INTRODUCTION

EM-385 is NOT a new model of diesel-electric car!  It is the Safety & Health Requirements Manual published by the US Army Corps of Engineers (USACE) for DoD projects, and it is serious business.
                       
The requirements in the USACE EM-385-1-1 Manual are MANDATORY for contractors who work on military installations.  If you hope to profit by performing contract work on Department of Defense property, you need to be thoroughly familiar with this manual.  At first glance, it looks a lot like the OSHA 29CFR Part 1926 regulations for construction.  In fact, it is a lot like it, but there are differences in some details, and the Devil is truly in the DETAILS.  You are unlikely to win a contract in the first place if you have not at least met the administrative requirements for safety plans; activity hazard analyses; hazard communication requirements; and a small mountain of other paperwork.  However, having met all of these, you can still find yourself in serious trouble if you overlooked the differences between Part 1926 and EM-385 in those critical details.   A contracting officer can stop your work if noncompliance with one or more of those little details is determined to be a contract violation, and the penalty for late completion may be $2,000 a day.  

The administrative end of these projects is a much bigger deal than what you might expect.  A Project-specific Accident Prevention Plan (APP) must be submitted on request, and you can lose the contract if it is judged to be inadequate.  They want something much more detailed than the basic Incident & Injury Prevention Plan (IIPP) we are all required to maintain under Cal/OSHA requirements.  They want real details that specifically address the risks involved in the activities of the project.  This plan must be based on detailed studies of the potential hazards involved in the project.  A separate Activity Hazard Analysis (AHA) must be conducted for each activity in each phase of the project.  Each AHA must provide detailed information on the precautions and control measures to be utilized for each identified hazard.  The EM-385 manual goes into great detail about these and other planning and safety management issues. If you fail to address all of the elements, your plan (and you) will likely be rejected.

After clearing these rather formidable hurdles, you start the job and sometimes get into worse trouble.  While the EM-385 regulations match up well with OSHA rules in the Construction Safety Orders for the most part, experienced safety professionals can easily overlook the differences in specific requirements. That’s why the Department of Defense requires proof of training that covers the use of the USACE Safety and Health Manual.  And that’s why we are offering this course.

Our approach is based on the principle that new information can be absorbed more readily by starting from familiar territory – the OSHA Construction Safety Orders.  Our combined course follows the standard 10-Hour OSHA Construction Outreach Program and connects the dots by discussing specific points of difference as each topic is being covered.  

Students who successfully complete the course will receive a 10-Hour OSHA Outreach Program card plus a GENI® certificate for the full course.  

HERE'S WHAT THE LATEST (2008) EDITION OF THE EM-385 MANUAL SAYS ABOUT ONE ELEMENT OF THE APP:

1. RESPONSIBILITIES AND LINES OF AUTHORITIES.  Provide the following:
1. A statement of the employer’s ultimate responsibility for the implementation of his SOH program;
2. Identification and accountability of personnel responsible for safety at both corporate and project level. Contracts specifically requiring safety or industrial hygiene personnel shall include a copy of their resumes. Qualifications shall include the OSHA 30-hour course or equivalent course areas as listed here:

1. OSH Act/General Duty Clause;
2. 29 CFR 1904, Recordkeeping;
3. Subpart C: General Safety and Health Provisions, Competent Person;
4. Subpart D: Occupational Health and Environmental Controls, Citations and Safety Programs;
5. Subpart E: PPE, types and requirements for use;
6. Subpart F: understanding fire protection in the workplace;
7. Subpart K: Electrical;
8. Subpart M: Fall Protection;
9. Rigging, welding and cutting, scaffolding, excavations, concrete and masonry, demolition; health hazards in construction, materials handling, storage and disposal, hand and power tools, motor vehicles, mechanized equipment, marine operations, steel erection, stairways and ladders, confined spaces or any others that are applicable to the work being performed.

1. The names of Competent and/or Qualified Person(s) and proof of competency/ qualification to meet specific OSHA Competent/Qualified Person(s) requirements must be attached. The District SOHO will review the qualifications for acceptance;
2. Requirements that no work shall be performed unless a designated competent person is present on the job site;
3. Requirements for pre-task safety and health analysis;
4. Lines of authority;
5. Policies and procedures regarding noncompliance with safety requirements (to include disciplinary actions for violation of safety requirements) should be identified;
6. Provide written company procedures for holding managers and supervisors accountable for safety.

WHO NEEDS THIS COURSE, AND WHY? 

There are several categories of project personnel who must provide documentation of training on the EM-385 Manual.  Project Managers, Safety Managers, and Site Safety Officers must have current OSHA cards for the 30-Hour Outreach Program PLUS at least 10 hours of class on EM-385.  Some facilities require the OSHA 30 for all site personnel; others require it only for key safety supervisors.  All require the OSHA 10 as a minimum.  And all facilities require compliance with EM-385.  Familiarity with the critical differences is beneficial for all personnel and crucial for foremen and supervisors who will be enforcing your safety program. 

WHAT WILL YOU LEARN?

The focus of the course is two-fold.  The core is the OSHA 10-Hour Construction curriculum, including coverage of the topics listed above.  Differences between the EM-385 Manual and the OSHA Construction Safety Orders are discussed during each topic.  You will learn about the 10 specific areas listed in the MINIMUM BASIC OUTLINE FOR ACCIDENT PREVENTION PLANS provided in Appendix A of EM-385. These must be addressed in considerable detail.  The Activity Hazard Analysis requirements are also very demanding.  The AHAs become the foundation of a properly constructed APP.  Our workshop provides a framework for developing AHAs and using them to build the APP.   A copy of the latest edition of the EM-385-1-1 Manual is included in the course material. 

MORE ABOUT THE AHA

EM-385, 01.A.13: Contractor-Required AHA. “Before beginning each work activity involving a type of work presenting hazards not experienced in previous project operations or where a new work crew or subcontractor is to perform the work, the Contractor(s) performing that work activity shall prepare an AHA.”  The AHA must define the activities and identify the work sequences, specific hazards, site conditions, equipment, materials and control measures for each activity.  This is somewhat more involved than what many of you may be used to doing.  Remember that this will serve as the foundation of your APP, and without a strong foundation, developing an acceptable plan will be difficult.

TRAINING AND EM-385

EM-385 is much more specific regarding qualifications of trainers, content and frequency of training, and documentation of meetings.  Each AHA should be reviewed with everyone who is involved in or affected by the activity.  How often must you conduct training for the various categories of personnel?  What about initial training? EM-385 is more specific than either OSHA or Cal/OSHA on these issues.

INSPECTIONS

OSHA requires “frequent and regular” inspections.  EM-385 is more specific.  The competent person must be identified, and daily inspections are stipulated, plus your plan must include a timetable for corrective action, which must also be included in the inspection reports.

• EM 385 Training Flyer
• Registration Form