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New Requirements for Accident Prevention Plans in the Revised EM 385-1-1

The Accident Prevention Plan (APP) is a requirement for the commencement of work on a government construction project and is one of the first documents you must submit for a project.

The new version of the EM 385-1-1 will likely go into effect in the third quarter of 2022, and will significantly change the formatting of any new Accident Prevention Plans. 

Thankfully, we can provide an example outline for the structure required for each site-specific plan and the information that must be included. Understanding these changes in advance of the plan revision will provide an advantage in mitigating plan rejections.

What Must be Included in Site-Specific Accident Prevention Plan?

An accident prevention plan needs to consist of 10 sections in order to meet the revised EM 385-1-1 requirements. These 10 required sections are:

  1. Signature sheet
  2. Background information
  3. Statement of safety and health policy
  4. Responsibilities and lines of authority
  5. Subcontractors and suppliers
  6. Training
  7. Safety and health inspections
  8. Accident reporting
  9. Plans
  10. Risk management process

It’s also important to keep in mind that an APP isn’t something that you create, submit, and do your best to abide by. It’s a fluid document that should change over time – and not just when safety standards change, but as you conduct reviews of the plan. Revisions should be commonplace as standards change and as your firm’s goals change. Think of an APP as a long-term commitment and not just something that’s necessary for you to “check a box” when working on a project. Committing to one and making it a part of your safety culture can significantly reduce accidents and make your job site a safer overall place for all who are working on it.

Section 9 Changes

Section 9 of EM 385-1-1, which addresses site-specific plans, has included the following changes that are important to pay attention to.

  1. The checklist doesn’t provide you with a list of possible plans you will have to go through the EM-385 to identify what plans may be required for each project. It is up to you to assess the project and what is required. You can find a list of required plans per chapter in sub-chapter 7 of each main chapter.
  2. The order in which plans are listed in the APP has also changed and will be required to be in a specific order when submitted.
  3. Section 9 should be formatted as a checklist and not included as part of an APP. Use the following order: 
    1. Attach Section 9 Checklist in Appendix A
    2. All information that is not yet known. The Plan will be provided on: [Insert date it will be submitted]
    3. No, this plan is not required for this project. [Justify why]

Alongside the Accident Prevention Plan, there are 68 additional site-specific plans that may be required as an appendix to the Accident Prevention Plan. ACE Consulting has reviewed the draft version of this EM 385-1-1 and understands the changing requirements to the Accident Prevention Plan and their accompanying site-specific plans. 

These Site-Specific Plans Include:

  • Medical & First Aid
    • Site-Specific Exposure Control Plan
    • AED Program
  • Sanitation
    • Housekeeping Plan
    • Extermination Plan
  • Hazardous or Toxic Agents and Environments
    • Hazard Communication (HazCom) Program
    • Process Safety Management (PSM) Program
    • Lead Compliance Plan
    • Asbestos Compliance Plan
    • Ionizing Radiation Safety Plan
    • Radiofrequency (RF) Plan
    • Abrasive Blasting Plan
    • Thermal Stress Management Plan
    • Mold Remediation Plan
    • Silica Compliance Plan
    • Fatigue Management Plan (FMP)
  • Lighting
    • Night Operations Lighting Plan
  • Hazardous Waste Operations and Emergency Response (HAZWOPER)
    • Site Safety and Health Plan (SSHP)
    • Comprehensive Work Plan
    • Emergency Response Plan
  • Personal Protective and Safety Equipment
    • Hearing Conservation Program (HCP)
    • Respiratory Protection Program (RPP)
  • Fire Prevention and Protection
    • Fire Prevention Plan
    • Wildland Fire Management Plan
  • Accident Prevention Signs, Tags, Labels, Signals and Traffic Control
    • Traffic Control Plan
  • Welding, Cutting, and Brazing
    • Housekeeping Plan
  • Electrical
    • Electrical Safety Plan (ESP)
    • Assured Equipment Grounding Conductor Program (AEGCP)
  • Control of Hazardous Energy
    • Site-Specific Energy Control Plan (SPECP)
    • Hazard Isolation Procedures (HIPs)
  • Work Platforms and Scaffolding
    • Scaffold Work Plan – Tube & Coupler
    • Scaffold Work Plan – Supported Scaffolds Height to Base ratio of more than 4:1
    • Scaffold Work Plan – Suspended Scaffolds
    • Scaffold Work Plan – Scaffolds Requiring Tenting due to Weather Conditions
  • Fall Protection
    • Fall Protection Program (USACE Only)
    • Fall Protection & Prevention Plan
    • Rescue Plan
  • Rope Access
    • Rope Access Work Plan
  • Excavation and Trenching
    • Excavation and Trenching Plan
  • Concrete, Masonry, Roofing, and Wood Construction
    • Formwork and Shoring Plan
    • Masonry Bracing Plan
  • Steel Erection
    • Steel Erection Plan
    • Site Playout
  • Underground Construction (Tunnels), Shafts, and Caissons
    • Compressed Air Work Plan (CAWP)
    • Contingency Response Plan (CRP)
    • Emergency Rescue Plans and Equipment
    • Ventilation and Dust Control Plan
    • Fire Prevention and Protection Plan
  • Demolition Renovation and Re-Occupancy
    • Demolition Plan
  • Blasting
    • Explosives Site Safety Plan (ESSP)
    • Master Blasting Plan
    • Written Plan for Monitoring Vibrations and Air Blast
  • Diving Operations
    • Dive Operations
  • Floating Plant and Marine Activities
    • Severe Weather Plan for Marine Activities
    • Emergency Plan for Marine Activities
    • Float Plans
    • Tow Plans
  • Confined Space Entry
    • Confined Space Plan
  • Rigging Equipment
    • Critical Lift Plan (If Multiple Lift Rigging Assembly is Used)
  • Load Handling Equipment (LHE)
    • Standard Lift Plan (SLP)
    • SLP – Floating Plant
    • Critical Lift Plan
    • Pile Driving
  • Airfield Operations
    • Construction Safety and Phasing Plan (CSPP)
    • Safety Plan Compliance Document (SPCD)
  • Unmanned Aircraft Operations
    • Pre-Accident Plan
  • Tree Maintenance and Removal
    • Tree Maintenance and Removal Plan
  • Temporary Facilities
    • Construction Site Plan
    • Access/Haul Road Plan

It is confusing and stressful whenever the government rolls out new requirements for the construction industry; however, our team of industry experts have been reviewing these changes since March 2022. We are prepared to help you identify which site-specific plans are required for your project and ensure that they meet the requirements of the EM 385-1-1, 29 CFR 1926, and 29 CFR 1910.

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