Chapter 2 of the EM 385-1-1 manual, titled Safety and Occupational Health Program Management for Contractors, lays the foundational requirements for contractors undertaking work under a USACE contract, including those administered on behalf of USACE.
This chapter mandates the development, management, and implementation of a comprehensive Safety and Occupational Health (SOH) program by contractors, forming the bedrock for all subsequent safety stipulations within the manual. It outlines the necessary references, defines key terms relevant to contractor safety management, and specifies the required training and qualifications for personnel involved in the SOH program. The chapter delineates the roles and responsibilities of various contractor personnel, such as the Site Safety and Health Officer (SSHO), Competent Persons (CPs), Qualified Persons (QPs), and supervisors, in ensuring SOH program implementation and compliance.
Furthermore, it details the inspection requirements, including both external agency and contractor-led inspections, and sets forth the crucial requirements for Activity Hazard Analyses (AHAs) that must be prepared for all work activities. Minimum plan requirements, such as the Accident Prevention Plan (APP), are specified, along with general SOH requirements concerning medical and first aid, drug-free workplaces, SOH communications including safety bulletin boards, hazard reporting, and processes for requesting interpretations, variances, or waivers. Ultimately, Chapter 2 serves as the principal guide for contractors to establish and maintain an effective SOH program that aligns with USACE safety standards and relevant regulations.
Table of Contents
Summary and Key Takeaways by Section
Section 2-1
The first section of Chapter 2, 2-1. References, lists various external documents and regulations that contractors must adhere to when developing and implementing their SOH programs. These references include ANSI/ASSP standards concerning safety and health program requirements for multi-employer projects and criteria for accepted practices in safety, health, and environmental training. It also cites the Unified Facilities Guide Specification (UFGS) for Governmental Safety Requirements and relevant sections of the Code of Federal Regulations (CFR) pertaining to personnel records, recording and reporting occupational injuries and illnesses, general occupational safety and health standards, safety and health regulations for construction, notice of marine casualty and voyage records, accident prevention clauses in federal acquisition regulations, and notice of casualty regulations for pipeline safety. These references underscore the need for contractors to be aware of and comply with a wide array of national and industry-specific safety standards.
Section 2-2
Section 2-2. Definitions provides explanations for terms specifically used within Chapter 2 to ensure clarity and consistent understanding of the requirements. These definitions include “Competent Person (CP)” and “Qualified Person (QP)”, both of which refer to individuals with the necessary knowledge and experience to perform specific tasks or make judgments regarding safety.
Section 2-3
Section 2-3. Personnel Required Training/Qualification, mandates that all contractor employees receive safety and occupational health training as required by the manual, applicable federal, state, and local regulations prior to commencing work. It further specifies that supervisors must also receive the necessary SOH training relevant to their responsibilities. This section highlights the importance of ensuring that all personnel are adequately trained to recognise hazards and follow safe work practices.
Section 2-4
Section 2-4. Roles and Responsibilities clearly outlines the duties of various contractor personnel in relation to the SOH program. The Contractor’s Project Manager or equivalent is identified as ultimately responsible for the overall implementation and enforcement of the SOH program and ensuring compliance with all safety requirements. The Site Safety and Health Officer (SSHO) is tasked with developing, implementing, and managing the contractor’s SOH program at the project site, conducting inspections, developing AHAs, and ensuring all project personnel comply with safety requirements. Competent Persons (CPs) are responsible for developing AHAs, overseeing work activities as required by the manual, and taking corrective measures when unsafe conditions arise. Qualified Persons (QPs) provide guidance and perform work activities as required by the manual. Supervisors are ultimately responsible for SOH program implementation at their work sites and ensuring their employees comply with necessary safety requirements, including preventing work in unsafe conditions. Contractor Quality Control (QC) personnel are responsible for conducting daily SOH inspections and documenting their findings. This section emphasizes a hierarchical structure of safety responsibility within the contractor’s organisation.
