What EM 385-1-1 requires on an AHA
EM 385-1-1 is the Corps' safety and occupational health manual. It applies to USACE elements and to USACE contracts, including contractor personnel performing activities at a USACE site of work. [US Army Corps of Engineers] Chapter 2 covers contractors. Its paragraph 2-6.d sets what an AHA must contain, and the first line is broad:
“AHAs must be prepared and documented for all field, laboratory, industrial, and maintenance activities performed.”
Each field on the template maps to an item in paragraph 2-6.d(4):
| On the form | What goes there |
|---|---|
| Activity / task / DFOW, project location, date | The activity or definable feature of work, where, and the date the AHA was developed. All three are in EM 385-1-1 para 2-6.d(4)(a). [US Army Corps of Engineers] |
| Contractor name and contract number | Required by 2-6.d(4)(a). [US Army Corps of Engineers] Most generic JHA forms leave these out, which is why a JHA cannot simply be relabeled as an AHA. |
| Prepared by; acceptance authority (name and title) | Both the preparer and the acceptance authority are identified by name and title. [US Army Corps of Engineers] The acceptance signature and date sit beside them. |
| Overall RAC | The residual risk for the whole activity. It may not be lower than the highest step RAC on the form. [US Army Corps of Engineers] |
| Job steps | The manual wants steps detailed enough that a reader understands how the job will be done, and gives examples: how a part is installed or removed, anticipated voltages, quantities of chemicals, equipment used, heights accessed or trenched. [US Army Corps of Engineers] |
| Potential hazards | All potential hazards for each specific step. [US Army Corps of Engineers] |
| Controls | All controls needed, chosen through the hierarchy in 2-6.b: elimination or substitution, engineering, administrative, PPE. If one layer does not bring the risk to an acceptable level, add more. [US Army Corps of Engineers] |
| RAC per step | The residual risk left after the controls for that step, as E, H, M or L. [US Army Corps of Engineers] |
| Equipment, training, inspection requirements | A three-column table for 2-6.d(4)(g): the equipment needed, the training the people involved need, and any inspections the activity requires. [US Army Corps of Engineers] |
| Competent and qualified persons | The manual asks the employer to designate required CPs and QPs by name in writing for activities such as excavation, confined space, scaffolding and fall protection, with proof of competency. [US Army Corps of Engineers] This table records the names and where the proof is. |
| Employee review signatures | Every involved employee reviews the AHA before starting and documents the review with a signature on the AHA or an added signature sheet. [US Army Corps of Engineers] The template carries 22 lines across the last pages. |
Assigning the RAC
The manual defines the Risk Assessment Code this way:
“The conversion of the probability and severity of a given hazard into a specific risk level based on the residual risk. The levels of risk are extremely high (E), high (H), medium (M) and low (L).”
Severity is rated catastrophic, critical, moderate or negligible, and probability frequent, likely, occasional, seldom or unlikely; the risk matrix converts the pair into the RAC. [US Army Corps of Engineers] The template prints these categories as a key but does not print a matrix, because the manual's text refers you to the matrix rather than fixing the cell values in words, and your accepted plan may carry its own. Rate each step after its controls, since the RAC is residual risk, then set the overall code:
“Assign an overall RAC to the AHA. The overall RAC must not be lower than the highest job step RAC on the AHA.”
The controls column is meant to bring each step down to low or medium where possible, adding layers of control if one is not enough. [US Army Corps of Engineers]
How to fill it in
- Header first. Activity or DFOW name, contractor, contract number, project location, date, and your name and title as preparer. Leave the acceptance block for the authority named in your plan.
- Write the steps in detail. The manual wants a reader to understand how the work will be done: voltages, chemical quantities, equipment, heights, trench depths. [US Army Corps of Engineers] Draw on the crew, supervisors and safety staff; the manual expects the writer to use their knowledge and experience. [US Army Corps of Engineers]
- List every hazard for each step, then the controls, working down the hierarchy: eliminate or substitute, engineer it out, change the procedure, then PPE. [US Army Corps of Engineers] The manual warns that PPE should not be the only protection against a hazard. [US Army Corps of Engineers]
- Rate the residual risk for each step, then the overall RAC, no lower than the highest step. [US Army Corps of Engineers]
- Fill the equipment, training and inspection table, and name the competent and qualified persons the activity needs, with where their proof of competency is filed. [US Army Corps of Engineers]
- Get it accepted, then reviewed and signed by every involved employee before the activity begins. [US Army Corps of Engineers]
Example row
EM 385-1-1 does not print a filled AHA, so this example row borrows OSHA's worked job hazard analysis of grinding iron castings and adds the AHA-specific columns. The hazard and controls are OSHA's words; the step wording is ours, and the RAC is left for you, because it depends on your matrix and your site.
- Reach into the metal box, grasp a 15-pound casting and carry it to the grinding wheel; 20 to 30 castings per hour.
“Picking up a casting, the employee could drop it onto his foot. The casting's weight and height could seriously injure the worker's foot or toes.”
“1. Remove castings from the box and place them on a table next to the grinder. 2. Wear steel-toe shoes with arch protection. 3. Change protective gloves that allow a better grip. 4. Use a device to pick up castings.”
- Rate the residual risk with the controls in place, using your accepted matrix.
- Grinder, staging table, pick-up device; grinder operation training; daily grinder and guard inspection (your entries).
Review, acceptance and updates
Work waits for acceptance:
“Activities that require an AHA must not begin until the AHA with the identified RAC has been reviewed, accepted, and signed by the proper approval authority.”
Prime contractors set out in their accident prevention plan who accepts each level of residual risk, and the manual notes that USACE does not accept contractor risk. [US Army Corps of Engineers] Accepted AHAs are submitted to the contracting officer or COR for review. [US Army Corps of Engineers] Every involved employee reviews the AHA before the task and signs:
“AHAs must be provided to and reviewed by all involved employees prior to starting the task. Each employee must document their review with a signature on the AHA or an additional signature sheet.”
The AHA is updated when site conditions, operations or the named competent or qualified persons change. [US Army Corps of Engineers] If a change raises the RAC, the AHA goes back for acceptance before work starts; changes that do not raise the RAC do not need resubmission; and after any revision, work does not resume until every involved employee has reviewed the new version. [US Army Corps of Engineers] Keep AHAs available on site for 12 months or the length of the contract, and make sure the crew has the current one with them while the work is done. [US Army Corps of Engineers]