Taking EM 385-1-1 training is of paramount importance for any contractor undertaking work under a USACE contract. The EM 385-1-1 manual serves as the definitive guide for safety and occupational health requirements on these projects, and a thorough understanding of its contents is not merely advisable but essential for successful and compliant project execution.
A comprehensive grasp of the EM 385-1-1 manual, facilitated by dedicated training, extends far beyond the need for basic compliance. It delves into the practical aspects of establishing and maintaining a robust SOH program, including the critical Activity Hazard Analysis (AHA) process, the clear definition and understanding of roles and responsibilities for key safety personnel, and the proper implementation of inspection and hazard reporting procedures. This knowledge enables contractors to move beyond a superficial understanding of safety protocols and to embed safety considerations into every stage of their work.
Here are five reasons why taking EM 385-1-1 training is important, drawing on the provided sources:
1. Ensuring Compliance with Mandatory USACE Safety and Health Requirements
The EM 385-1-1 manual lays down the foundational requirements for contractors undertaking work under a USACE contract, including those administered on behalf of USACE. Chapter 2 of this manual, titled “Safety and Occupational Health Program Management for Contractors“, serves as the principal guide for contractors to establish and maintain an effective Safety and Occupational Health (SOH) program that aligns with USACE safety standards and relevant regulations. Taking EM 385-1-1 training ensures that contractors are fully aware of these mandatory requirements.
The manual specifies the development, management, and implementation of a comprehensive SOH program, forming the bedrock for all subsequent safety stipulations within the document. This includes adherence to a wide array of national and industry-specific safety standards referenced in Section 2-1, such as ANSI/ASSP standards and relevant sections of the Code of Federal Regulations (CFR). Non-compliance with these requirements can lead to contractual issues, project delays, and potential legal ramifications. Understanding the EM 385-1-1 through dedicated training is therefore crucial for contractors to operate within the bounds of USACE regulations and maintain a compliant and safe work environment. Furthermore, the manual outlines the process for requesting interpretations, variances, or waivers from manual requirements, highlighting the importance of understanding the standard before seeking deviations.
2. Establishing and Managing a Comprehensive Safety and Occupational Health Program
EM 385-1-1 training is essential for contractors to understand the intricacies of developing, managing, and implementing a comprehensive SOH program, as mandated by Chapter 2. The manual specifies the necessary references, defines key terms relevant to contractor safety management in Section 2-2, and outlines the required training and qualifications for personnel involved in the SOH program in Section 2-3. Training on EM 385-1-1 will clarify 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.
This comprehensive understanding extends to inspection requirements, including both external agency and contractor-led inspections, as detailed in Section 2-5. Moreover, the manual sets forth crucial requirements for Activity Hazard Analyses (AHAs) that must be prepared for all work activities, as explained in Section 2-6 and paragraphs 1-6 and 2-6. Training on EM 385-1-1 equips contractors with the knowledge to establish minimum plan requirements, such as the Accident Prevention Plan (APP) and Emergency Plan, as specified in Section 2-7. Finally, the training covers 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, as detailed in Section 2-8.
3. Understanding and Implementing the Critical Activity Hazard Analysis (AHA) Process
Taking EM 385-1-1 training provides a thorough understanding of the crucial Activity Hazard Analysis (AHA) process, which is a cornerstone of USACE safety requirements. Section 2-6 and paragraphs 1-6 and 2-6 explicitly lay out the requirements for developing and implementing AHAs for all field, laboratory, industrial, and maintenance activities before work begins. Training on this manual will clarify the minimum requirements for an AHA, including identifying the activity, contractor information, project details, date, preparer, and acceptance authority. It also details the need to 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.
EM 385-1-1 training emphasises that work requiring an AHA cannot begin until the AHA with the RAC has been reviewed and accepted by the proper authority, and that contractors must submit accepted AHAs to the KO or COR for review and acceptance. Furthermore, the training covers the vital aspect of updating the AHA 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. Understanding the risk assessment process, including the hierarchy of controls, is integral to developing effective AHAs, and this is thoroughly covered in the EM 385-1-1 training.
4. Defining and Understanding the Roles and Responsibilities of Key Safety Personnel
EM 385-1-1 training clearly outlines the roles and responsibilities of various contractor personnel in relation to the SOH program, as detailed in Section 2-4. Understanding these defined duties is paramount for effective safety management on USACE projects. The training clarifies the ultimate responsibility of the Contractor’s Project Manager or equivalent for the overall implementation and enforcement of the SOH program.
It also defines the tasks of the Site Safety and Health Officer (SSHO) in developing, implementing, and managing the SOH program at the project site. The training elaborates on the responsibilities of Competent Persons (CPs) in developing AHAs, overseeing work activities, and taking corrective measures, as well as the role of Qualified Persons (QPs) in providing guidance and performing work activities. Furthermore, the training underscores the responsibility of Supervisors for SOH program implementation at their work sites and the duties of Contractor Quality Control (QC) personnel in conducting daily SOH inspections. For the prime contractor, the role of the Corporate Safety Official in designating SSHOs and approving the APP is also covered, as is the overall responsibility of the Prime Contractor for SOH program management. This comprehensive understanding of roles and responsibilities fostered by EM 385-1-1 training ensures a structured and accountable approach to safety on USACE projects.
5. Ensuring Proper Implementation of Inspection and Hazard Reporting Procedures
Taking EM 385-1-1 training is crucial for understanding and properly implementing the necessary inspection and hazard reporting procedures mandated by the manual. Section 2-5 details the necessary safety inspections that must be conducted, distinguishing between External Agency Inspections, such as those by OSHA, requiring immediate notification of USACE, and Contractor SOH Inspections, stipulating frequent inspections and audits by the QC and SSHO with documented logs and follow-up actions. EM 385-1-1 training ensures that contractors understand the notification processes for external inspections and the documentation requirements for their own inspections.
Furthermore, Section 2-8 covers Hazard Reporting procedures, requiring employees to be informed of how to report hazards without fear of reprisal, and for reported hazards to be promptly investigated and corrected. The training also addresses the establishment and maintenance of a Deficiency Log and Hazard Tracking System and the importance of SOH Communications, including the establishment of a safety bulletin board and the conducting of safety meetings. By providing a thorough understanding of these procedures, EM 385-1-1 training ensures that contractors can proactively identify and address safety hazards, maintain a safe work environment, and comply with USACE requirements for inspection and reporting.
Summary
Ultimately, EM 385-1-1 training provides the necessary foundation for contractors to not only meet the mandatory requirements of USACE contracts but also to foster a proactive and effective approach to safety and occupational health management, leading to enhanced project outcomes and the well-being of their workforce.
