510 EM 385-1-1 Chapters 1-8

1-6. Activity Hazard Analysis Requirements.

Risk Management

Leaders at every level must integrate risk management into all work phases, ensuring decisions are based on sound judgment and principles.
Steps include identifying hazards, assessing risks, developing and implementing controls, and continuously evaluating their effectiveness.
Tools like the AHA assist in implementing risk management effectively.

Hazard Mitigation

Control measures should be implemented in a hierarchy:

Elimination/Substitution. Elimination/substitution involves removing the hazard from the work area. This may be accomplished by modifying structures, changing work processes, or substituting equipment so that persons are not exposed to the hazard(s).
Engineering Controls. Engineering controls isolate or separate the hazard(s) from the general work area and personnel exposure. A common engineering control is physical barriers that prevent contact/exposure to the hazard(s) (for example, guardrails, machine guards, containment).
Administrative Controls. Administrative controls involve work practices or procedures to govern/control the way persons work so that hazardous situations or conditions can be avoided. A common example of an administrative control is training, in that persons are trained in proper procedures so that they do not subject themselves or others to hazards.
PPE. PPE is equipment worn or used by persons performing work with hazards to minimize the effects of exposure to the hazard(s). PPE includes hard hats, safety glasses, safety shoes, hearing protection, respirators, etc. (See chapter 5) PPE should be a secondary measure after higher-level controls.

In some cases, multiple control measures may be necessary to control hazards adequately.

Risk Acceptance

Residual risk must be communicated and accepted by the proper authority before beginning any activity.
Activities requiring an AHA must not start until the AHA is reviewed, accepted, and signed by the proper authority.
USACE commands must establish a risk acceptance process, identifying the proper authority for acceptance.

AHA Minimum Requirements

AHAs must be prepared for all field, laboratory, industrial, and maintenance activities, reviewed by all employees involved, and kept onsite and accessible for 12 months.
AHAs must detail the activity, list potential hazards, required controls, and assign a RAC to each job step and overall activity.
Updates to AHAs are necessary if site conditions or operations change, and work must not resume until the revised AHA is reviewed and accepted.

Knowledge Check Choose the best answer for the question.

1-5. Which control measure in the hierarchy of controls involves physically removing the hazard?

PPE

Engineering controls

Elimination

Administrative controls

You forgot to answer the question!

EM 385-1-1 Paragraph 1.6.

1-6. Activity Hazard Analysis (AHA) Requirements.

The requirements of this paragraph apply to all AHAs required by this manual.  Specific AHA requirements are identified in paragraph 6 of each chapter in this manual.

a.  Risk management is a business process that requires planning to ensure risk is reduced to an acceptable level prior to performing work activities.  Risk management provides consistent and systematic identification and communication of risks, consequences, and potential actions to mitigate those risks.  Unidentified and unmanaged hazards and their associated risks impede successful missions, undermine readiness, decrease morale, and deplete resources.  A properly documented risk assessment serves as evidence that leadership decision-making was based on sound judgment and reasonable principles.  Leadership and management at every level must exercise risk management.  Risk management must be integrated into all phases of work to ensure risk decisions are made at the appropriate level, no unnecessary risk is taken, and the process is applied consciously.  Effective risk management requires the following steps (see para 1-10.b):

(1)  Step 1.  Identify all potential hazards associated with the task prior to work.
    (2)  Step 2. Assess identified hazards to determine probability and potential severity of occurrence (that is, risk).
    (3)  Step 3. Develop adequate controls to mitigate hazard and reduce probability and risk (see para 1-6.a).
    (4)  Step 4. Implement controls to ensure all workers know, understand, and implement required controls to reduce risk.
    (5)  Step 5. Continuously supervise and evaluate controls to ensure they are fully implemented, adequate, and effective at reducing risk. When needed, stop work to make corrections, modify, or add more controls, to ensure risk is managed.

Note.  The USACE uses many tools to aid with risk management implementation.  One of these tools is the AHA.

b.  Hazard Mitigation.  Analysis of hazards and implementation of control measures is a vital element to the risk management process and reducing the residual risk to an acceptable level.  Use the following hierarchy of controls, listed from most effective to decreasing effectiveness, to identify control measures to be implemented to eliminate or control hazards to an acceptable level:

Note.  There may be some situations or activities when more than one control measure or level of controls may need to be implemented to adequately control the hazard(s) to an acceptable level.

