Construction RISK, PRE-TASK PLANS, ACCIDENT PREVENTION AHA

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 GUIDE FOR THE ACTIVITY HAZARD ANALYSIS (AHA), EM 385, USACE

This page is an overview of the US Army Corp of Engineers, Activity Hazard Analysis (AHA) along with information on the USACE safety process.  

There are online versions of the EM 385  1-1, USACE, 40 Hour, 24 hour, 16 hour, or 8 hour courses that may be a good option as part of your training program. 

Disclaimer: This page is for educational purposes only. Opinions or points of view expressed on this page do not necessarily represent the official position or policies of the USACE and it is not to be considered legal advice.   The information contained in the video and written content posted represents the views and opinions of the original creators of the video and written content is not legal or business advice and does not necessarily represent the views or opinions of Safety Kaizen, LLC.  

Thank you for visiting!

• That safety training was long and the wrong message! -  They don't need to listen to two hours about OSHA Laws, they need to know what they should do so they don't get hurt on the job today!
• Yes, just one of many lessons I have learned, in my safety career.  (At least it was not last week.) 

• When I think about what makes a 'competent person' skills, knowledge, and experience, I think of all the good and not so great experiences that we have along the way.
• Sharing that experience with others in a way that they are engaged in the conversation can be a challenge in the field.
• The Activity Hazard Analysis (AHA) is like your script for the day.
• You can use the AHA tool to share your experience for the day's work for all field operations, and for some other operations 
• How are you going to share your story about hazards for the day, and not have the day end in an injury or a scene from Fast & Furious.

•  You may be familiar with a Job Hazard Analysis (JHA), Job Safety Analysis (JSA), or Pre-Task Plan (PTP) at your company or where you have worked.  
• I view the Activity Hazard Analysis (AHA) as a Fortified JHA or PTP.
• If you have been asked to fill out AHAs, or you just want to learn more about the process, I have put together below what I hope will be of interest to you.
• I included some related topic videos on YouTube that I like, and hopefully help you, or your team members.

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• The Activity Hazard Analysis (AHA) could be used when you are planning work as a civilian contractor, government employee, or military personnel.  You need  to either already have your EM 385-1-1 manual training or you could consider taking the online version of the training you need, such as the 40-Hour EM 385-1-1 Training through an online training provider. ‡
• You could be a Site Safety Health Officer (SSHO) on military projects of contract, where you need to maintain EM 385-1-1 compliance. 
• A good Activity Hazard Analysis is part of the safety system that helps to prevent potential injuries, accidents, deaths or a shutdown of your work on the USACE construction site.  

• Each day is different and some can be very dynamic.
• For your team competing work for you activities for the day, you all have your strengths and weaknesses.
• If you are the team leader, you want to make sure that you get everybody through the activities of the day safety.
• That can be quite an adventure, depending on your team members and what you have to get done.
• Linked below is a 3 minute clip from Jumanji.  I thought it was a fun movie.
• You can watch the clip if you have not seen the movie.  
• Think of yourself as the Adventure Guide....

• I also have cake (and ice cream), speed, and strength as my weaknesses.
• It  helps to have a map, or a plan, and someone that can read the map - which is why the AHA has a lot of value.

• We can all learn lessons from each other, and this is why the AHA is most valuable when completed as a team.
• That way everyone knows the plan and is engaged in the interactive process.
• You may be wishing your team had the chemistry of Dwayne Johnson and Kevin Hart, but everyone can contribute something.
• It may not be as fun as the movie, but the AHA process is important because some folks just nod their head and think about something else if they don't have to engage in the conversation about the days plan.
•  The hazards, who does what, what could go wrong, and when to stop if something significant changes - before it goes really bad.  

• For each person working on the USACE site, there is a minimum level of training that is expected.   
• Here is a basic overview of the content you may find online EM 385 1-1 training was designed for employees and contractors, such as managers, supervisors and team leads, who are working on military projects and need to comply with EM 385-1-1 regulations.   

