Activity Hazard Analysis Review for EM 385 Projects.
Activities that require an AHA can't begin until the AHA, with its Risk Assessment Code, has been reviewed and accepted. We read your AHAs against paragraph 2-6 of EM 385-1-1 before they're submitted, so the crew can start on the day you planned.
What EM 385-1-1 Asks of an AHA
The manual requires an AHA for all field, laboratory, industrial, and maintenance activities, prepared before each activity, task, or definable feature of work begins, and written by Competent Persons who draw on the expertise of the employees, supervisors, and safety staff involved (paragraph 2-6.d(1)). Contractors submit their accepted AHAs to the Contracting Officer or COR for review and acceptance (paragraph 2-6.d(4), note), and activities that require an AHA must not begin until it has been reviewed, accepted, and signed by the proper approval authority (paragraph 2-6.c(1)).
ENG Form 6206 is a non-mandatory format for the AHA (paragraph 2-10.b). Job Safety Analyses and Job Hazard Analyses are accepted as equivalents as long as they collect the same data the AHA requires (paragraph 2-6.d(1), note), so the content matters more than the form it's on.
Every Element Paragraph 2-6.d(4) Lists
These are the items the manual says an AHA must include, and we check each one against the work the AHA describes.
- The activity name, contractor name and contract number, location, date, preparer, and acceptance authority
- Job steps detailed enough that a reader understands how the work will actually be done
- The hazards for each specific job step, not one list for the whole activity
- Controls for each hazard, with more than one layer where one layer doesn't bring the risk down far enough
- A RAC for every job step, and an overall RAC no lower than the highest step
- Equipment, training, and inspection requirements, with the required Competent and Qualified Persons named
AHAs Change as the Job Does
An AHA is modified when site conditions or operations change, or when a Competent or Qualified Person changes. If a change raises the RAC, the AHA is resubmitted for acceptance before work starts; if it doesn't, it isn't required to be resubmitted (paragraph 2-6.d(5)). Every involved employee reviews the AHA before starting the task and signs it (paragraph 2-6.d(2)), and crews keep the current AHA with them while they work (paragraph 2-6.d(3)). We're glad to read revisions as well as first submissions.
You get a numbered list of comments, each tied to the job step or section it's about. Where it helps, we include example language. The AHA stays yours: your Competent Person writes it from what your crew knows about the work, and our comments help it say so clearly.
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. For the reasoning behind the risk codes, read the Risk Assessment Code (RAC) and EM 385-1-1 AHA requirements. AHAs usually go in alongside your Accident Prevention Plan.
Have AHAs Ready to Go In?
Send us the AHAs and the schedule for the work they cover, and we'll tell you when you'll have our comments.