EM 385-1-1 Accident Prevention Plan Requirements.

On a contract under EM 385-1-1, the Accident Prevention Plan comes first: no contract work begins until the Contracting Officer or COR has accepted it. Here's what the 15 March 2024 manual requires of the APP, who has a hand in it, and how it stays current, with paragraph numbers.

What the APP Is

The manual defines the APP as a safety and occupational health plan that documents site-specific policies, responsibilities, and plan and program requirements (paragraph 2-2.c). In paragraph 2-7.b it describes the APP as a written, site-specific plan that documents project, contract, and job-specific potential hazards, and the company policies, controls, and work practices used to minimize them, and calls it an integral part of planning and risk management.

Who Develops, Approves, and Accepts It

The APP must be developed by a Competent Person and reviewed and approved by the prime contractor and the corporate safety official, then submitted to the Contracting Officer or COR for review and acceptance before any work. No contract work can begin without an accepted APP (paragraph 2-7.b). The Competent Person develops and signs it and coordinates its review with affected employees, prime and subcontractors (paragraph 2-4.c(3)). The Corporate Safety Official reviews and approves it with a signature and date (paragraph 2-4.f(2)). The prime contractor makes sure a Competent Person developed it, reviews it for compliance before submission, and keeps the Competent Person's credentials on site for the Contracting Officer to review (paragraph 2-4.g(3)).

What Goes In It

The APP is written in English and describes the specific work, work process, equipment, and materials, the hazards of the contract work, and the controls that will be used, following the mandatory ENG Form 6293, the Accident Prevention Plan Worksheet (paragraph 2-7.b(1)). It includes measures to control hazards from materials, services, or equipment provided by vendors and subcontractors, and it addresses any unusual or unique aspects of the project (paragraph 2-7.b(3)(a) and (b)).

Other plans ride with it. All plans and other safety submittals the manual requires are submitted as part of the APP, and work can't begin until they're accepted (paragraph 2-7.a(2) and (3)). The APP also carries the prime contractor's risk acceptance process and the people with acceptance authority for each level of residual risk (paragraph 2-6.c(2)).

What You Don't Know Yet

The manual expects some of the work to be unknown at submission. Include everything known before work starts; information that comes later, such as the subcontractors, the type of fall protection for a phase, or the specific cranes coming to site, is added and submitted before each preparatory phase or meeting along with the matching AHAs (paragraph 2-7.b(2)).

Keeping It Current

The SSHO evaluates and updates the APP throughout the project so it stays current and site-specific; changes are reviewed and approved by the contractor and submitted to the Contracting Officer or COR for acceptance (paragraph 2-7.b(3)). The accepted APP has to be available at the site of work at all times and accessible to all employees, with a copy on the safety bulletin board or a notice saying where it is (paragraph 2-7.b(4)).

AHAs work hand in hand with the APP; read EM 385-1-1 AHA requirements. If you'd like a second read before you submit, see our accident prevention plan review.

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