             40-Hour EM 385-1-1 Training

• Site Safety Health Officers (SSHO) are required to complete the initial 40 Hour Course and then the 8 Hour Refresher Course each following year.
• The SSHO uses their training, along with their skills, knowledge, and experience to prevent potential injuries, accidents.  In some situations, they may need to completely shutdown the construction site. 
• The online course reviews the EM 385 manual—(2014 revision)—to ensure you understand the U.S. Army Corps of Engineers Contractor (USACE) Safety and Health requirements. There are safety tips that will help you recognize and respond to construction-site hazards. 
• The course provides an in-depth exploration of several topics, including: 
• How to select and use the appropriate Personal Protective Equipment (PPE)
• The proper protection to use during excavation and trenching   
• Methods for using ladders and hand tools safely
• If you are a civilian contractor, military personnel, or government employee, you will need to complete EM 385-1-1 manual training.

              24-Hour EM 385-1-1 Training 

• Managers and supervisors, who lead teams, should take the 24 Hour Training  Course. 
• Aware of unsafe worksite conditions 
• Prepare site-specific Accident Prevention Plans (APP) 
• Prepare Activity Hazard Analysis (AHA) forms.  
• You will also understand how to conduct site personnel training, create incident response reports, perform jobsite auditing, and initiate hazard communication.     
• This training was designed for employees and contractors, such as managers, supervisors and team leads, who are working on military projects and need to comply with EM 385-1-1 regulations.   

              16-Hour EM 385-1-1 Training

• Workers and contractors must complete an introductory 16 Hour Training Course.
• This training course provides you with an orientation to the safety standards you need to follow from the EM 385 manual.
• THe course is designed for employees and contractors working on military projects.   . 
• You’ll learn:     
• How to identify the Site Health and Safety Officers (SSHOs)  
• How to choose the right equipment to keep yourself safe from falls  
• The proper ways to handle, store, and dispose of potentially hazardous materials 
• Best practices for working safely in confined spaces   
• You will also understand what to do to stay safe during excavations and trenching.   

• I have included what I think are two of the best videos available from OSHA.  You could refer to these trenching videos later, when that exposure comes up on a site and you need to prepare for that activity.   Onn focuses on trenching hazards and the other is on soil classification.

• As part of the USACE Risk Management Processes, the detailed project-specific hazards and controls are provided by the Activity Hazard Analysis for each activity  (Definable Features of Work DFOW).   
• The USACE describes a DFOW as a task that is separate and distinct from other tasks and has control requirements and work crews unique to that task.
• Work can only begin on a site after an initial AHA has been accepted by the Government Designated Authority (GDA) addressing the project-specific hazards. (01.A.14 & 01.A.15) 
• Although USACE uses the AHA, Contractors and other individual employer’s typically may use the their own versions of the AHAs, like a Job Safety Analyses (JSAs) or Job Hazard Analyses (JHAs) as they are often referred to by Contractors.  These documents are typically considered equivalent to, and acceptable substitutes for, the USACE’s AHA.  (Provided that the data collected is the same as that required by the AHA.)
• A site will likely have a minimum expectation for PPE for anyone on the site, and the AHA would also define the additional PPE for the task.
• Such as:  PPE for all activities on site shall include at a minimum: ANSI Z89.1 Hardhat, ( Type 2 hard hats based on ANSI and CSA standards are designed to reduce force as a result of an impact to the front, back, sides, AND top of the head. A Type 2 Hardhat is becoming a more popular requirement, which is great), ANSI Z87.1 safety glasses, leather work shoes or boots, short sleeve (min 4” sleeve) shirt, and long pants.

             Here is the Definition of Activity Hazard Analysis (AHA) from the EM 385 1-1 Manual:

• Activity Hazard Analysis (AHA): a documented risk management process by which the steps (procedures) required to accomplish a work activity/task are outlined and the actual/potential hazards of each step are identified. 
• This is identification of “inherent risk”.
• Safety measures, precautions and controls are then identified and put into place to reduce the level of hazard for each step. 
• The risk level then identified, is called the residual risk for that step/activity. A risk acceptance code (RAC) is then assigned to the entire activity. 
• The AHA is an analysis tool that the USACE uses, however, other similar analysis tools are acceptable (e.g., Job Hazard Analysis, JHAs; Job Safety Analysis, JSA;, etc) provided the information required on the AHA is included, steps are identified, hazards associated with each step are listed. > See also “Inherent Risk”, “Risk Assessment Code” and “Residual Risk”.

