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What’s the Difference: EM 385 vs. OSHA Requirements

Janet Cornett June 21, 2018 0
What’s the Difference: EM 385 vs. OSHA Requirements

If you work with the military or for the Department of Defense (DoD), you have to adhere to EM-385 rather than OSHA safety requirements. While many of the rules of military grade safety requirements are similar to OSHA, there are some small differences. In other words, if you have to adhere to EM-385 rules, you will be working with similar, but different rules.

EM-385 is the Safety and Health Requirements Manual that is published and updated by the US Corps of Engineers (USACE). It is mainly meant for DoD projects and violation of the terms of the manual can lead to a cancelled contract. In other words, if you want to work on any military contract, you have to become familiar with this manual and not OSHA per se.

At first glance, EM385 regulations look very similar to OSHA 29CFR 1926 regulations that are meant for those who work in construction. For example, both require scaffolds to be level and planked, flexible cords to be approved for service and all machinery parts to be guarded.

However, the devil is in the details which you should be familiar with if you want to land a military contract. A contracting officer has the authority to stop operations in case of noncompliance and you may also face a $2,000 a day penalty.

Here are some differences you should be aware between these standards:

Detailed Accident Prevention Plan (APP)

Unlike OSHA’s basic Incident and Injury Prevention Plan (IIPP), an EM385 based project needs a project specific Accident Prevention Plan (APP) in place. This has to be produced on demand and you may lose a contract if the officer in charge finds the regulations to be inadequate.

The military looks for in-depth details that address all of the risks involved in each aspect of a project. As such the APP has to go into detail about all of the potential hazards that are involved. To ensure an accurate analysis of the dangers involved, each phase of the project has to have a separate APP to determine control measures and safety management issues.

Stringent technical provisions

EM385 places a lot more importance on employee and job site training than OSHA since it believes these two elements are crucial when it comes to preventing injuries. This is understandable since military based contracts are usually more complex and heavy compared to general industry work. Employees who are aware of potential hazards in a military based job will be more careful on the job.

This includes hazards that are not obvious at first glance. For instance, most workers who are trained in accordance with OSHA regulations can recognize a worn power cord by its appearance. However, EM385 workers know this and realize the importance of conducting a ring test before installing a new grinding wheel and the importance of evaluating a confined work space for hazards.

Comprehensive employee training

OSHA and EM385 regulations are quite different when it comes to employee training. OSHA has broader training requirements and requires that each worker is trained in the avoidance and recognition of unsafe work conditions. This includes the regulations that are suitable for different work environments that can control or reduce hazards.

OSHA and EM385 regulations are quite different when it comes to employee training. Click To Tweet

EM385 training requirements are more rigorous in comparison. For instance, in a required Accident Prevention Plan (APP) the contract holder has to present a list of subjects that are discussed with workers during safety training. This is more than sufficient to ensure DoD contractors maintain a safe work environment for every worker irrespective of the tasks they are responsible for.

Besides initial safety indoctrination, EM385 also insists on ongoing training throughout a DoD project. Employers have to conduct regular safety training and meetings to review past activities, determine safe work practices for potential hazards, determine appropriate safety/health training requirements, and plan for operational changes. These meetings have to be held at least once each month for all supervisors that are working on the project and at least once each week for workers.

40-hour EM 385-1-1 USACE Safety & Health

Learn all you need to know about EM385 regulations by signing up for the 40-hour EM 385-1-1 USACE Safety & Health course from 360training.com. Students who complete the course will be able to work with the US Army Corps of Engineers without violating stringent safety regulations. Sign up today.

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