Step-by-Step Guide to Writing a USACE/NAVFAC Safety Plan

(How to Ensure Your Plan Meets EM 385-1-1 Standards & Avoid Costly Rejections)

If you’re a contractor bidding on a U.S. Army Corps of Engineers (USACE) or Naval Facilities Engineering Systems Command (NAVFAC) project, you already know that getting your safety plan approved is a non-negotiable requirement.

Your Accident Prevention Plan (APP) and Activity Hazard Analyses (AHA) must comply with EM 385-1-1, or your project will be delayed or rejected outright. Worse, an incomplete or non-compliant plan can put your contract at risk, leading to fines, project stalls, and even disqualification from future government work.

As a plan writer with 30+ years of experience in federal government approvals, I’ve seen too many contractors struggle with rejections, delays, and compliance issues—simply because they didn’t follow the right steps.

So, whether you’re writing your first USACE/NAVFAC safety plan or trying to fix a rejected one, this guide will walk you through exactly what you need to do to create a fully compliant, USACE-approved plan—guaranteed.

📌 Why Is a USACE/NAVFAC Safety Plan So Important?

If you’re working on a U.S. Army Corps of Engineers (USACE) or Naval Facilities Engineering Systems Command (NAVFAC) project, one of the first hurdles you’ll face is getting your safety plan approved. These agencies do not take safety lightly—and for good reason.

The EM 385-1-1 Safety and Health Requirements Manual is a strict set of guidelines designed to prevent workplace accidents, ensure worker safety, and maintain compliance with federal regulations. A well-written, fully compliant safety plan doesn’t just protect your workers—it protects your contract, your company’s reputation, and your ability to secure future government projects.

Let’s break down exactly why having a USACE/NAVFAC-approved safety plan is critical for your business.

✅ Prevents Accidents, Injuries, and Fatalities

Federal construction projects are high-risk environments. Whether you’re working on a military base, a bridge, an airfield, or a large-scale infrastructure project, safety hazards are everywhere.

The EM 385-1-1 manual exists to prevent:

• Falls from heights (the leading cause of fatalities in construction)

• Electrocution and electrical hazards

• Trenching and excavation collapses

• Struck-by and caught-in/between incidents

• Hazardous material exposure

Without a properly structured and implemented safety plan, the chances of a serious accident, injury, or fatality increase significantly. These aren’t just theoretical risks—OSHA statistics show that 1 in 5 worker deaths occurs in construction, and many of these could have been prevented with proper safety measures.

✔ A USACE/NAVFAC-approved safety plan ensures:

• Hazard identification and control measures are clearly outlined.

• All personnel are trained on safety protocols before work begins.

• Regular inspections and job site safety audits are performed.

✅ Meets Federal and OSHA Safety Requirements

OSHA regulations set minimum safety requirements for private sector construction, but federal construction projects under USACE/NAVFAC have even stricter standards.

• OSHA 29 CFR 1926 applies to general construction safety.

• EM 385-1-1 adds additional safety protocols, including:

• More detailed hazard analysis (AHA - Activity Hazard Analysis)

• Specific training and certification requirements for key personnel

• Mandatory fall protection at lower heights than OSHA requires

• Stricter requirements for accident reporting and record-keeping

✔ A properly written safety plan ensures:

• Your project meets EM 385-1-1’s heightened safety requirements.

• You avoid OSHA fines and citations for non-compliance.

• Your workers, supervisors, and SSHOs (Site Safety & Health Officers) are all aligned with federal expectations.

✅ Minimizes Liability for Contractors and Subcontractors

A single safety incident on a federal project can result in massive financial and legal consequences.

• If a worker is injured, you may be held liable for medical costs, lost wages, and penalties.

• If your safety plan is inadequate, you could be removed from the project entirely.

• If subcontractors are non-compliant, the prime contractor (you) is responsible for their violations.

💡 The best way to protect yourself?

✔ A detailed, site-specific safety plan that clearly outlines:

• Roles & responsibilities of every worker and supervisor.

• Emergency response protocols for incidents and injuries.

• Subcontractor safety compliance expectations and enforcement.

✅ Ensures Compliance with Federal Project Regulations

Unlike private construction, federal government contracts are heavily regulated. If you fail to meet compliance standards, you won’t just face safety risks—you could lose your ability to bid on future contracts.

Every USACE/NAVFAC project requires:

• A complete and approved Accident Prevention Plan (APP).

• Activity Hazard Analyses (AHAs) for each work phase.

• Proper safety training and documentation for key personnel.

• Strict accident and near-miss reporting procedures.

🚨 Common Compliance Pitfalls That Lead to Plan Rejections:

✔ A well-prepared safety plan ensures that:

• Your project moves forward without delays.

• Your company stays in good standing with federal agencies.

• You maintain a strong reputation as a reliable contractor.

🔴 What Happens If Your Safety Plan is Rejected?

If your USACE/NAVFAC safety plan is rejected, you are immediately at risk for delays, financial losses, and contract penalties.

🚨 Consequences of a Rejected Safety Plan:

🚨 Most Common Reasons for Plan Rejections:

✔ 💡 The Solution? Follow these step-by-step instructions to create a fully compliant, rejection-proof safety plan.

📝 Step 1: Understand the USACE/NAVFAC Safety Plan Requirements

Before you start writing, you need to know exactly what’s required.

EM 385-1-1, Section 1 outlines the mandatory components of an Accident Prevention Plan (APP), which serves as the core safety document for any federal construction project.

Here’s what must be included:

📌 Pro Tip: Never use a one-size-fits-all template—USACE and NAVFAC reviewers expect fully customized plans tailored to your specific project site, work activities, and hazards.

