What Must a USACE Activity Hazard Analysis Include?

An activity hazard analysis (AHA) under USACE EM 385-1-1 must be prepared and documented for field, laboratory, industrial and maintenance activities, and an initial AHA must be prepared before each work activity, task or definable feature of work begins (EM 385-1-1, 2-6.d). Paragraph 2-6 sets the contractor AHA requirements, and paragraph 1-6 sets the parallel rules for USACE personnel.

Contents. An AHA must identify the activity, location, date, preparer and acceptance authority. It must define the job steps, list the hazards of each step, and list the controls needed to reduce each hazard. Each step gets a risk assessment code (RAC) for the residual risk after controls, and the overall RAC must not be lower than the highest step RAC. The AHA must also list equipment, training and inspection needs, and required competent and qualified persons must be designated in writing. AHAs are written by competent persons.

Controls. Controls follow a hierarchy from elimination or substitution to engineering controls, administrative controls and then personal protective equipment (EM 385-1-1, 2-6.b).

Acceptance and review. Work that requires an AHA must not begin until the AHA with its RAC has been reviewed and accepted by the proper authority. USACE does not accept contractor risk through this review. Involved employees must review and sign the AHA. Job safety analyses and job hazard analyses are acceptable equivalents (EM 385-1-1, 2-6.c and 2-6.d).

Onsite copies and updates. AHAs must be available onsite for 12 months, and crews must have the current AHA while working. When the AHA is updated and the RAC increases, the AHA must be resubmitted for acceptance before work starts. ENG Form 6206 is a non-mandatory AHA format.

Related topics. Incident testing after an accident is covered in the FAQ on OSHA post-incident drug testing. Respirator selection appears in the FAQ on NIOSH-approved respirator requirements, and overlapping rules are covered in the FAQ on whether DOT employers are regulated by OSHA.

The FAQ on USACE Site Safety and Health Officers covers who inspects the work, and the FAQ on EM 385-1-1 contractor applicability covers coverage.