards associated with assigned tasks, such as confined space entry, fall protection, trenching, or equipment operation. Equipment operation certification ensures only qualified personnel operate equipment such as cranes, forklifts, or heavy machinery. Rescue and emergency procedures training prepares personnel for emergency response including first aid, CPR, rescue techniques, and evacuation procedures. First aid and CPR certification through recognized training providers provides emergency medical skills. Competency verification methods include written testing, skills demonstrations, and supervisor evaluation of job performance. Training records are maintained documenting training type, date, trainer, content, attendees, and test results. Refresher training occurs annually and whenever procedures change or near-misses indicate knowledge gaps. Competency assessment during performance evaluation ensures trained personnel continue applying learned safety practices throughout employment.