EM 385 1 1 Accident Prevention Plan Requirements for Federal Contractors

A federal construction project can have an experienced team, a clear scope, and a strong schedule, yet still encounter delays before field work begins. One common reason is an Accident Prevention Plan that is incomplete, too general, or disconnected from the actual work.

The Accident Prevention Plan, commonly called the APP, is not simply a company safety manual placed inside a project binder. It is a site specific document that explains how the contractor will manage the personnel, equipment, materials, hazards, and work activities associated with a particular contract.

For projects governed by EM 385 1 1, the APP is also a formal safety submittal. It must pass through the required review and acceptance process before contract work begins.

Understanding the requirements early gives the project team time to prepare an accurate plan, address missing information, and resolve concerns before they affect mobilization.

An EM 385 1 1 Accident Prevention Plan is a written, site specific safety and occupational health plan. It documents project hazards, company policies, control measures, responsibilities, and work practices. The plan must be developed by a Competent Person, approved by the prime contractor and corporate safety official, then accepted by the Contracting Officer or Contracting Officer’s Representative before contract work begins.

What Is an Accident Prevention Plan Under EM 385 1 1?

The APP provides the main safety framework for the project.

It should explain what work will be performed, how that work will be carried out, what hazards can reasonably be expected, and which controls will be used to protect employees. It should also identify the people responsible for implementing, monitoring, and enforcing those controls.

The current published edition of EM 385 1 1 is dated 15 March 2024. The current ENG Form 6293 Accident Prevention Plan Worksheet is dated 31 August 2024.

This matters because many contractors still have APP templates built around earlier versions of the manual. An older template may contain useful information, but it should not be assumed to satisfy the controlling contract or the current worksheet.

A contractor should begin with the contract documents, the incorporated edition of EM 385 1 1, applicable safety specifications, and ENG Form 6293. The plan should then be developed around the actual project rather than assembled from language copied from an unrelated job.

Confirm Which Edition Applies to the Contract

Before drafting or updating an APP, confirm which edition of EM 385 1 1 has been incorporated into the contract.

For covered construction contract work, the manual states that contractors must follow the version in effect on the date of solicitation, including applicable interim changes. Existing contracts may continue to apply the previous edition until contract completion.

The newest published manual is therefore not automatically the controlling document for every active project.

Review the solicitation, awarded contract, safety specification, amendments, and agency instructions before preparing the APP. Project specific provisions may establish additional submittal requirements, review periods, staffing qualifications, or documentation standards.

When a general template conflicts with the contract, the contract requirements must guide the plan.

Who Prepares, Approves, and Accepts the APP?

Several people take part in the APP process. Their responsibilities are connected, but they are not interchangeable.

The Competent Person develops the plan

EM 385 1 1 requires the APP to be developed by a Competent Person.

A Competent Person must be able to identify existing and predictable hazards and have the authority to take prompt corrective action. Naming an employee as the preparer is not enough. That person should understand the project scope, planned work methods, equipment, materials, and hazards being addressed.

The APP will be more useful when the preparer works directly with project management, field supervision, quality control personnel, subcontractors, and the safety team.

The prime contractor reviews and approves it

The prime contractor is responsible for confirming that the APP reflects the contract and the work being performed.

This review should involve more than checking whether each section contains text. The contractor should verify that the named personnel are assigned to the project, the described equipment is accurate, required supporting plans are included, and the controls can be implemented under actual field conditions.

The corporate safety official reviews and approves it

The corporate safety official provides another level of contractor review.

This person should confirm that the plan is consistent with the company safety program, contractual obligations, and applicable requirements. The corporate review is also an opportunity to identify missing information before the plan reaches the government.

The KO or COR reviews and accepts it

After contractor approval, the APP is submitted to the Contracting Officer, known as the KO, or the Contracting Officer’s Representative, known as the COR.

The government reviews the document for conformance with the safety and health requirements of the contract. When the APP does not adequately address those requirements, the submittal may be returned for correction.

Government acceptance does not transfer responsibility away from the contractor. The contractor remains responsible for providing a safe and healthful workplace and complying with the contract.

The SSHO keeps the plan connected to field conditions

Once the project begins, the Site Safety and Health Officer has an important role in monitoring the plan, evaluating changing conditions, and helping the project team keep the APP current.

For a closer look at this responsibility, read what a Site Safety and Health Officer does on a federal jobsite.

The current manual requires the SSHO to conduct ongoing evaluations and updates throughout the life of the project. Revisions must be reviewed and approved by the contractor and submitted to the KO or COR for acceptance.

What Should an EM 385 1 1 Accident Prevention Plan Include?

ENG Form 6293 provides the required structure, but completing the form should not become a box checking exercise. The information must still be complete, accurate, and specific to the contract.

Project and contract information

The plan should identify the contract, project location, prime contractor, anticipated schedule, scope of work, and major phases of construction.

