OSHA Training vs EM 385-1-1 Why USACE Projects Ask for More.

One Set of Rules on Top of Another

The manual's preamble lists 29 CFR 1926, OSHA's construction standards, among its references, and says the manual is designed to supplement those requirements. Contractors follow the manual and every applicable federal, state, and local rule, and where the requirements differ, the most stringent governs (preamble, paragraphs 4 and 5.a). The manual applies to construction contract work under FAR clause 52.236-13, and contractors comply with the version in effect on the date of solicitation (preamble, paragraph 5.b(1)). So on a federal job, OSHA is not replaced; the manual adds to it. Four places where that shows up in training and paperwork are below.

SSHO Qualifications Start at OSHA 30

Every Level 1 and Level 2 Site Safety and Health Officer needs OSHA 30-hour general industry or construction training, and the manual then builds on it: 24 hours of documented safety and health training within the past five years, and 24 more every three-year period for the length of the contract. The manual says plainly that the OSHA 30-hour course does not count toward those 24 hours (paragraph 2-3.b(1) and (2)).

Experience is on top of that. A Level 1 needs at least five years of cumulative safety experience within the last ten on projects similar in type, size, and complexity, or three years with a safety-related degree or a qualifying accredited certification (paragraph 2-3.b(1)(c)). The Contracting Officer, working with the local Safety and Occupational Health Office, can adjust the training and experience requirements, so your contract language governs (paragraph 2-3.b, notes).

Competent Person Classes Have a Minimum Length

The manual sets how much training some competent persons need, not just the topics. Initial fall protection competent person training must include a minimum of 24 hours of course work, combining formal classroom training with a performance assessment of trainees, conducted by a competent person or qualified person trainer who documents the training and issues a certificate (paragraph 21-3.c(1) and (2)). All fall protection training follows ANSI/ASSP Z359.2 and ANSI/ASSP Z490.1 (paragraph 21-3).

A scaffold competent person needs a documented minimum of 8 hours of scaffold training, including training on the specific type of scaffold being used (paragraph 22-3.b(1)). The employer decides the rest of that training, but it must include assessment of the base material, load calculations for materials and personnel, erection and dismantling, and the training requirements in the applicable ANSI standard (paragraph 22-3.b(5)). On a USACE job, the length and content of a class matter as much as its title.

Written Plans Before the Work Starts

Two documents have to be accepted before the work they cover begins. The Accident Prevention Plan is developed by a Competent Person on the mandatory ENG Form 6293 worksheet, and no contract work can begin without an APP the Contracting Officer or COR has accepted (paragraphs 2-7.b and 2-7.b(1)).

An Activity Hazard Analysis is required for all field, laboratory, industrial, and maintenance activities, prepared before each activity, task, or definable feature of work begins (paragraph 2-6.d(1)), and activities that require one must not begin until the AHA, with its Risk Assessment Code, has been reviewed, accepted, and signed by the proper approval authority (paragraph 2-6.c(1)). Each AHA lists the training requirements for the people doing the work, and the employer designates the required competent and qualified persons by name, in writing, with proof of their competency or qualification (paragraph 2-6.d(4)(g)). That is where the training above gets put on paper.

What This Means for Your Crew

If your crews work both commercial and federal jobs, training that covers both saves you from sorting it out later: OSHA's construction standards for every job, and the EM 385-1-1 hours, content, and documentation a USACE contract adds. Our training courses are built for both, and our page on SSHO staffing for USACE projects covers the people side. For more on each point, see our articles on EM 385-1-1 SSHO requirements, AHA requirements, and APP requirements.