EM 385-1-1 SSHO Requirements in the 2024 Manual.

Three Levels of SSHO

The manual defines the SSHO as a contractor employee responsible for overseeing and ensuring implementation of the prime contractor's safety and occupational health program (paragraph 2-2.x). It then sets three levels. A Level 1 SSHO has full-time safety responsibility. A Level 2 SSHO has collateral duty safety responsibility. A Level 3 SSHO is a designated Qualified Person or Competent Person with safety responsibility. Levels 2 and 3 cannot be assigned to projects that have a residual Risk Assessment Code of high or extremely high (paragraph 2-2.x(1) to (3)).

Training and Experience by Level

Level 1 and Level 2 SSHOs both need OSHA 30-hour general industry or construction training, and both need 24 hours of documented safety and health training within the past five years, then 24 more every three-year period for the life of the contract. The manual notes that the OSHA 30-hour course itself does not count toward the 24 hours, and that hours spent teaching a safety course can count, once per course (paragraph 2-3.b(1) and (2)).

Experience is where the levels differ. A Level 1 needs at least five years of cumulative safety experience within the last ten, managing or implementing a safety program on projects similar in type, size, and complexity; three years is enough with a safety-related degree or a third-party, nationally accredited certification that takes at least three years of experience to obtain (paragraph 2-3.b(1)(c)). A Level 2 needs three years within the last ten, or two with a qualifying degree or certification (paragraph 2-3.b(2)(c)). A Level 3 must be a designated Qualified or Competent Person with the experience to identify hazards and put controls in place for the work (paragraph 2-3.b(3)). For Levels 1 and 2, the Contracting Officer, working with the local Safety and Occupational Health Office, may adjust the training and experience requirements (paragraph 2-3.b, notes).

Time on Site

The contractor must employ at least one Level 1 SSHO at each project site as the primary SSHO, and a designated Level 1 must be at the site of work whenever work is performed. A Level 1 SSHO is not permitted to supervise non-safety personnel. Projects with multiple sites or shifts, or large projects, may need additional or alternate SSHOs, and the contract will say so (paragraph 2-8.b(2)). While on site, SSHOs must be located so they have full mobility and reasonable access to all major work operations during the shift (paragraph 2-4.b).

If the Level 1 has to leave for up to 24 hours because of something unforeseen, a Level 1, 2, or 3 SSHO may cover in the interim. If the Level 1 will be gone longer than 24 hours, an additional or alternate Level 1 must be at the site of work whenever work is performed (paragraph 2-8.b(2)(c) and (d)). Remote sites more than 45 minutes from the primary Level 1's site, on activities rated low or medium, may use an SSHO of any level (paragraph 2-8.b(2)(e)). Any project with a residual RAC of high or extremely high must have a Level 1 assigned and on site (paragraph 2-8.b(2)(f)).

Exceptions and Designation

The Contracting Officer and the local Safety and Occupational Health Office can modify the full-time Level 1 requirement in the contract documents, based on job complexity, size, and other factors. The manual's examples include tasks with no exposure to mechanical or explosive hazards, such as surface soil sampling, and dredging, maintenance, service, and limited scope contracts (paragraph 2-8.b(3)).

Every SSHO, at every level, is designated in writing on the mandatory ENG Form 6282, and work doesn't start until it's accepted (paragraph 2-8.b(1)). Our article on ENG Form 6282 covers that step, and our page on SSHO staffing for USACE projects covers how we place SSHOs who meet these requirements.