• In my experience with JHA and JSA, I think it would be challenging to meet the AHA Risk Assessment requirement, because the JHA and JSA may not have the level of Risk Assessment Coding that the AHA does.  
• Here is a hyperlink for the OSHA Job Hazard Analysis (JHA) publication, that explains the JHA process and shows a JHA form.
• That is why I think of the AHA as a 'Fortified' JHA or JSA.
• If I were going to work on a USACE site, I would use the AHA form.  I have a link to a blank pdf version and the version with the color in the Risk Assessment Code section as a pdf at the bottom of the page for you.

             CONSTRUCTION SITE HAZARDS

•  Subcontractors could include Carpenters, Concrete, Drywall,  Electrical subs, Glass/ windows, HVAC, Framing, Masonry, Painting, Plumbing, Roofing, Site Preparation, Sheet Metal, Specialty Trade, Traffic Control, Structural, Underground, or a specialty trade. There is a box on the AHA to identify the 'Specific Anticipated Hazards'.  Here are some examples of Hazards that could be encountered by a worker on a construction site:

• Caught Between 
• Caught By 
• Caught On 
•  Cave-In 
• Chemical Exposure
• Cold Exposure
• Collapsing By Oxygen Deficient Atmosphere 
• Contact By 
• Electric Shock 
• Equipment Failure 
• Equipment Rollover 
• Exposed To 
• Fall on Different Level
• Fall on Same Level
• Fire
• Heat Exposure
• Impaled By Object
• Lifted, Strained by
• Punctured By Laceration
• Slipped Same Level/ Tripped 
• Struck By
• Struck by Falling Object 
• Struck Against
• Stung By 

• Here are construction hazards from the OSHA Etool for Construction, which can provide more knowledge on some of the hazards listed above hazards to assess activities on the AHA:

             Electrical Hazards: 

• Many workers are unaware of the potential electrical hazards present in their work environment, which makes them more vulnerable to the danger of electrocution.  The most frequent causes of electrical injuries:
• Contact with power lines, Lack of ground-fault protection, 
• Path to ground missing or discontinuous, 
• Equipment not used in manner prescribed, and 
• Improper use of extension and flexible cords. [29 CFR 1926.416(a)(1)] 

             Falls:   Falls are the leading cause of fatalities in the construction industry.   Here are the cause the most fall-related injuries:

• Unprotected sides, wall openings, and floor holes
• Improper scaffold construction
• Unguarded protruding steel rebars
• Misuse of portable ladders

             Trenching and Excavation:    

• Employers should also consider potential struck-by hazards associated with heavy equipment, falling loads, and public vehicular traffic in close proximity to the excavation operations. Also consider potential hazards from undermining sidewalks and buildings. Other unsafe conditions that may be encountered include hazardous atmospheres and electrical hazards from overhead and underground power lines.  These five key trench safety tips will help keep workers safe:
• Ensure that there's a safe way to enter and exit
• Ensure trenches have cave-in protection
• Look for standing water and test if atmospheric hazards are or may be present
• Keep materials away from the edge of the trench
• Never enter a trench unless it has been properly inspected by a competent person

             Struck-by:  

• Struck-by objects is another leading cause of construction-related deaths.  One in four "struck by vehicle" deaths involve construction workers Approximately 75% of struck-by fatalities involve heavy equipment such as trucks or cranes.  Here are the most common struck-by injuries:
• Vehicles
• Falling/flying objects
• Constructing masonry walls

             Material Handling/ Heavy Lifting:  

• When employees use smart lifting practices and work in their "power zone," they are less likely to suffer from back sprains, muscle pulls, wrist injuries, elbow injuries, spinal injuries, and other injuries caused by lifting heavy objects.
• Weight of objects
• Awkward postures
• High frequency and long-duration lifting
• Inadequate handholds
• Environmental factors

             SEVERITY AND PROBABILITY

             SEVERITY🩹- How bad could it be?  (Consequence)

