REVISION OF ACCIDENT PREVENTION PLANS (APP) IN THE 2024 EM 385-1-1

The accident prevention plan (APP) required by EM 385-1-1 is not a vague, generic document.  It is a strict and concise document required to be approved before any commencement of work on a government construction project. It is one of the first documents a contractor must submit. The APP must be a detailed, site-specific written plan that describes the management processes that will be used to prevent accidents from occurring on a specific construction project.

The latest revision of the ENG FORM 6293, AUG 2023 Accident Prevention Plan significantly changes the formatting and the requirements of future submissions.

The newest version of the EM 385-1-1 effective March 15, 2024, eliminated the abbreviated Accident Prevention Plan previously allowed for Service, supply, and research and development contracting actions. The new APP must be presented regardless of the type of activity.

Understanding the changes will provide an advantage in mitigating plan rejections.

An accident prevention plan will consist of 13 parts to meet the revised EM 385-1-1 requirements. The required parts are as follows:

PART 1: SIGNATURES

PART 2: PROJECT INFORMATION

PART 3: PRIME CONTRACTOR INFORMATION

PART 4: SOH COMMITMENT AND POLICY

PART 5: TRAINING

PART 6: SOH INSPECTIONS

PART 7: ACCIDENT REPORTING AND INVESTIGATION

PART 8: SOH OVERSIGHT

PART 9: SEVERE WEATHER PLAN

PART 10: ACTIVITY HAZARD ANALYSIS (RISK MANAGEMENT)

PART 11: REQUIRED PROJECT SITE-SPECIFIC PLANS AND PROCEDURES

PART 12: PROJECT SITE COORDINATION

PART 13: REQUIRED APPENDICES

Part 11: Required Project Site-Specific Plans and Procedures of EM 385-1-1, which addresses site-specific plans, has been significantly revised and requires increased attention.

The new chapter structure of the revised EM 385-1-1 provides for a list of required plans in section 7 – Minimum Plan Requirements. The list in Part 11 details the minimum plans required to be addressed in the APP. The references to the appropriate paragraph in the EM 385-1-1 are detailed in the APP to assist the contractor.

Applicable and completed plans from the list in Part 11 will be attached to Appendix 5 and must be submitted int the order listed.  If a plan is applicable but not all information is available justification for the incompletion and an expected date of completion must be submitted.  Justification must also be made if any required plan is deemed not applicable for the specific project.

The plans required are as follows:

• Exposure Control Plan 3-7.a
• AED Program 3-7.b
• Construction Site Plan 4-7.a
• Access/Haul Road Plan 4-7.b
• Hearing Conservation Program 5-7.a
• Respiratory Protection Program 5-7.b
• Hazard Communication (HazCom) Program 6-7.a
• Process Safety Management (PSM) Program 6-7.b
• Lead Compliance Plan 6-7.c
• Asbestos Management Plan 6-7.d
• Ionizing Radiation Safety Plan 6-7.e
• Radiofrequency Plan 6-7.e
• Abrasive Blasting Plan 6-7.g
• Thermal Stress Management Plan 6-7.h
• Mold Remediation Plan 6-7.i
• Silica Compliance Plan 6-7.j
• Fatigue Management Plan 6-7.k
• Night Operations Lighting Plan 7-7
• Traffic Control Plan 8-7
• Fire Prevention Plan 9-7.a
• Wildland Fire Management Plan 9-7.b
• Housekeeping Plan 10-7
• Electrical Safety Plan 11-7
• Assured Equipment Grounding Conductor Program 11-7.b
• Energy Control Plan 12-7.a
• Hazard Isolation Procedures 12-7.b
• Demolition Plan 17-7
• Emergency Plan for Marine Activities 19-7.a
• Severe Weather Plan for Marine Activities 19-7.b
• Float Plans 19-7.c
• Tow Plans 19-7.d
• Fall Protection and Prevention Plan 21-7.a
• Rescue Plan 21-7.b
• Scaffold Work Plan 21-7.b
• Rope Access Work Plan 23-7
• Excavation and Trenching Plan 25-7
• Fire Prevention and Protection Plan 26-7 a & f
• Compressed Air Work Plan 26-7 a & b
• Contingency Response Plan 26-7 a & c
• Emergency Rescue Plans and Equipment 26-7 a & d
• Ventilation and Dust Control Plan 26-7 a & e
• Formwork and Shoring Plan 27-7.a
• Masonry Bracing Plan 27-7.b
• Steel Erection Plan 28-7.a
• Site Layout Plan 28-7.b
• Explosive Site Safety Plan 29-7.a
• Master Blasting Plan 29-7.b
• Vibrations Monitoring Plan 29-7.c
• Dive Operations Plan 30-7.a & d
• Emergency Management Plan 30-7.a & e
• Safe Practices Manual 30-7.b
• Snorkeling Plan 30-7.f
• Tree Maintenance and Removal Plan 31-7
• Construction Safety and Phasing Plan 32-7.a
• Safety Plan Compliance Document 32-7.b
• Aviation Pre-Accident Plan 33-7
• Standard Lift Plan 34-7.b
• Confined Space Plan 34-7.b & c
• Standard Lift Plan – Floating Plan 34-7.c
• Critical Lift Plan 34-7.d
• Pile Driving 34-7.e
• Housekeeping Plan 35-7.a
• Extermination Plan 35-7.b
• Site Safety and Health Plan 36-7.a
• Comprehensive Work Plan 36-7.b
• Emergency Response Plan 36-7.c

There may also be other required site-specific plans or procedures required to be attached to Appendix 6 of the APP. These may include Medical & First Aid, Welding, Cutting, & Brazing, Work Platforms & Scaffolding, Excavation and Trenching, Temporary Facilities, etc.

The APP should be a fluid document. The plan should be revised as safety standards or goals change. The elements of this plan can aid the overall safety of the Department of Defense operation and prevent accidents.