What is EM 385-1-1 & Why is it Important?

November 29, 2023

Construction employees are the most important asset in our industry. Ensuring the safety of those workers is of utmost importance.

The U.S. Army Corps of Engineers (USACE) has proudly authored and maintained the EM 385-1-1 (USACE Safety and Health Requirements Manual) for over 75 years. This manual applies to Headquarters U.S. Army Corps of Engineers (HQUSACE) elements, major subordinate commands, districts, centers, laboratories and field operating activities (FOA), as well as USACE contracts and those administered on behalf of USACE. Applicability extends to occupational exposure for missions under the command of the Chief of Engineers, whether accomplished by military, civilian or contractor personnel.

While EM 385-1-1 covers similar topics as the Occupational Safety and Health Administration (OSHA), EM 385-1-1 safety requirements are more stringent than OSHA standards in some areas. Additionally, the EM 385-1-1 course addresses topics not covered in OSHA training, including accident prevention plans, program management and job site inspections.

EM 385-1-1 places significant importance on employee and job site training as USACE believes these two elements are crucial in preventing injuries. EM 385-1-1 requires the prime contractor to submit an Accident Prevention Plan specific to each contract to maintain a safe work environment for every worker irrespective of the tasks they are responsible for. Besides initial safety indoctrination, the EM 385 also requires ongoing training throughout the project through weekly meetings with workers and monthly meetings with supervisors while onsite.

For the Department of Defense (DoD) and Federal projects, GBA Builders develops a site-specific Accident Prevention Plan (APP) to meet all requirements of the EM 385. All personnel who will be working on the jobsite are trained on the requirements of the EM 385, APP and any other applicable safety and health regulations. An initial job site inspection is conducted to identify any potential hazards and ensure compliance. Monitoring for hazards and compliance is continued throughout the duration of the project. Periodic safety meetings and toolbox talks are held to reinforce the importance of following safety and health procedures. GBA Builders documents all training, job site inspections, safety meetings and other activities related to the implementation of the EM 385 and the APP. The key to successful implementation of the EM 385 is ongoing monitoring, training and documentation to ensure compliance with the requirements of the manual and the APP.

USACE has spent significant time during the most recent Safety and Health Manual (EM 385-1-1) revision reviewing each provision of the manual and discussing the pros and cons of various provisions and suggested reform. USACE received and adjudicated over 5,000 comments, and more than 190 USACE personnel were involved in the rewrite.

The latest revision is more aligned with industry and OSHA, ANSI and NFPA standards, and is expected to be presented in a user-friendly, manageably sized, standardized format. USACE has defensible rational for all changes.

Major changes include:

Chapter 14 – Material Handling, Storage and Disposal and Chapter 17 – Conveyors were merged (to align with OSHA)
Rope Access became its own chapter (Chapter 20)
New chapter on Emergency Operations (Chapter 37)
New chapter on Uncrewed Aircraft Operations (Chapter 34)
Completely updated chapter on Confined Space (Chapter 30)
New chapter on Dive Operation – Scientific Diving (Chapter 28)
Chapter 15 – Electrical was revised to be in alignment with Army regulations (defining AHJ)
Updated Chapter 12 – Hazardous Isolation Procedure (HIP) (non-mandatory, but best practice)
Fall Protection
- No significant changes
- Updated requirements in accordance with OSHA
  - Working over water
  - Fixed ladder
- Load Handling Equipment
  - Operator Training (initial/refresher)
  - Variances included
- Separated Section 1 Program Management into two sections: Chapter 1 – Safety and Occupational Health (SOH for USACE Personnel and Chapter 2 – SOH Management for Contractors to provide clarity to both USACE personnel and contractors.
  - No appendix for Accident Prevention Plan (APP) – now included in Chapter 1
    - Improved APP checklist (form to be submitted as coversheet of APP) to simplify the process.
    - Identifies minimum plan requirements for site specific plans
  - Site Safety and Occupational Health (SSHO) Options updated/added (removed Designated Representative)
    - Level 1 – Full-time SSHO
    - Level 2 – Dual Duty SSHO
    - Level 3 – Qualified/Competent person with 10-hr OSHA (replaces the previously required Designated Representative)
    - Designation letter for all SSHOs

These safety requirements are followed [when/in what situation, etc.]

EM 385-1-1 is available for referral on iOS and Android platforms, especially in field environments where quick reference is often needed.

The revised EM 385-1-1 is expected to be published in the fourth quarter of 2023. You can access a draft version of the safety manual update now.

Erin Aldridge, PE, LEED AP

As Senior Project Manager for GBA Builders, Erin has a comprehensive, 16-year background in construction and project management, with a focus in the federal market. She possesses demonstrated capabilities in the areas of estimating, scheduling, budgeting, contract negotiations and quality control while ensuring compliance with company and regulatory requirements. Her understanding of federal regulations and requirements is critical to the work she performs for agencies such as VA, USACE, GSA, USDA, DoD, EPA and private clients.