•  The AHA form identifies the categories of severity as Catastrophic, Critical, Marginal, or Negligible.
• We have all likely assessed risk for an injury we had, a family member, or coworker.  Take a few Advil, First Aid Bandage, Medical Clinic, or Emergency.  
•  Work injuries could resulted death, permanent impairment, or temporary disability, medical treatment (beyond first aid) or restricted work duties but did not result in days.
•  BLS.gov summarizes information on nonfatal injuries for severity information for falls, slips, and trips accounting for 35.3 percent of the workplace deaths within construction and extraction occupations in 2020.   
• Of the 345 construction occupation deaths from falls, 96 occurred among construction laborers which would could contribute to your severity rating analysis.  
• Although falls are the leading cause of death for construction laborers, workers in this occupation encounter other exposures that result in injuries and deaths that should be considered for your severity rating.  
•  In 2020, construction laborers experienced 8.9 percent of all workplace deaths due to exposure to harmful substances or environments, so that severity should be taken into account when assessing activity exposures and controls.
• High-risk construction activities that could be above Negligible and maybe up to Catastrophic might include crane operations, hoisting, setting scaffolding, concrete work/ tilt ups, confined space work, live electrical exposure, fall exposure, and excavation operations just to name some of them.

             PROBABILITY 🎲🎲  - What are the chances?

• The chances you are a coffee drinker is high.  About 3 of 4 (75%) Americans drinks coffee every day.
• The odds you are left handed are lower, at about 10 - 15%.
• Your odds for getting drawn for a Big Game Hunting Tag tags for deer, bear, or elk, could be less predictable, unless you know the number of applicants.
•  Those odds are so much better then odds of winning a Mega Millions jackpot, which is about 1 in 302 million. 

• The AHA form identified Probability as the likelihood the activity will cause a Mishap (Near Miss, Incident, or Accident). 
• When assessing what you think what might happen, you may consider also consider the probability of injury or loss.  
• The site conditions are important because there need to be enough layers of controls to prevent an event, a roll of the dice odds would be far from enough where having enough real controls in place closer to winning the Mega Millions could seem like a better approach.
•  If the team and the supervisor have worked under similar conditions without an incident or near miss - you may see the probability as unlikely or seldom.
•  You will select one on the  AHA probability ratings of either Frequent, Likely, Occasional, Seldom, or Unlikely - for each activity.

• Casinos are excellent at understanding and applying odds and probability.
• The more experience that we have about construction activities and  learning about events and injuries that have happened in the past, we should be able to use that knowledge to assess probability.
• There is a banner link down the page where you can read over 30 Lessons Learned, that is just one way of increasing experience and knowledge.

• To bet on a dice game, like Craps, you roll two die, with six spots on each die.
• You may win if you get a 7 or 11. (A 'six ace' or 'yo-leven'.)
• Because each die has 6 possibilities, and there are two dice, out of the 36 possible combinations, rolling a 7 or 11 would be a probability of 8 out of  36 or 2/9.  
• Who knows, you could get lucky short term and win eight or nine times in a row.
• The probability of rolling a two 'snake eyes' is a low probability at about 3%, but the casino pays more on a bet, if the 'shooter' rolls a two.
•  Typically, the bet on 2 would be bet as including three number to make if more likely  (2, 3 or 12 roll), where if you win you are paid 7 to 1.  
• The casinos know that in craps, over the long term they are going to win about half the time.  
• You don't want to learn the 'hard way' when it comes to probability.   (Hard way is when a 4, 6, 8, and 10 rolled as doubles.) 

• Your construction project is defined by  more than the 36 possibilities as a dice game, so for the AHA you would select a probability, based on your experience of the activities you are analyzing.
• BLS.gov found that in 2020, workers in construction and extraction occupations experienced 21,400 nonfatal workplace injuries and illnesses due to falls, slips, and trips. 
•  The 2023 BLS Spotlight on Statistics focuses on the typical physical requirements for construction laborers, exposures they experience on the job, and nonfatal and the fatal injuries they incur, which could be considered a good reference for frequency of injuries.
•  An example is the frequency incidence rate of overexertion and bodily reaction for construction laborers - which was 48.3 cases per 10,000 full-time workers.  
• Construction laborers experienced 3,950 nonfatal injuries or illness resulting in at least one day away from work due to overexertion in 2020.

             RISK ☣️ Can you manage it?

