USACE Accident Prevention Plan Review.
No contract work can begin until the Contracting Officer or COR accepts your Accident Prevention Plan. We read your APP against EM 385-1-1 and your contract before it goes in, so what comes back from the government is acceptance rather than a list of corrections.
What EM 385-1-1 Asks of an APP
The manual describes the APP as a written, site-specific safety and occupational health plan that documents the project, contract, and job-specific hazards, and the company policies, controls, and work practices that will be used to minimize them. It has to be developed by a Competent Person, reviewed and approved by the prime contractor and the corporate safety official, and then submitted to the Contracting Officer or COR for review and acceptance before any work is performed (paragraph 2-7.b).
The plan follows the mandatory ENG Form 6293, the Accident Prevention Plan Worksheet (paragraphs 2-7.b(1) and 2-10.d). It has to name the specific work, work process, equipment, and materials, the hazards that go with them, and the controls that will be put in place. Information you don't have yet, such as subcontractors or the specific cranes coming to site, is added and submitted before each preparatory phase with the matching AHAs (paragraph 2-7.b(2)).
Government acceptance is a cursory review to see whether the submittal generally conforms to the contract's safety requirements, and a plan that doesn't conform is returned for correction (paragraph 2-8.c). Acceptance doesn't relieve the contractor of anything. That's why a careful read on your side, before submission, is worth the time.
A Review Built Around the Worksheet
We read your plan the way a reviewer on the government side will: section by section, against the worksheet, the manual, and your contract.
- Every item on ENG Form 6293 is answered, and answered for this project rather than in general terms
- The work, equipment, and materials in the plan match your contract scope
- Hazards are tied to the work that creates them, with controls to match
- Plans the manual requires for your scope, such as fall protection or excavation plans, are included or scheduled
- Your risk acceptance process and who accepts each level of residual risk are written into the plan (paragraph 2-6.c(2))
- SSHO designation, competent person credentials, and training records line up with what the plan says
Comments You Can Act On
You get a numbered list of comments, each one tied to the section or page it's about, so your team can find it and decide how to handle it. Where it helps, we include example language, and the plan stays yours: your competent person develops it and your company approves it, the way the manual intends.
We don't stop at the first read either. The manual expects the SSHO to keep the APP current and site-specific for the life of the project, with changes approved by the contractor and submitted for acceptance (paragraph 2-7.b(3)), and we're glad to read revisions as the job moves along.
Optimum Safety is led by Kali Irvin, CSP, CHST (both through BCSP), currently an SSHO on a federal construction project under EM 385-1-1, so the plans we read are the kind we work under. We're a small business, so you deal directly with the person reading your plan.
AHAs usually travel with the APP. See our activity hazard analysis review, or read what the manual requires in EM 385-1-1 APP requirements.
Getting Ready to Submit Your APP?
Send us the draft and the safety section of your contract, tell us when it's due, and we'll tell you when you'll have our comments.