Section 2-5
2-5. Inspection Requirements details the necessary safety inspections that must be conducted. It distinguishes between External Agency Inspections, such as those by OSHA, requiring immediate notification of the Contracting Officer (KO) or Contracting Officer’s Representative (COR) and the local SOHO, and providing them the opportunity to accompany the inspector. Contractors are also required to provide copies of any citations or reports and their corrective action responses to the KO/COR and local SOHO. The section also covers Contractor SOH Inspections, stipulating that the APP must provide for frequent safety inspections and audits by the QC and SSHO, with daily inspections of work sites, material, and equipment to ensure APP and manual compliance. These inspections must be documented in a written log, including identified hazards, corrective actions, responsibilities, and timelines. Follow-up inspections to ensure correction of deficiencies are also mandated.
Section 2-6
Section 2-6. Activity Hazard Analysis (AHA) Requirements lays out the crucial requirements for developing and implementing AHAs. AHAs must be prepared and documented for all field, laboratory, industrial, and maintenance activities before work begins, ensuring minimum safety requirements are addressed. The development of AHAs should draw 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 each employee documenting their review. Signed AHAs must be readily available onsite and accessible to all employees for a specified period. Minimum requirements for an AHA include identifying the activity, contractor information, project details, date, preparer, and acceptance authority. They must define job steps, list potential hazards for each step, detail required controls, assign a Risk Assessment Code (RAC) to each step and an overall RAC, and identify necessary equipment, training, and inspection requirements. Work requiring an AHA cannot begin until the AHA with the RAC has been reviewed and accepted by the proper authority, and contractors must submit accepted AHAs to the KO or COR for review and acceptance. The AHA must be updated as necessary to address changing conditions, operations, or personnel, with increases in the initial RAC requiring resubmission for acceptance prior to the start of work.
Section 2-7
2-7. Minimum Plan Requirements outlines the general requirements applicable to all plans mandated by the manual, with specific plan requirements detailed in paragraph 7 of each chapter. These General Plan Requirements include ensuring plans are site-specific, tailored to the project’s activities, hazards, and controls, and are reviewed and updated as conditions change. Plans must clearly define roles and responsibilities, include necessary permits, and be communicated effectively to all affected personnel. An Accident Prevention Plan (APP) is specifically required for each project, outlining the contractor’s overall approach to safety and health management. The APP must include elements such as a policy statement, project description, hazard identification and control methods, risk management procedures, emergency response procedures, accident reporting and investigation protocols, SOH training details, inspection requirements, a list of current AHAs, analysis of applicable site-specific plans, and occupational health information. An Emergency Plan must also be prepared in writing and reviewed with all affected employees, detailing evacuation procedures, emergency contacts, and reporting means.
Section 2-8
Section 2-8. General SOH Requirements covers a range of overarching safety and health obligations for contractors. This includes requirements for Medical and First Aid, mandating readily available first aid supplies and personnel trained in first aid. It also addresses Drug-Free Workplace policies, prohibiting the use or being under the influence of alcohol or drugs while on duty. SOH Communications require all safety information to be communicated in a language understood by employees, with interpreters and translators provided at sites with non-English speaking workers. The establishment of a SOH Bulletin Board within seven calendar days of commencing work is mandated, requiring the posting of emergency information, the APP location, OSHA Form 300A, the SOH deficiency tracking log location, safety posters, the OSHA safety and health poster, and hazardous material inventory details. A Deficiency Log and Hazard Tracking System must be established and maintained to monitor the status of SOH deficiencies, with monthly evaluations. Hazard Reporting procedures require employees to be informed of how to report hazards without fear of reprisal, and for reported hazards to be promptly investigated and corrected. The section also details the process for requesting Interpretations, Variances, and Waivers from manual requirements, requiring submission through the local USACE SOHO to HQUSACE, including justifications and proposed alternative protective measures.
Section 2-9 & 2-10
The final sections of Chapter 2, 2-9. Figures and Tables, and 2-10. Checklists and Forms, are referenced within the chapter but do not contain substantive requirements in themselves. They serve as supporting materials for implementing the requirements outlined in the preceding sections.
Chapter 2 Review
In conclusion, Chapter 2 of EM 385-1-1 mandates the development, management, and implementation of a comprehensive Safety and Occupational Health (SOH) program by contractors, forming the bedrock for all subsequent safety stipulations within the manual.
By adhering to the principles and requirements outlined in this chapter, USACE aims to create and maintain safe and healthy work environments for all personnel. Chapter 2 is covered in full in all EM385 training courses.