• The question for the site may be - Does the Risk Management Process at the site effectively identify; analyze; evaluate; monitor; and control all work activities hazards/exposures - and mitigate the adverse effects of any injuries, illnesses, equipment, or property damages - to the desired acceptable defined risk level?  (Which is probably Low Risk). 
• For the AHA, ( Severity x Probability = Risk Assessment Code <RMC>) 
• Once you have rated the Severity and Probability of the activity exposure on the AHA, you can get the Risk Activity Code (RAC) from the colorful Chart  of E = Extremely High Risk H = High Risk M= Moderate Risk or  L = Low Risk .
•  A Risk Assessment Code (RAC) is assigned to each step, to the risk that remains after controls have been applied (residual risk).  
• The highest RAC (probability x severity) gets entered at the top of the AHA  

• Your team could consider watching the CSB video, linked  lower down this page.
• Think about the hazards and the event that occured.  
• Think about what they knew going in, and who else was involved.  
• Would you have analyzed the risk differently?  
• Would the team be able to stop and rethink things when things were not going well?
• Consider having a discussion and getting the teams thoughts.
• The thought process can be similar for assessing all risks, beyond just that event.

• Most of the safety plans I have seen are built for things going well.  Often there is something that a competent person or worker has to recognize during the job, and the decision to address the issue is what makes the difference to have a safe day.

• Even though there is a draft newer version of the EM 385 1-1 (the EM 385–1–1, April 2022  version), that 2022 version is "Informational Only"and still under review.  The EM 385 1-1 manual (the EM stands for "Engineers Manual)—the 2014 EM 385 1-1 revision, is still the most current version that is approved.  I would imagine that that is the version that is in you  contract or the rules you operate under with the U.S. Army Corps of Engineers Contractor (USACE) Safety and Health requirements. 

•  The EM 385 1-1 manual resulted from Executive Order (E.O.) 12196, Occupational Safety and Health Programs for Federal Employees, Executive Order 11988,  (back in 1980) which more recently under DoDI 6055.1   DoD policy applies to all Military Departments to: 

1.  Protect DoD personnel from accidental death, injury, or occupational illness.
2. Apply this instruction to all personnel at all operations worldwide with certain limitations.
3. Apply risk management strategies to eliminate occupational injury or illness and loss of mission capability and resources both on and off duty.
4. Use SOH management systems across all military operations and activities, including acquisition, procurement, logistics, and facility management.
5. Apply this instruction to off-duty military personnel, except for OSHA standards

•  The  AHA combined with continuous safety recognition and response to construction-site hazards is an important part of a successful safety injury prevention plan, that supports the DoD policy. 
• It is part of the  DoD Safety and Occupational Health (SOH) Program and under 2 b it states that:  
• The contractor is directly responsible for complying with federal and State occupational safety and health (OSH) standards for its employees.  
• Under the AHA, selecting the the appropriate personal protective equipment Safely using equipment, hand tools and ladders, and trench safety are part of what is covered in the EM 385 1-1 Training that are applied to the AHA.
• Outlined below are more details on roles and expectations.  

• The AHA's and JHA's are summarizing the important job steps or activities for the  day (not to many but not to few), what can go wrong given what you know about the hazards of the work your team is going to do, and how you are going to prevent your team from getting hurt, hurting others, breaking equipment, or doing damage on the project.
• There are many variables that might be different that day that should be accounted for.
• You might be able to understand most of the AHA activities figured out because of the work you did yesterday, but you should consider todays activities as well.  Do you have new hazards, other work nearby, a new team member, the weather changed, or maybe something else that a team member brings up. 

• Here is one last consideration for getting your team ready for a day of work on the project.
• Some days might be especially difficult for someone on your team.  
• Maybe a team member showed up for work, but their head is not in the game.  
• Maybe a parent died, a family member is in prison, the have a sick partner, were in a traffic accident, kid ran away - we all have tough days.
• Sometimes people are just going through some difficult times and some days are not the best to be working with live electrical or in a confined space.
• We may handle stress and challenges differently, but it is important to recognize severe stress of potential suicidal signs.

• I am reminded of a discussion I had with a coworker when we were investigating a fatality on a clients construction project.  
• The worker was electrocuted.  It was a heartbreaking tragic story.  The worker had a lot going on in his life.  
• He had just had his truck repossessed, he was going through a divorce, was living away from his kids, and he had been late and missing  work.
• He had a lot of stress in his life and he was in trouble at work for poor performance.   
• The day he died, was in the process of retrieving a tool that he forgot inside an live electrical cabinet (without his hard hat as well).  
• He did not want to tell his boss he messed up again, because that would have been his last strike.