The project description should be detailed enough for a reviewer to understand what the contractor will actually perform. Broad phrases such as general construction work or miscellaneous repairs do not provide enough context for meaningful hazard planning.

Safety responsibilities and lines of authority

The APP should identify the people responsible for safety management, project supervision, quality control, emergency coordination, inspections, and hazard control.

It should explain who has the authority to stop work, order corrective action, approve changes, coordinate subcontractor safety, and communicate with government representatives.

The names and responsibilities in the plan must match the people assigned to the project. Names copied from an earlier contract create confusion and weaken accountability.

Work processes, equipment, and materials

The APP must describe the specific work, work processes, equipment, materials, hazards, and control measures associated with the contract.

This is where general templates often fall short.

An APP for roofing work should address the roof system, access method, material handling process, fall exposure, changing weather conditions, and rescue arrangements.

A plan involving excavation should reflect anticipated depths, soil evaluation, underground utilities, protective systems, access, spoil placement, water accumulation, and equipment movement.

The document should clearly belong to the project being reviewed.

Hazard identification and controls

The plan should describe the major hazards expected throughout the project and the systems that will be used to control them.

Controls should be specific enough to guide field decisions. Statements such as employees will follow OSHA requirements or workers will use proper personal protective equipment do not explain what will happen at the jobsite.

A stronger plan identifies the hazard, the selected control, the responsible person, required training, inspection expectations, and conditions that would require work to stop.

Supporting safety plans

Plans and other safety related submittals required by the work must be included as part of the APP package for review and acceptance.

Depending on the scope, supporting documents may include:

1. An emergency plan
2. A fall protection plan
3. A confined space program
4. A hazardous energy control program
5. An excavation and trenching plan
6. A critical lift plan
7. A rigging plan
8. A respiratory protection program
9. A hot work or fire prevention program
10. Other plans required by the contract or the applicable chapter of the manual

Not every project requires every plan. The contractor should determine what applies to the known scope and explain how later information will be incorporated as the work develops.

EA & Associates provides federal construction safety support and project specific safety documentation for contractors managing these requirements.

Emergency planning

A project emergency plan should address the actual location, work environment, communication systems, and available response resources.

The current manual calls for written emergency planning that addresses evacuation procedures, routes, rally points, employee accountability, rescue and medical duties, emergency reporting, and responsible contacts. Onsite planning must also be coordinated with offsite emergency support.

A list of telephone numbers is not a complete emergency plan.

The contractor should confirm emergency access routes, communication coverage, nearby medical resources, site security procedures, response arrangements, and any conditions that could delay emergency services.

How to Use ENG Form 6293

ENG Form 6293 is identified as the mandatory Accident Prevention Plan Worksheet in the current manual.

The worksheet should guide the structure of the APP, but it does not replace careful planning.

Completing every field does not automatically produce an adequate plan. The information still needs to reflect the project, its personnel, its methods, and its hazards.

A practical drafting process begins with the scope of work and schedule. From there, the contractor can identify major phases, subcontractors, equipment, materials, and known hazards. Supporting plans and Activity Hazard Analyses can then be mapped to those phases.

This approach produces a document that follows the project rather than a document assembled from disconnected safety language.

Some information may not be available when the initial APP is submitted. The manual allows later project specific details to be added before the relevant preparatory phase or meeting, along with the appropriate AHAs. All known information must still be included before work begins.

The APP should clearly explain how unknown information and later revisions will be managed.

The Difference Between an APP and an AHA

The APP and Activity Hazard Analysis serve different purposes.

The APP establishes the overall safety management system for the project. It identifies responsibilities, general hazards, programs, procedures, and controls that apply across the contract.

The AHA focuses on a particular activity, task, or definable feature of work. It breaks the operation into logical steps, identifies the hazards associated with those steps, and documents the controls, training, equipment, and inspections needed to perform the work safely.

An initial AHA must be prepared before the relevant work activity, task, or definable feature of work begins. The manual also directs preparers to draw on the knowledge and experience of employees, supervisors, and safety personnel.

The APP does not replace the AHA, and the AHA does not replace the APP.

They should support one another. The APP provides the project framework. The AHA turns that framework into practical controls for the work taking place in the field.

For more detail, read Understanding Hazard Analysis Documentation for Construction Projects.

Common APP Problems That Lead to Revisions

APPs are often returned when the document does not clearly demonstrate how the contractor will satisfy the project requirements.

The scope is too general

The APP discusses construction safety broadly but does not describe the work, equipment, materials, project phases, or site conditions.

Information belongs to another project

Names, addresses, emergency contacts, subcontractors, and agency references were carried over from an earlier plan.

Required supporting plans are missing

The project includes fall exposure, excavation, confined space entry, lifting, hot work, or hazardous energy, but the related documents are absent or incomplete.

Controls do not match the planned work

The APP names equipment, protective systems, or procedures that are not available or appropriate for the project.

