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USACE Revises Safety & Health Manual

Ellen B. Stewart, CSP is program manager for the U.S. Army Corps of Engineers’ (USACE) newly revised Safety and Health Requirements Manual, EM 385-1-1. In this interview, Stewart discusses the manual’s revision process and explains how USACE employees have responded to the manual since it took effect in January 2009.

Please provide a brief description of your professional background and of your positions as senior safety engineer and program manager for USACE’s newly revised Safety and Health Requirements Manual, EM 385-1-1.

I graduated from Auburn University as an industrial engineer. Auburn’s engineering curriculum includes classes in occupational safety and health, and I was sold from that moment on. I went to work almost immediately for USACE as a safety engineer. I accepted my current position as senior safety engineer, systems and technical program manager at USACE headquarters safety office more than three years ago. It was exciting because I realized I would be able to address and correct issues and problems that I had experienced or had seen our teammates experience over the course of my career.

The integration of safety and health into contracts and designs as well as the development of various USACE programs, policies, regulations and guidance was a better way to solve problems, issues and concerns. Correcting on the front end made implementation and interpretation easier on the back end. The Safety and Health Requirements Manual is critically important to USACE’s success, and the fact that I am now program manager for that document is still hard to believe at times. I consider it a great honor to be in this position, to be able to effect change and improvement to such a large program that impacts the lives of so many people.
How does the revised manual differ from the 2003 version?

Many changes in industry standards and federal requirements have occurred since the 2003 version was published, and these changes needed to be reflected in our requirements document as well.

As we revised the manual from a technical aspect, it was obvious that the organization of the subject material could be improved upon as well. We consolidated subject material into single locations for ease of reference and clarified many requirements. We added new subject sections, such as Fall Protection, that reflected new requirements and also pulled the topic material into one location from many peripheral areas. All of these improvements were based on input received from our team members throughout USACE. I relied on the users’ points of view to guide us through the revision process.   

USACE received more than 4,000 comments during the manual’s revision. How did USACE’s safety office solicit and collect suggested revisions, and how did it determine which changes to make?

Comments were solicited via data calls to our field members, our contractors, industry and other governmental groups and to professional organizations as well. Each section of the manual was assigned a technical leader from within USACE, someone with knowledge, experience and interest in that particular topic material. As comments were received, they were consolidated and provided to the technical leader who reviewed and considered the suggested changes with a technical team. Once decisions were made and the sections were drafted, they were distributed for comment. Responses were provided back to those that submitted comments and included actions to take on each and associated rationale. All drafted sections were vetted internally and externally. 
As program manager for the revision, what did you consider to be the most challenging aspect of the revision process?

The most challenging aspect of the revision process was the sheer size of the manual, the large number of requested/suggested changes and ensuring that every change needed was incorporated into the document. It seemed as though everyone was interested in it, and that is so encouraging, but it made for a daunting task!

The manual references the following ANSI/ASSE standards and code:

A10.3 (Powder-Actuated Fastening Systems)
A10.4 (Personnel Hoists & Employee Elevators on Construction & Demolition Sites)
A10.5 (Safety Requirements for Material Hoists)
A10.6 (Safety & Health Program Requirements for Demolition Operations)
A10.7 (Safety Requirements for Transportation, Storage, Handling & Use of Commercial Explosives & Blasting Agents)
A10.8 (Safety Requirements for Scaffolding)
A10.22 (Safety Requirements for Rope-Guided & Non-Guided Workers’ Hoists)
A10.34 (Protection of the Public on or Adjacent to Construction Sites)
A10.38 (Basic Elements of an Employer’s Program to Provide a Safe & Healthful Work Environment)
Z117.1 (Safety Requirements for Confined Spaces)
Z244.1 (Control of Energy Sources (Lockout/Tagout) for Construction & Demolition Operations)
Z359 Fall Protection Code
Z490.1 (Criteria for Accepted Practices in SH&E Training)

How do these standards apply to USACE’s engineering services and projects? Why did USACE feel it necessary to include these particular standards in the revised manual?

USACE has always recognized the importance of the ANSI/ASSE/ASME standards to our designs, our projects, our construction and operations and maintenance management projects, and mostly, to the success of our safety and occupational health program. Appendix S lists all references for the manual and includes more than those listed above. Industry standards indicate a norm that is so critical. At times, we go above and beyond these standards, but they are always an excellent baseline developed by subject matter experts, which is important.