(1)  Elimination/Substitution.  Elimination/substitution involves removing the hazard from the work area.  This may be accomplished by modifying structures, changing work processes, or substituting equipment so that persons are not exposed to the hazard(s).
    (2)  Engineering Controls.  Engineering controls isolate or separate the hazard(s) from the general work area and personnel exposure.  A common engineering control is physical barriers that prevent contact/exposure to the hazard(s) (for example, guardrails, machine guards, containment).
    (3)  Administrative Controls.  Administrative controls involve work practices or procedures to govern/control the way persons work so that hazardous situations or conditions can be avoided.  A common example of an administrative control is training, in that persons are trained in proper procedures so that they do not subject themselves or others to hazards.
    (4)  PPE. PPE is equipment worn or used by persons performing work with hazards to minimize the effects of exposure to the hazard(s).  PPE includes hard hats, safety glasses, safety shoes, hearing protection, respirators, etc.  (See chapter 5)

Note. PPE should not be used as the only protection against a hazard.  It should only be used after attempt has been made to implement higher level controls, or as a subsequent control to provide an additional layer of protection.

c.  Risk Acceptance.  Acceptance of risk is a serious matter; therefore, the appropriate level of leadership must accept the overall residual risk associated with a task before its commencement.  Residual risk must be communicated and accepted by the proper authority before beginning the activity.

Note.  The proper authority may be different in each scenario and is based on the scope of work, hazards, and associated risk.

(1)  Activities that require an AHA must not begin until the AHA with the identified RAC has been reviewed, accepted, and signed by the proper approval authority.
    (2)  Each USACE Command must establish a process for risk acceptance for USACE activities identifying the proper acceptance authority or implement table for Risk Acceptance Matrix (see table 1-1).

Note.  USACE does not accept contractor risk.

d.  AHA Minimum Requirements.

(1)  AHAs must be prepared and documented for all field, laboratory, industrial, and maintenance activities performed.  Before beginning each work activity, task, or DFOW, an initial AHA must be prepared to ensure minimum safety requirements are adequately addressed.  In developing the AHA for a particular activity, the writer(s) (that is, CPs) should draw upon the expertise (for example, knowledge, skills, and experience) of the employees, supervisors, and SOH personnel.  Additional AHA requirements may be found in other applicable paragraphs of this manual.  See paragraph 6 of each chapter of this manual.

Note.  Job Safety Analyses (JSAs), Job Hazard Analyses (JHAs), or similar risk management assessment tools are considered equivalent to, and acceptable substitutes for, AHAs as long as the data collected is the same as that required by the AHA.

(2)  AHAs must be provided to and reviewed by all involved employees prior to starting the task. Each employee must document their review with a signature on the AHA or an additional signature sheet.  Provide copies of signed AHAs to the supervisor or local SOHO upon request.
    (3)  AHAs must be readily available onsite (for example, office trailer) and accessible onsite by all employees for a period of 12 months.  Workers/crews must have in their possession the current AHA that reflects current site conditions, personnel, equipment, control measures, etc. while the work is being performed.
    (4)  AHAs must include the following:
        (a)  Identify the activity/task/DFOW name, activity location, date of AHA development, name, and title of AHA preparer, and name and title of AHA acceptance authority.
        (b)  Define the steps to be performed for the activity/task/DFOW and the work sequences (for example, site conditions, materials, personnel) needed.  Job steps should be detailed so that the reader clearly understands how that job will be accomplished (for example, how the part will be installed or removed, anticipated voltages, quantities of chemicals utilized, equipment utilized to accomplish the task, heights being accessed or trenched).
        (c)  List all potential hazards associated with each specific job step.
        (d)  List all controls required to mitigate hazards according to paragraph 1-6.a.  If one layer of control cannot fully eliminate or reduce hazards to an acceptable level, put additional controls be in place to reduce risk to an acceptable level (that is, low or medium where possible).
        (e)  Assign a RAC to each job step, to identify the residual risk that remains after controls have been applied.
        (f)  Assign an overall RAC to the AHA.  The overall RAC must not be lower than the highest job step RAC on the AHA.
        (g)  Identify the equipment needed, training requirements needed of involved personnel, and any inspection requirements necessary for the activity/task/DFOW. Supervisor will designate, in writing (for example, certification, company letter) any required CP(s) and QP(s) by name for a particular activity (for example, excavation, confined space, scaffolding, fall protection, lead removal, asbestos abatement, other activities as specified by OSHA and this manual), and provide proof of competency/qualification.  (See para 1-10.c)
        (h)  Risk acceptance according to paragraph 1-6.b.  Activities that require an AHA must not begin until the AHA with RAC has been reviewed and accepted by the proper acceptance authority.

(5)  Updates to the AHA.  The AHA must be modified as necessary to address changing site conditions, operations, or change of CP(s) or QP(s).

(a)  If the initial RAC increases due to a change made to the AHA, resubmit the AHA for acceptance prior to the start of work.
        (b)  Changes or updates to an AHA that do not increase the RAC are not required to be resubmitted for acceptance.
        (c)  If the AHA needs to be revised, work should not resume until revision is complete and provided to and reviewed by all involved employees prior to starting the task.
        (d)  If the work has been stopped due to safety non-compliance with this manual, site-specific SOH Plan, AHA, etc. and the AHA needs to be revised, work should not resume until revision is complete and accepted and employees have re-reviewed.

Note.  For a non-mandatory formatted outline of an AHA see ENG Form 6206 (Activity Hazard Analysis) (see para 1-10.b).

510 EM 385-1-1 Chapters 1 - 8