Chapter 1 of the EM 385-1-1 Engineers Manual is titled “Safety and Occupational Health Program Management for United States Army Corps of Engineers Personnel”.
This chapter establishes the fundamental requirements for the Safety and Occupational Health (SOH) program within the U.S. Army Corps of Engineers (USACE). This chapter’s primary objective is to provide overall programmatic guidance for the development, management, and implementation of a comprehensive SOH program across all USACE elements, including major subordinate commands, districts, centres, laboratories, and field operating activities. The requirements outlined in this chapter serve as the bedrock for the entire USACE SOH program and are intended to be applied and further elaborated upon in the subsequent chapters of the manual.
Table of Contents
Chapter Overview
Chapter 1 commences by highlighting a significant change: the elimination of the term Government Designated Authority (GDA) within the manual. The responsibilities previously associated with the GDA are now assigned to the USACE supervisor.
Summary and Key Takeaways by Section
Section 1-1
Section 1-1 provides a list of References that are integral to understanding and implementing the USACE SOH program. These references include:
- ANSI/ASSP A10.33 Safety and Health Program Requirements for Multi-Employer Projects.
- ANSI/ASSP Z490.1, Criteria for Accepted Practices in Safety, Health and Environmental Training.
- AR 40-5, Army Public Health Program.
- AR 385-10, The Army Safety and Occupational Health Program.
- DA Pam 385-10, Army Safety Program and Occupational Health Program Procedures.
- DA Pam 385-40, Army Mishap Investigations and Reporting.
- DoDI 6055.1, DoD Safety and Occupational Health Program.
- DoDI 6055.07, Mishap Notification, Investigation, Reporting, and Record Keeping.
- DoDI 6055.12, Hearing Conservation Program.
- Executive Order 12196, Occupational Safety and Health Programs for Federal Employees, February 26, 1980. These references provide external and internal regulations, standards, and guidelines that shape the USACE SOH program.
Section 1-2
Section 1-2 is dedicated to Definitions of key terms used throughout the manual. Understanding these definitions is crucial for the consistent interpretation and application of the SOH requirements. Some of the significant terms defined include:
- Accident: Defined as synonymous with mishap.
- Activity Hazard Analysis (AHA): A process for identifying hazards and implementing controls for specific work activities.
- Collateral Duty Safety Officer (CDSO): A designated USACE employee with SOH responsibilities as a minor duty (20% or less of their time).
- Competent Person (CP): An individual capable of identifying hazards and authorised to take corrective measures.
- Contractor: Any firm under agreement with the government for services or products.
- Employee: A government person engaged in work for USACE.
- Facility: A permanent or temporary location including buildings, structures, and other designated items.
- Hazard: Any actual or potential condition that can cause harm or loss.
- Imminent Danger: A condition that could reasonably be expected to cause death or serious harm immediately.
- Mishap: Synonymous with accident.
- Near Miss: A potentially serious event that did not result in injury or damage.
- Project Manager (PM): An individual assigned to achieve project objectives.
- Qualified Person (QP): An individual with specific knowledge, training, or credentials.
- Risk Assessment Code (RAC): A system for categorising the level of risk.
- Safety and Occupational Health (SOH): Encompasses the safety and health aspects of work.
Section 1-3
Section 1-3 introduces the USACE Safety and Occupational Health Management System (CE-SOHMS). It notes the transition to this performance-based safety management system. While this section in Chapter 1 is brief, it signifies a fundamental shift towards a more systematic and proactive approach to managing safety and occupational health within USACE.
Section 1-4
Section 1-4 meticulously outlines the Roles and Responsibilities of various individuals and organizational elements within the USACE SOH program. This section is critical for establishing accountability and ensuring that all aspects of the SOH program are effectively managed. Key roles and their responsibilities include:
- General Employees: All employees are accountable for SOH program implementation in their work areas. This includes complying with SOH requirements, using prescribed personal protective equipment (PPE), reporting hazards and near misses immediately, being involved in the development of Activity Hazard Analyses (AHAs), adhering to AHAs, and developing and maintaining a Personal Hazard Analysis (PHA). When on sites controlled by contractors, USACE employees must also comply with the contractor’s Accident Prevention Plan (APP).