Safety authority is unclear

Personnel are listed, but the plan does not explain who can stop work, direct corrections, approve changes, or coordinate subcontractor safety.

Emergency planning is incomplete

The emergency section contains telephone numbers but does not address evacuation, accountability, rescue, communications, site access, or coordination with responders.

There is no process for updates

The APP is treated as a finished submittal even though personnel, equipment, subcontractors, work methods, and field conditions will change.

A careful contractor review before submission can identify most of these problems.

What Happens After the APP Is Accepted?

Acceptance is not the end of the APP process.

The accepted plan must remain available at the site and accessible to employees. The current manual requires the most recent APP to be posted on the safety and occupational health bulletin board, or for a notice to be posted identifying where the plan is located.

The plan must also remain aligned with the work.

When subcontractors change, equipment is introduced, work methods are revised, or new hazards appear, the APP should be evaluated. Necessary revisions must pass through contractor review and government acceptance.

The AHA process should follow the same practical approach. Crews must have access to the current AHA while the work is being performed, and the document should reflect actual site conditions, personnel, equipment, and controls.

When field conditions no longer match the accepted documentation, the answer is not to ignore the difference. The APP, supporting plans, or AHA should be reviewed and revised through the appropriate process.

Accident Prevention Plan Checklist Before Submission

Before sending the APP for government review, confirm the following:

1. The controlling contract documents and applicable edition of EM 385 1 1 have been verified.
2. The correct ENG Form 6293 has been used.
3. The project description reflects the actual scope of work.
4. The Competent Person, corporate safety official, SSHO, quality control personnel, and project leadership are correctly identified.
5. Work processes, equipment, materials, and expected hazards are described accurately.
6. Each major hazard is connected to a practical control method.
7. Required supporting plans are included or scheduled for submission before the related phase of work.
8. Emergency contacts, evacuation routes, rally points, communication methods, and response arrangements have been verified.
9. Known subcontractor, vendor, and equipment information has been included.
10. The APP explains how unknown details and changing conditions will be addressed.
11. Contractor review and approval are complete before submission to the KO or COR.
12. Enough review time has been allowed before the planned start of contract work.

The last point deserves attention. When work cannot begin without an accepted APP, an incomplete submission can become a schedule problem as well as a safety problem.

When Outside APP Support Makes Sense

Some contractors maintain experienced internal safety departments that routinely prepare federal project documentation. Others have strong construction teams but limited familiarity with EM 385 1 1, ENG Form 6293, or the government review process.

Outside support may be useful when the project has a tight mobilization schedule, complex hazards, several subcontractors, unfamiliar agency requirements, or a scope that requires multiple supporting plans.

Before engaging outside assistance, it helps to understand what a safety consultant does and whether your business needs one.

A qualified consultant can review the contract, organize the documentation, identify missing information, develop project specific language, and help align the APP with the AHAs and planned field execution.

EA & Associates provides APP development, AHA development, SSHO support, federal compliance planning, jobsite safety support, and project specific documentation for federal and military construction projects.

You can also learn more about EA & Associates and the field experience behind its safety consulting work. The company’s leadership profile includes federal construction experience, APP and AHA development, EM 385 1 1 training, construction management education, and related safety credentials.

Build the APP Around the Work

A useful Accident Prevention Plan should help the project team make better decisions before work begins.

It should tell project leadership who holds safety authority. It should tell the SSHO what must be monitored. It should tell supervisors which controls are expected. It should give employees clear direction when conditions change.

Most importantly, it should reflect the work that will actually happen.

A completed worksheet may satisfy the required format. A project specific plan informed by field conditions is what gives the APP practical value.

Need an Accident Prevention Plan developed or reviewed for an upcoming federal project? Contact EA & Associates to discuss the contract, scope, schedule, and required safety documentation.

Frequently Asked Questions

Can federal contract work begin before the APP is accepted?

For work covered by the APP requirements in EM 385 1 1, contract work cannot begin until the plan has been reviewed and accepted by the KO or COR. Other safety related plans and submittals may also require acceptance before the related work begins.

Is a standard APP template enough?

A template can provide structure, but the completed plan must be site specific and contract specific. It should identify the actual work, equipment, materials, hazards, controls, personnel, and supporting plans for the project.

Can the APP be updated after work starts?

Yes. The APP is expected to remain current as personnel, subcontractors, equipment, hazards, and site conditions develop. Revisions must be reviewed and approved by the contractor and submitted to the KO or COR for acceptance.

Does the APP replace Activity Hazard Analyses?

No. The APP establishes the overall safety framework for the project. AHAs address the steps, hazards, risk levels, and controls associated with individual activities, tasks, or definable features of work.

Who is responsible for keeping the APP current?

The SSHO must conduct ongoing evaluations and updates. The contractor remains responsible for approving revisions and submitting them to the KO or COR for acceptance. Project management also remains responsible for implementing and enforcing the accepted plan.