EM 385-1-1 Activity Hazard Analysis Requirements.

When an AHA Is Required, and Who Writes It

AHAs must be prepared and documented for all field, laboratory, industrial, and maintenance activities. An initial AHA is prepared before each work activity, task, or definable feature of work begins. The writers are Competent Persons, who should draw on the knowledge, skills, and experience of the employees, supervisors, and safety staff involved (paragraph 2-6.d(1)). Supervisors are responsible for making sure AHAs are developed by Competent Persons (paragraph 2-4.e(9)). Individual chapters add their own AHA requirements in their paragraph 6 (paragraph 2-6).

The form isn't the point. ENG Form 6206 is a non-mandatory format (paragraph 2-10.b), and Job Safety Analyses, Job Hazard Analyses, and similar tools are acceptable substitutes as long as they collect the same data the AHA requires (paragraph 2-6.d(1), note).

What Every AHA Must Include

Paragraph 2-6.d(4) lists the contents:

• The activity, task, or feature of work; the contractor name and contract number; the project location; the date; and the name and title of the preparer and of the acceptance authority
• The job steps and work sequences, detailed so a reader clearly understands how the job will be done
• All potential hazards for each specific job step
• The controls for each hazard, with additional controls where one layer can't bring the risk to an acceptable level (low or medium where possible)
• A Risk Assessment Code for each job step, showing the residual risk after controls
• An overall RAC for the AHA, never lower than the highest job step RAC
• Equipment, training, and inspection requirements, with any required Competent and Qualified Persons designated in writing by name and proof of their competency or qualification
• Risk acceptance by the proper authority

Controls are chosen using the hierarchy in paragraph 2-6.b: elimination or substitution, then engineering controls, then administrative controls, then PPE, which the manual says should not be the only protection against a hazard.

Acceptance Before Work

Activities that require an AHA must not begin until the AHA with its RAC has been reviewed, accepted, and signed by the proper approval authority. The prime contractor sets up an internal process naming who accepts each level of residual risk and writes it into the APP, and the manual notes that USACE does not accept contractor risk (paragraph 2-6.c). Contractors then submit their accepted AHAs to the Contracting Officer or COR for review and acceptance (paragraph 2-6.d(4), note).

On Site and Over Time

Every involved employee reviews the AHA before starting the task and signs it or a signature sheet (paragraph 2-6.d(2)). AHAs stay available on site for 12 months, or for contracted work the length of the contract, and crews keep the current AHA with them while they work (paragraph 2-6.d(3)).

The AHA is updated as 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; changes that don't raise it don't have to be resubmitted. If work was stopped for safety non-compliance and the AHA needs revising, work doesn't resume until the revision is accepted and employees have reviewed it again (paragraph 2-6.d(5)).

For how RACs are assigned, read the Risk Assessment Code (RAC). If you'd like a second read before submission, see our activity hazard analysis review.