- Collateral Duty Safety Officer (CDSO): CDSOs are responsible for overseeing and ensuring SOH program implementation at their assigned work sites. Their duties include ensuring hazards in AHAs are addressed, verifying employee knowledge of hazards and controls, providing safety feedback, seeking support from the Safety and Occupational Health Office (SOHO), prioritising safety duties, reporting safety matters to their supervisor, and coordinating with the local SOHO.
- Quality Assurance Representative (QAR): QARs are responsible for ensuring contract work is performed according to the contract and this manual, which includes conducting daily SOH inspections and documenting their findings.
- Supervisors: Supervisors hold the ultimate responsibility for SOH program implementation at their work sites. Their extensive responsibilities include ensuring safe working conditions, designating CDSOs, verifying site-specific SOH plans, removing employees from unsafe situations, conducting regular safety meetings (at least monthly for all employees), reporting all accidents and near misses, immediately notifying the SOHO of regulatory inspections, enforcing drug-free workplace requirements, ensuring completion of required SOH training, ensuring emergency preparedness training, implementing the AHA process, ensuring employee medical qualifications, ensuring visitor safety, implementing the PHA process, and assisting with the implementation of CE-SOHMS.
- Competent Person (CP): CPs are responsible for developing AHAs and overseeing work activities, with the authority to take prompt corrective measures to eliminate hazards.
- Qualified Person (QP): QPs are responsible for developing AHAs and providing guidance and performing work activities as required by the manual.
- Command: Each USACE Command is responsible for establishing and maintaining a SOH program that complies with the manual and relevant regulations, and for implementing CE-SOHMS.
- Project Manager (PM)/Program Manager (PgM): PMs/PgMs are responsible for ensuring SOH integration into all aspects of work planning. This includes developing site-specific SOH Plans, coordinating high-hazard projects with the SOHO, collaborating on safety goals, ensuring SOH coordination between design and construction phases, communicating identified hazards, using the current UFGS 01 35 26 in contracts, coordinating contract SOH requirements with the SOHO, including FAR Clause 52.236-13 in relevant contracts, and not including unapproved local SOH requirements in contracts.
- Contracting Officer (KO): The KO is responsible for reviewing SOH documents for contractual compliance, ensuring site-specific documents are reviewed and accepted, notifying the SOHO of regulatory visits, reporting accidents, and having the authority to stop unsafe work in imminent danger situations.
- Safety and Occupational Health Office (SOHO): The SOHO holds the ultimate responsibility for SOH program management, communication, and implementation within their area of responsibility. Their duties include providing technical input on SOH requirements, identifying training needs, assisting with SOH Plans and AHAs, assisting PMs with contract safety requirements, providing guidance to CDSOs, ensuring accident investigation and reporting, ensuring supervisor competency in SOH document review, ensuring a full-time SOH Professional is onsite for high-risk activities, performing annual workplace inspections, managing OSHA inspections and notifications, ensuring accurate accident data entry, and approving local Standard Operating Procedures (SOPs).
Section 1-5
Section 1-5 specifies Inspection Requirements to ensure ongoing compliance with SOH standards. Different types of inspections are outlined:
- External Agency Inspections: Requires immediate notification of the local SOHO and providing them the opportunity to accompany the inspector, as well as providing copies of any citations or reports.
- Quality Assurance Representative (QAR) Inspections: Mandates daily SOH inspections of work sites, materials, and equipment by QAR personnel, with documentation in daily logs.
- USACE Annual Workplace Inspections: Requires all USACE workplaces to be inspected at least annually according to Standard Army Safety and Occupational Health Inspection procedures (DA Pam 385-10), with identified violations documented.
- CDSO Inspections: Requires CDSOs to conduct and document daily SOH inspections of work sites, materials, and equipment.
- Supervisor Inspections: Recommends that supervisors conduct and document frequent (minimum monthly) SOH inspections.
Section 1-6
Section 1-6 details the Activity Hazard Analysis (AHA) Requirements, emphasizing the critical role of risk management in ensuring work is performed safely. Key aspects of AHA requirements include:
- Risk management is defined as a business process involving hazard identification, risk assessment, and the development of controls.
- AHAs must be prepared and documented for all field, laboratory, industrial, and maintenance activities before work begins.
- AHAs must be developed by Competent Persons (CPs) or Qualified Persons (QPs), drawing upon the expertise of employees, supervisors, and SOH personnel.