• When he leaned in to get his torque wrench, the high voltage electricity entered his forehead and exited out his boot to ground - burning his internal organs and stopping his heart.  Truly a tragic and preventable death.  

• A lesson learned for me is that you really don't know what people are going through, but if you recognize some signals, you could help support them .
• I am no expert on mental health, but when each of my parents died, I know I would have been in no shape to do high hazard work soon after.  
• It takes a while to process high stress events, in my experience.
• I do think stress and mental health are important risks that can be overlooked.
• I have included some materials from OSHA below for you, I you want to learn more about you could help a team member or friend.

• Being able to focus of work activities is important, and you may consider what work is being done and recognize the ability to do the work.
• In construction, if we misjudge the margin of error, it can hurt or kill someone, so being able to focus in a safe way is a big deal.
• OSHA has some new Workplace Stress tools for this, here they are: 

• OSHA, Support One Another Toolkit (ZIP) Spanish (ZIP). 
• Provides tips on creating a workplace culture that support mental health by talking about mental health.
• Working Together poster. Provides a brief overview of steps employers and workers can take to address stress and mental health in the workplace.
• Supporting Your Co-Workers poster. Provides concrete tips that people can use to support their co-workers, offering suggestions on how to be respectful when broaching stress and mental health topics, how to listen compassionately, how to determine if more assistance is needed, and how to follow up on concerns.
• Worker-Fatigue Webpage. Focuses on worker fatigue and includes information about the impact of demanding work schedules and measures workers and employers can take to prevent worker fatigue and fatigue-related injuries and illnesses by providing or participating in education, training, and fatigue management programs.
•  https://www.osha.gov/preventingsuicides 
• Helping Your Co-Workers and Yourself poster.

PRE-TASK PLAN - AHA ADVENTURE GUIDE - RISK MANAGEMENT

01.A.15 USACE Risk Management Process. Risk management is a business process that includes the identification, assessment, and prioritization of risks, followed by coordinated and economical application of resources to minimize, monitor, and control the probability and/or impact of unfortunate events to an acceptable level.

• The USACE uses the Activity Hazard Analysis (AHA) as part of a total risk management process.  
• When Contractors are performing work on the USACE project site, the USACE S SOHO (Safety and Occupational Health Office)/ Chief of Health and Safety approach's the AHA roles as: 
• Contractor:   Required Activity Hazard Analyses are addressed in EM 385-1-1, paragraph 01.A.14 for each work activity involving a type of work presenting hazards not experienced in previous project operations or where a new work crew or sub-contractor is to perform the work. Competent and Qualified Personnel are to be specifically identified.
• USACE:   Required Activity Hazard Analyses are addressed in EM 385-1-1, paragraph 01.A.15 for each USACE activity as warranted by the hazards associated with the activity. Generally, this is for all field operations and for some office/administrative/other operations.  Competent and Qualified Personnel are to be specifically identified.

• Just as a refresher, here are the definitions from the EM 385 1-1 Manual for Competent Person and Qualified Person.  There are also more specific definitions for various types of activities: 

• Competent Person: one who can identify existing and predictable hazards in the working environment or working conditions that are dangerous to personnel and who has authorization to take prompt corrective measures to eliminate them.

• Qualified person: one who, by possession of a recognized degree, certificate, or professional standing, or extensive knowledge, training, and experience, has successfully demonstrated his/her ability to solve or resolve problems related to the subject matter, the work, or the project.

• These documents (AHA's) are intended to be created and used in the field, where the involved workers are located.  They are NOT intended to be corporate documents, nor just submittals.  Ideally, the workers involved with the activity should develop the AHA(s), as they normally have the technical expertise to know the process and the hazards involved.  It should be used as a training tool for all members involved in the activity, and reviewed before work begins. 
• There is a short YouTube Video below, where a USACE Chief of Safety summarizes site safety when working with a contractor on her site. 

