Accident Prevention Plan (APP)

Need Help Writing Your Accident Prevention Plan (APP)?

One of the most essential parts of being successful on federal projects is implementing an effective Accident Prevention Plan (APP).  An acceptable APP is required by EM 385-1-1 before you can start your project on any Federal construction site.  The APP has to be job specific and address the safety exposures associated with your Scope of Work.  In addition, 2014 EM 385-1-1 also references your company safety program.  So you may want to update your company safety program. The APP is a written document that explains how you (the construction contractor) intends to prevent accidents from occurring on your construction project.

We can develop your site specific APP which includes any required revisions if it is rejected for any reason. You should keep in mind that depending on the type of project, subcontractors may be required to submit portions to your APP (i.e. Lead Abatment Plans, Asbestos Abatement Plans, etc.). We can review or make sure that your entire plan is in compliance with the EM 385-1-1 as well as other state & local guidelines.

We will participate in the pre-construction meetings if as your Company Safety Officer if the need arises.

There are 10 sections to the APP and each section must be answered completely. There is a very specific way in which the APP should be written.  Appendix A in EM 385-1-1 provides you with the outline and format for the APP.  It must be Scope of Work specific detailing the process that you will be using to prevent accidents/mishaps from occurring on your project.  The 10 Sections required to be in the APP are:

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Section 1   Signature Sheet
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Section 2   Background Information
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Section 3   Statement of Safety and Health Policy
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Section 4   Responsibilities and Lines of Authority  
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Section 5   Subcontractors and Suppliers
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Section 6   Training
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Section 7   Safety & Health Inspections
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Section 8   Accident Reporting
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Section 9   Plans (Programs, Procedures)
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Section 10 Risk Management Process

The New 2014 EM 385-1-1 Safety & Health Manual APP requirements have been greatly expanded and still have to be site specific based on your Scope of Work.  An APP can be extremely complicated.  Most APPs written by us are 60 to 150 pages in length. While preparing an APP for any project, it is also sometimes easy for some information to be overlooked.  

Example:  EM 385-1-1 states you (the contractor) have to follow the most stringent safety standard.  So if OSHA, ANSI, EPA, etc., has published a new safety standard since the most recent publication date of EM 385-1-,1 then you have to comply with the new safety standard (if it applies to your Scope of Work).  The new safety standard requirements also have to be included in your APP.

The challenge for contractors is to keep up with newly published safety standards.  You need to have a process that notifies you about new safety standard publications.  If you have no knowledge about new safety standards, your APP could be rejected because you left new, more stringent, safety requirements out of your APP.  We help keep contractors up to date with new regulations all the time.  Call us at 202-557-6869 if you need assistance.

An APP is a very technical document, you may experience some degree of difficulty, frustration or may not have the knowledge to decipher what information is needed. We have written hundreds of APPs over the past few years and continue to help contractors every day.

Appendix A, Section 9, Plans (Programs, Procedures) has fifty four (YES 54!) plans to be included in your APP!   Each plan is referenced to applicable EM 385-1-1 Sections. Again, each plan has to written specific for your project.  You cannot copy and paste from your company safety program.  We had one client who had submitted their three inch Corporate Safety Plan as their APP.  The contractor contacted their customer after several days to get an update about the APP review.  The customer informed the contractor the APP had been rejected.  “Nice book but it did not comply with EM 385-1-1.”  We tell people all the time to write the APP for their project and be site specific.  We still get portions copied from company safety plans.  Remember – THE APP HAS TO BE SITE SPECIFIC! 

We understand how overwhelming writing the APP can be.  We have a track record of 98% acceptance on the first submission of APP’s for our clients.  We help alleviate your stress having to prepare an acceptable APP.  Especially since the 2014 APP requirements are much more complicated than the 2008 version.  We know firsthand that it is discouraging to submit an APP only to have it rejected as “Not Acceptable”.  Several of our clients have tried multiple times to have their APP accepted after several failing submissions to their customer. On more than one occasion our clients had submitted the APP 12 and 13 times to their customer before coming to us for assistance.  We have a lot of expertise when developing a winning APP for you.

You have to also understand and be aware that each of your Federal customer requirements are going to be different.  In addition to the APP requirements there are site specific safety requirements you may not know about that are required to be in the APP.  This is another challenge for contractors.  There is no consistency between federal locations or inspector’s interpretations.  Think about it.  We have USACE, NAVFAC, all military branches, GSA, DOD and others requiring compliance with EM 385-1-1.  It is not a bad thing, you just need to be aware and ready.  It depends on who and what location you are working with.  You may have followed Appendix A to the letter but will still get comments from your customer requesting you to amend your submitted APP.  This is normal when you do not know the site specific safety requirements and site interpretations.

Example: Federal OSHA has an on-line data base of “Letters of Compliance” at www.osha.gov.  This resource communicates OSHA Standard Interpretations to everyone and lends some consistency to implementing OSHA standards.  There is not a resource or data collection tool like this for the interpretation of EM 385-1-1 requirements.  It depends on the site and inspector you are working with.  We have had two different inspectors on the same base interpret portions of EM 385 two different ways for the same project. For the most part EM 385 interpretations may be left up to the agency or inspector.  How do you manage this situation?  
 
In addition, but as part of the APP, you are required to prepare Activity Hazard Analysis (AHA).  You, the contractor, must prepare an AHA for each Definable Feature of Work (DFOW) in your Scope of Work.  The AHAs then need to be included in your APP.  If your project is sizable you may have several AHAs.  There are many resources that teach you how to fill out an AHA.  AHAs are basically the same as a Job Hazard Analysis (JHA) and Job Safety Analysis (JSA).

2014 EM 385-1-1, Appendix A now states you can use an AHA, JSA or JHA if you prefer.  You need to keep in mind that this document needs to be very detailed.  The AHA documents each Task, Hazards of each Task and Controls for each Hazard.  2014 EM 385-1-1 also requires the people doing the job to fill out the AHA.  If you need help call us at 202-557-6869.  We can train you how to fill it out or we can review the AHA with you.

You may not know this but your AHAs will most likely be used by your customer to conduct safety inspections of your project.  I have personally seen, on several occasions, contractors shut down for not following their AHA.  If some changes occur on a construction project (and it always happens) then note it on the AHA and submit it to your customer as soon as possible.  That way you will not be cited (or shut down) for not following your AHA.

Lastly, you need to include a resume in your APP for your designated Site Safety and Health Officer (SSHO).  The resume needs to show a minimum of five years “construction safety experience”.  We have seen a number of proposed SSHOs rejected because they did not have the requisite construction “safety” experience.  In addition, the SSHO is required to have at a minimum a current First Aid/CPR card and OSHA 30 hour card.  We have seen some contract requirements also require the EM 385-1-1 40 training for the SSHO. 

Recent News

Be cautious. We provide SSHOs on projects for construction contractors. This past year we have encountered three individuals who stated they had some type safety certification.  After effective background checks were completed we discovered the individuals did not have any certifications.  Safety is serious business. False safety credentials can be misleading and put your project and workers at risk.  Only deal with reputable sources when retaining safety professionals.

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Experience

We have prepared 100's of Accident Prevention Plans over the past 5 years for many diverse projects. Our experience on the job sites helps to know exactly what the customer is looking for in an APP.

Training

If you think you might need a better understanding of the EM 385-1-1 standards give us a call at 202-557-6869 or go to our training page to see the course schedule and more information about the training.

Cost

Our APP cost is based on the job itself. So, if you feel you need help give us a call at 202-557-6869 or send us an email at safety@thesafetyco.com. We'd be glad to help.