- AHAs must be provided to and reviewed by all involved employees prior to starting the task, with documented acknowledgement of review.
- Activities requiring an AHA must not begin until the AHA with the identified Risk Assessment Code (RAC) has been reviewed, accepted, and signed by the proper approval authority. Each USACE Command must establish a process for risk acceptance.
- Minimum AHA requirements include the activity name and location, date, preparer and acceptance authority details, detailed job steps, identification of potential hazards for each step, required control measures, assignment of a RAC for each step and an overall RAC, identification of necessary equipment and training, and risk acceptance information.
- The AHA must be updated as necessary to reflect changing site conditions, operations, or personnel.
Section 1-7
Section 1-7 outlines Minimum Plan Requirements for various safety-related aspects. These plans include:
- Site-Specific Safety & Occupational Health (SOH) Plan: Required for USACE activities beyond routine office or administrative duties. This plan must be developed, signed, implemented, and updated (at least annually) by the supervisor and must include elements such as a signature sheet, project information, SOH commitment and policy, a statement regarding the presence of a CDSO, accident reporting and investigation procedures, SOH training details, a list of required inspections, a list of current AHAs, analysis of applicable site-specific plans, and the most recent Industrial Hygienist (IH) report.
- Emergency Plan: Required to ensure employee safety in case of emergencies such as fire or severe weather. The plan must be in writing, reviewed with all affected employees, and tested for effectiveness. It must include evacuation procedures, critical plant operations, employee accountability, rescue and medical duties, means of reporting emergencies, and points of contact.
Personal Hazard Analysis (PHA): Required for all USACE employees upon initial assignment and reviewed annually. The PHA identifies potential hazards associated with an employee’s job duties, required controls, training needs, medical surveillance requirements, and required PPE. Both the employee and supervisor must review and sign the PHA.
Section 1-8
Section 1-8 covers General Program Requirements that apply broadly to the USACE SOH program. These include:
- Accident Investigation and Reporting: Mandates the reporting of all accidents and near misses using ENG Form 3394 and their investigation according to ER and EP 385-1-99.
- Safety Bulletins: Requires the issuance of safety bulletins to disseminate information on identified hazards, unsafe trends, and lessons learned.
- Safety and Occupational Health (SOH) Bulletin Board: Requires the establishment and maintenance of a SOH bulletin board (or an approved alternative) at all work sites to display critical safety information, including emergency contacts, the location of the site-specific SOH plan, OSHA Form 300A, the location of the SOH deficiency tracking log, SOH promotional posters, the OSHA Safety and Health Poster, and hazardous material information.
- Deficiency Log and Hazard Tracking System: Requires each USACE project, facility, and field office to establish and maintain a current SOH deficiency tracking system to monitor the status of identified hazards and deficiencies.
- Safety Meetings: Mandates regular safety meetings (at least monthly for supervisors and weekly for workers) to review safety performance, plan for new activities, discuss AHAs, establish safe work procedures, and provide relevant SOH training.
- Requests for Information: Outlines the formal process for requesting clarification on requirements within the manual, requiring submission through the local USACE SOHO and the HQUSACE-SO SharePoint.
- Requests for Interpretation, Variances, and Waivers: Specifies that interpretations, variances, and waivers to the manual’s provisions require approval from the Chief of Safety and Occupational Health, HQUSACE. Requests must be submitted through the local SOHO via the HQUSACE-SO SharePoint, with justification and documentation, including a hazard analysis demonstrating equal or greater protection for variances and waivers.
- The chapter also includes definitions for Risk Assessment Code (RAC), Risk Management, and Risk Matrix.
- Finally, it emphasizes the responsibility of supervisors to ensure the safety of visitors on USACE sites.
Chapter 1 Review
In conclusion, Chapter 1 of EM 385-1-1 lays the essential groundwork for the USACE Safety and Occupational Health program. It clearly defines the objectives, establishes lines of responsibility, mandates critical safety processes such as hazard analysis and inspections, and sets forth the minimum requirements for essential safety plans.
By adhering to the principles and requirements outlined in this foundational chapter, USACE aims to create and maintain safe and healthy work environments for all its personnel. Chapter 1 is covered in full in all EM385 certification courses.