📝 Step 2: Define Key Personnel & Responsibilities

USACE/NAVFAC contracts require clearly defined safety roles. Your plan must detail who is responsible for what and provide proof of qualifications.

📌 Key Safety Personnel That Must Be Listed:

🚨 Common Mistake: Failing to include proof of SSHO training and experience—this is a guaranteed rejection point!

✔ How to Fix It:

• List full names, roles, and qualifications of all personnel.

• Attach certificates and training records for key safety staff.

• Ensure your SSHO meets EM 385-1-1 requirements.

📝 Step 3: Develop a Comprehensive Activity Hazard Analysis (AHA)

Your AHA must be detailed, site-specific, and meet USACE formatting requirements.

📌 Each AHA Must Include:

🚨 Common Mistake: Listing generic hazards (e.g., “fall risks” instead of specifying “scaffolding fall hazards over 6 feet with unprotected edges”).

✔ How to Fix It:

• Provide phase-specific AHAs for every major construction task.

• Ensure each AHA is formatted according to EM 385-1-1 standards.

• Include hazard-specific PPE and mitigation strategies.

📝 Step 4: Emergency Response & Medical Planning

USACE and NAVFAC require a detailed emergency response plan, including:

📌 Mandatory Emergency Plan Components:

🚨 Common Mistake: Failing to include site-specific evacuation maps or emergency response team assignments.

✔ How to Fix It:

• Include clear, actionable steps for all emergency scenarios.

• Attach a map of emergency exits, muster points, and fire extinguisher locations.

📝 Step 5: Submit & Expedite Your Approval

(How to Ensure a Smooth Submission & Avoid Costly Delays)

Even if your USACE/NAVFAC Accident Prevention Plan (APP) is technically perfect, submission errors can cause unnecessary delays. Contractors often assume that if the content meets EM 385-1-1 requirements, approval is automatic—but that’s not always the case.

Your plan still needs to pass through multiple layers of review, and if it’s not formatted correctly, missing attachments, or submitted at the wrong time, your approval can be delayed for weeks—or even rejected outright.

To ensure fast, hassle-free approval, follow these critical submission best practices.

🚀 Why Submission Errors Cause Delays (Even for Good Plans)

Even when a safety plan meets all EM 385-1-1 requirements, submission mistakes can still result in:

🚨 Long wait times – Reviewers process hundreds of plans and flagging a missing attachment means your plan goes to the back of the queue.

🚨 Rejected plans for technical reasons – Formatting errors, missing documentation, or incorrect submission procedures will get your plan sent back for revisions.

🚨 Project work stoppages – Without an approved safety plan, no work can start, causing costly delays in mobilization, labor, and material deliveries.

📌 Solution? Follow these expert submission tips to ensure your plan is approved as quickly as possible.

✔ Follow These Steps for Fastest Approval

✅ 1. Use the Correct Submission Format Required by Your Contracting Officer

USACE and NAVFAC Contracting Officers (COs) have specific requirements for how APPs and AHAs should be formatted and submitted. Failing to follow these guidelines can result in automatic rejection or unnecessary delays.

📌 Common Submission Format Mistakes That Cause Delays:

✔ How to Fix It:

• 📞 Contact your Contracting Officer (CO) before submission and confirm:

💡 Pro Tip: If your contract specifies a Quality Control Manager (QCM) or Safety Officer, have them review the plan before submission to catch any formatting issues.

✅ 2. Double-Check for Missing Attachments

Many USACE/NAVFAC safety plans are rejected not because of content errors, but simply because required attachments are missing.

📌 Mandatory Attachments That Must Be Included:

🚨 Most Common Rejection Reason? Missing AHAs!

• Every phase of work requires a separate, detailed AHA.

• If you submit an APP without the corresponding AHAs, it will be automatically rejected.

• ✔ How to Fix It:

• •Cross-check your submission against the contract’s safety requirements checklist.

• If possible, combine all attachments into a single submission package, properly labeled for easy review.

• Use a pre-submission checklist to verify that all required documents are included.

💡 Pro Tip: If your contract allows it, submit your plan with a cover letter listing all included attachments so the reviewer can quickly confirm everything is present.

✅ 3. Submit Your Plan Early—Last-Minute Reviews Can Take Weeks

📌 Why Early Submission is Crucial:

• USACE and NAVFAC Contracting Officers review dozens of plans weekly—yours will not be a priority if it arrives at the last minute.

• Rush submissions increase the risk of errors—missing signatures, incorrect formatting, or incomplete sections.

• If revisions are needed, last-minute submissions don’t allow enough time to make corrections before your project’s start date.

🚨 How Long Does USACE/NAVFAC Take to Review Plans?

✔ How to Fix It:

• Submit your APP at least 30 days before project mobilization.

• Follow up with the Contracting Officer after submission to confirm receipt and estimated review time.

• If you’re on a tight deadline, request an expedited review—but only if your plan is 100% complete.

💡 Pro Tip: Always assume your first submission will need revisions—so build in extra time for corrections.

🚀 Need Your Safety Plan Approved—FAST? We Can Help.

If you’re struggling with a rejected plan or need a safety plan done right the first time, we’ve got you covered.

🔹 We specialize in writing and fixing USACE/NAVFAC safety plans that meet 100% compliance with EM 385-1-1.

🔹 Fast turnaround—most plans fixed within 24-48 hours.

🔹 Approval guaranteed—or we fix it free.

📞 Call us now at 206-734-4600 for a No-Obligation Quote

📩 Or request a free no obligation quote here: https://planthejob.com/quote-request

Don’t let safety plan delays cost you your contract—let’s get it approved today! 🚀