• Here are details for when an AHA should be completed. 
• a. An AHA shall be prepared and documented for each USACE activity as warranted by the hazards associated with the activity. Typically, an AHA shall be prepared for all field, laboratory, industrial and maintenance activities. 
• b. The supervisor, utilizing the recommendations of the SOHO, should determine the need for an AHA for each activity within his/her area of responsibility. AHAs shall define the steps being performed within the activity or task, identify the work sequences, specific anticipated hazards, site conditions, equipment, materials, personnel and the control measures to be implemented. 
• c. Before beginning each work activity, the workers performing that work activity shall prepare the initial AHA. A Risk Assessment Code (RAC) is assigned to each step, to the risk that remains after controls have been applied (residual risk). In developing the AHA for a particular activity, the involved workers should draw upon the expertise (knowledge, skill and experience) of the USACE supervisor for that activity as well as the SOH Office. 

1. Once this process has occurred, a RAC will be assigned to the activity as a whole (cannot be lower than the highest step RAC). 
2. Acceptance of risk. This residual risk must then be communicated to the proper authority for acceptance in order to proceed with the activity. 
3. The names of the Competent Person(s) (CP) and Qualified Person(s) (QP) required for a particular activity (e.g., confined space entry, scaffolding, fall protection or other activities as specified by OSHA/this manual) shall be identified and included in the AHA, as well as proof of their competency/qualification. 
4. If more than one CP/QP is used on the AHA activity, a list of names and appropriate qualifications shall be noted on the AHA. Those listed must be CPs/QPs for the type of work involved in the AHA and familiar with current site safety issues. d. Work shall not begin until the AHA with RAC for the work activity has been discussed with all engaged in the activity in a job pre-brief (to include Supervisor and/or local SOHO if applicable). 

• I have included this summary of a USACE article, because I am impressed with the safety process and level of caring to keep workers safe.  
• It can be easy to get caught up in just getting the job done, making your money, and moving on to the next job.  

• On a poorly managed construction project, where I was conducting a job site safety visit as a consultant, I remember asking a worker in a trench to come up and speak with me.  
• He climbed up the dirt wall, not sure why I needed to talk to him.  
• It was his second day on the job and he was just doing what is boss told him to do.  
• The worker in the trench did not recognize the tons of dirt as hazard that could bury him during a cave in if a truck drove by.  

• His boss came running over from his truck when he saw me talking to his worker.  
• He knew not having a trench box or a proper sloping or shoring system was wrong, and he told me "We're only going to be here three more days!" 
• His boss did not think anything would really happen, and cared more about getting paid then he did about the young man just trying to earn money another day.  
• His boss was the owner of the Trenching company, and was angry that I was stopping his work and going to cost him more time and money to make the changes to the trench, to make it safe.  

• Unfortunately, not all construction projects are as diligent about worker safety and contractor selection.  It can be difficult dealing with angry people and there is a lot of pressure to get work done, but it makes a huge difference in worker's lives.  
• Having a good safety process, and using AHA or JHA gets much better results than fighting about what the minimum standard for safety is.

• It can be what surprises workers, that gets them injured or killed.  
• The USACE safety planning, analysis, and execution safety system helps reduce that surprise element drastically.  

• There are more than 30 'Lessons Learned 'from USACE Fort Worth District are linked in the Banner below.  
• Thank you to the USACE Fort Worth District team for making you blank AHA form and Lessons Learned available! 

Here are some helpful guides that may be useful for safety on Superfund Projects.

OSHA, 2021 - PPE for Emergency Response and Recovery Workers.  

OSHA, 2021 -  Equipo de Protección Personal (EPP) para los Trabajadores de Respuesta y Recuperación en Emergencias 

EPA.gov, 2022, Emergency Response Personal Protective Equipment Level A to D Protection 

OSHA, 2008 Publication - Hazardous Waste Operations and Emergency Response 

NIOSH Pocket Guide to Chemical Hazards, General industrial hygiene information for hundreds of chemicals/classes 

NIOSH/ OSHA/ USCG/ EPA Occupational Safety Guidance Manual for Hazardous Waste Site Activities

DOT, 2024 Emergency Response Guidebook (ERG)

OSHA/ NIEHS  Safety and Health Awareness for Oil Spill Cleanup Workers 

There are great lessons to learn from the FIVE STAR SAFETY (my opinion) approach to a safe project at the Maywood Superfund Site.  Kudos to all the safe Workers, Cabrera Services, Contractor Supervisors, Safety Officers/ Managers, and USACE SOHO & the Project Team!  