In light of several high-profile construction accidents in the U.S. throughout this past year, the manual emphasizes worker training on construction sites. According to the manual, what level of training are workers at construction sites expected to achieve?

Yes, many of the accidents seen recently throughout the nation have resulted in an identified lack of training or experience by those involved in these accidents. USACE sometimes sees the same lack of training, experience or knowledge on our construction worksites and sometimes among our employees as well.

One of the resulting goals of USACE, via the EM 385-1-1 manual, is a more trained, educated workforce—one in which the safety professional, office or officer only monitors the program’s implementation. Employees implement and own the program, which is critical to success. However, for that to be successful, employees must possess the knowledge and skills to not only do their job, but to do it safely. Workers on our project sites must have required training as applicable to the work they perform. Site safety and health officers (SSHOs) are required to have a minimum of OSHA 30-hour construction training or equivalent.      

How does USACE believe the revised manual will improve safety practices among its contract workers?

The revised manual requires preplanning prior to performing work activities. Preplanning is intended to assure that employees involved sit down, think and plan before the work is performed. They will identify the work to be performed, the hazards associated with the work, the employees involved and the applicable training, equipment and inspections needed to safely perform the activity. It was also intended that the manual be more logically arranged and that its requirements be clearly stated so workers can easily understand them. If the manual is not easily understood, application will not occur.

How have USACE employees responded to the manual since it took effect on January 12, 2009? What do they most appreciate about the manual’s revised format and content?

I have received many positive comments from our USACE employees. Most appreciated are the inclusion of many problem areas that had not been included in the past, clarity of requirements, consolidation of subject material into one location and the fact that input was solicited and used from field members. Least appreciated is the thickness/size of the document itself, but what are you going to do? Like many new publications, there are errors in some places, which we will correct, but overall, it has been received most positively.

One goal of the revised safety manual is to increase efficiency and production. Has USACE noticed any improvements at this point?

I think so. As our workload is increasing due to stimulus monies, base realignment and closure and increased military programs, we are working with contractors who are new to USACE. The manual, while intimidating in size, has made allowances for smaller contract work and for less hazardous work. The manual will also be translated into other languages, such as Spanish, Korean, Arabic and Japanese.

I have plans to provide more tools for our contractor personnel so that it is easier for them to understand the manual requirements and how they can provide what is needed. These tools include templates for accident prevention plans and activity hazard analyses, national inspection forms and checklists (rather than each district having their own), training and testing on manual and inspection checklists for construction (to include marine construction and dredging) equipment.

These ideas have added to consistency of expectations, efficiency of the contracting process and knowledge and skills of the workforce. The manual, translated versions as well as official interpretations given, changes, errata and other information can be found at http://www.usace.army.mil/CESO/Pages/Home.aspx.    

Has USACE begun to plan the next revision of the manual? If so, what changes will be included?

The revision process started as soon as this version was distributed. I collect comments, changes, errors and problems noted with the manual, and to date, they are fairly editorial in nature. I continually monitor federal and industry requirements to assess the areas in which changes must be made.

For example, changes were made to USACE’s crane/hoist operation requirement to include operator qualifications. Once OSHA publishes its much debated crane and derrick requirements, this will be an area that will likely change for us as well. Changes and errata to the manual will be posted on our website as they are made. Once enough changes and errata are collected, the next version will be published. Another opportunity for continual improvement and success!

Ellen B. Stewart
Ellen B. Stewart, CSP is the senior safety engineer and program manager for systems safety and engineering in USACE’s safety and occupational health office. In this position, she is responsible for developing policy, regulations and technical guidance for all safety aspects of USACE operations, construction and design. She is the proponent for USACE’s Safety and Health Requirements Manual, EM 385-1-1 and responds to all requests for waivers, clarifications, interpretations and changes. She is also responsible for all Unified Facilities Guide Specifications related to safety and health, facility and systems safety and for integration of safety and health into USACE’s Project Management Business Process.

She is the career manager for safety engineers, and she works closely with USACE headquarters and field construction management, safety and operating personnel to evaluate hazards and to develop work methods that strive for the highest possible degree of safety while still getting the job done. She has successfully responded to hurricane recovery missions, most recently receiving a Commander’s Award for her efforts as safety and health manager for the Alabama side of the Hurricane Katrina mission.

She has been a member of the headquarters safety office since early 2006 but has dedicated her life and 28 years of service to the safety and health of Corps team members, contractors and public visitors.

Stewart holds a B.S. in industrial engineering from Auburn University and is pursuing a master’s degree in safety and occupational health.