This article provides a summary of the different roles covered by the EM 385 standard, along with examples and the required training for each role.
It is important for anyone working, or considering bidding on, Department of Defense (DoD) or other military construction projects to understand the mandated training covered in the EM 385-1-1 Engineers Manual.
Table of Contents
Roles Covered by EM 385-1-1
Contractor’s Project Manager or equivalent
This individual has ultimate responsibility for the overall implementation and enforcement of the Contractor’s Safety and Occupational Health (SOH) program and ensuring compliance with all safety requirements.
Example:
The senior manager overseeing a construction project undertaken by a contracting company.
Qualifications & Experience Required:
NA.
Specific EM385 Training Required:
EM385-1-1 40 Hour Training.
Site Safety and Health Officer (SSHO)
The SSHO is tasked with developing, implementing, and managing the contractor’s SOH program at the project site, conducting inspections, developing Activity Hazard Analyses (AHAs), and ensuring all project personnel comply with safety requirements. There are different levels of SSHOs (Level 1, Level 2, Level 3, and Alternate SSHO) with varying experience and responsibility levels.
Example:
The dedicated safety officer present on a USACE construction site managed by a contractor.
Qualifications & Experience Required:
Level 1 & 2 SSHO: Must receive OSHA 30-hour construction safety training (web-based if permitted by OSHA). Equivalent SOH training covering the subjects may be accepted by the KO in coordination with the local SOHO. Must maintain competency by taking 24 hours of documented formal classroom or online SOH-related training within the past five years and every three-year period thereafter.
Level 3 SSHO: Must be a designated Qualified Person (QP) or Competent Person (CP) with experience enabling identification of hazards and implementation of controls for the work being performed.
Level 2 SSHOs must have at least three years of cumulative safety experience within the last 10 years, managing or implementing a SOH program on similar projects (two years if they have a safety-related degree or nationally accredited SOH certification requiring a minimum of two years of experience).
Level 1 SSHOs must have at least five years of cumulative safety experience within the last ten years, managing or implementing a SOH program on similar projects (three years if they have a safety-related degree or nationally accredited SOH certification requiring a minimum of three years of experience).
Specific EM385 Training Required:
Intermediate-level EM 385 24 Hour training is required for contractors and employees who must comply with EM 385-1-1 training requirements for military or government contract work.
Competent Person (CP)
A CP is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorisation to take prompt corrective measures to eliminate them. They are responsible for developing AHAs and overseeing work activities as required.
Example:
A person with specific training and experience in excavation safety who can identify trenching hazards.
Qualifications & Experience Required:
All contractor employees must receive safety and occupational health training as required by the manual, applicable federal, state, and local regulations prior to commencing work. Trainers must have subject matter expertise and experience delivering training according to ANSI Z490.1. The specific training for a CP will depend on the hazards they are competent to identify and control, as mandated by the relevant sections of EM 385-1-1 and other regulations.
Specific EM385 Training Required:
EM385-1-1 24 Hour Training. This must include or be supplemented by USACE 24-Hour Fall Protection Competent Person Training, which must include eight hours of in-person training undertaken via a face-to-face training or on the job-site
Qualified Person (QP)
A QP possesses a recognised degree, certificate, or professional standing, or extensive knowledge, training, and experience, demonstrating the ability to solve or resolve problems relating to the subject matter, the work, or the project. They provide guidance and perform work activities as required.
Example:
A registered professional engineer (RPE) designing a temporary shoring system for an excavation.
Qualifications & Experience Required:
Similar to CPs, all contractor employees must receive safety and occupational health training as required. QPs will have specific qualifications related to their area of expertise, demonstrating their competence.
Specific EM385 Training Required:
EM385-1-1 40 Hour Training.
Supervisors
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.
Example:
A foreman overseeing a crew of steel erectors.
Qualifications & Experience Required:
Supervisors must receive the necessary SOH training relevant to their responsibilities. This includes ensuring they are adequately trained to recognise hazards and follow safe work practices.
Specific EM385 Training Required:
EM385-1-1 40 Hour Training.
Contractor Quality Control (QC) personnel
QC personnel are responsible for conducting daily SOH inspections and documenting their findings.
Example:
A quality control inspector on a construction site who includes safety checks in their daily inspections.
Qualifications & Experience Required:
All contractor employees must receive safety and occupational health training as required. Specific training on inspection procedures and reporting may also be required.
Specific EM385 Training Required:
EM385-1-1 16 Hour Training
Contractor Corporate Safety Official
This official is responsible for the company’s overall SOH Program and designates all contractor SSHOs.
Example:
The head of the safety department at the contracting company’s corporate office.
Qualifications & Experience Required:
It is expected they possess a high level of knowledge and experience in safety and health management.
Specific EM385 Training Required:
EM385-1-1 40 Hour Training.
General Employees
All employees are responsible for SOH program implementation in the workplace, complying with requirements, wearing PPE, and reporting hazards.
Example:
Any worker on a USACE project site, such as a carpenter, electrician, or equipment operator.
Qualifications & Experience Required:
All employees must receive SOH indoctrination training prior to the start of work, covering topics such as accident prevention responsibilities, SOH policies, hazard reporting, and job-specific hazards and controls. They must also receive safety and occupational health training as required by the manual, applicable regulations, and paragraph 3 of each chapter.
Specific EM385 Training Required:
EM385-1-1 16 Hour Training.
Contracting Officer (KO)/Contracting Officer Representative (COR)
While government personnel, the KO/COR has responsibilities related to contractor safety, including reviewing and accepting contractor SOH documents like APPs and AHAs.
Example:
A USACE project manager or contracting officer overseeing a contractor’s work.
Qualifications & Experience Required:
While not contractor personnel, Chapter 2 of EM 385-1-1 is written with their oversight in mind. Chapter 1, which covers USACE personnel, specifies SOH training for roles like Project Manager and KO/COR.
Specific EM385 Training Required:
EM385-1-1 40 Hour Training.
Summary
Remember, that EM385 training is an annual requirement, so ALL roles that initially trained on the 40 hour, or 16 hour courses will need to do EM385 refresher training once per year.