If you are looking for some tips on how to effectively run a safe project, you are going to appreciate this article.  

Here is a summary of the great USACE Safety Approach Maywood Superfund Site that is linked below.

Worker Safety Best Practices

• Not only is the health of the community important, but also the safety of the project’s workers, especially when it comes to FUSRAP projects. Michael Johnson, team leader, New York District, U.S. Army Corps of Engineers said, “Safety is very important for all construction projects and especially for FUSRAP projects because these projects introduce the workers to potential exposures to contaminants above and beyond your typical construction project hazards.”
• Because of this the team has implemented a series of worker safety best practices for its workers. The team has been so successful in doing this that they achieved 1-million-man hours without a lost time accident. “This type of achievement is rare. This is the only project that I have worked on in the Army Corps that has achieved this milestone,” says Johnson who has worked on this project for 15 years. Following is some of the key worker safety best practices the team is performing that make this project a leader in worker safety.

A.M. Safety Counseling

• Every morning, the workers take part in a short Daily Tailgate Meeting. According to Johnson, this 30-minute meeting sets the day for the team. During the meeting they discuss several things including the project’s safety analyses that can include discussing the steps needed to get through the potential hazards of a specific job. They also discuss a safety topic of the day that can include near misses or accidents that happened in the construction industry recently. Following this they hold a Q & A session and last the workers get up and take to the floor for some stretching exercises before heading out to the job site.

Worker Empowerment

• Workers are encouraged to have open dialogue to reduce workplace accidents. Johnson said, “For example, the workers have Stop Work Authority which means anyone on the job has the authority to stop the project is they observe unsafe conditions or behavior.”

Safety Incentive Award Program

• Each month, workers receive safety incentive awards for proactively taking steps to ensure safety on the project. According to Johnson, this program is a way to ensure inclusion for the project’s safety commitment.  The program is designed to have targeted goals that empower personnel to have “skin in the game” and encourages workers to proactively take ownership of the project safety culture by meeting those safety-oriented goals. In addition, each quarter, workers are selected by their peers as the “Quarterly Safety Performer” 
• Recognizing exemplary safety performance and achievement.
• According to Bill Lorenz, vice president of Cabrera Services, Inc, a contractor who plays an integral part in the project’s safety measures says, “We are recognizing and rewarding our employees, not only for noticing and taking actions to eliminate hazards from the job site, but also for making positive observations that illustrate a commitment to safety for everyone on the project.” 

• Here is the link to this article, by JoAnne Castagna, Ed.D., U.S. ARMY CORPS OF ENGINEERS, NEW YORK DISTRICT, Published March 13, 2023:

• Construction contract work under the provisions of FAR Clause 52.236-13. Contractors shall comply with the latest version of EM 385-1-1 (including interim changes) that is in effect on the date of solicitation. Prior to making an offer, bidders should check the HQUSACE Safety and Occupational Health website (see paragraph c) for the latest changes.

•  01.B Indoctrination and Training. 
• 01.B.01 A Competent Person (CP), qualified in the material presented, shall conduct all training required by this manual. All training shall correspond to American National Standards Institute (ANSI) regulation Z490.1. 01.B.02
• Employees shall be provided an SOH indoctrination prior to the start of work as well as continuous SOH training to enable them to perform their work in a safe manner. All training, meetings and indoctrinations shall be documented in writing by date, name, content and trainer. 
• 01.B.03 Indoctrination and training should be based upon the existing SOH program of the Contractor or Government agency, as applicable, and shall include but not be limited to: 
• a. Requirements and responsibilities for accident prevention and the maintenance of safe and healthful work environments; 
• b. General SOH policies and procedures and pertinent provisions of this manual; 
• c. Employee and supervisor responsibilities for reporting all mishaps; 
• d. Provisions for medical facilities and emergency response and procedures for obtaining medical treatment or emergency assistance; 
• e. Procedures for reporting and correcting unsafe conditions or practices; 
• f. Job hazards and the means to control/eliminate those hazards, including applicable PHAs and/or AHAs; 
• g. Specific training as required by this manual.