Developing a Successful Accident Prevention Plan (APP) in compliance with EM 385 1-1 Requirements
Now that you have landed a Federal Contract and are preparing for the project execution phase, an essential part of project planning is developing and submitting a thorough and effective Accident Prevention Plan in conjunction with Activity Hazard Analysis.
As identified under EM 385 1-1, Section 1, Program Management, the following shall be required prior to project initiation:
01.A.12 Accident Prevention Plans (APP) for Contract Work. Before initiation of work at the job site, an APP shall be reviewed and found acceptable by the GDA. > See Appendix A.
a. APPs shall be developed and submitted by the Contractor. The Contractor shall address each of the elements/sub-elements in the outline contained in Appendix A in the order that they are provided in the manual. If an item is not applicable because of the nature of the work to be performed, the Contractor shall state this exception and provide a justification.
As we have outlined previously in our GovGig articles, “the APP is not a vague document listing the general safety rules of the company, but rather a detailed, site-specific plan that describes the management processes that will be used to prevent accidents from occurring on your construction project.” This document is an integral part of the project planning process and should interface with your overall Safety & Health program.
Because this document is submitted prior to the start of work, there may be project-specific information not yet known. Because of this, the APP should be viewed as a living document and should be updated throughout the life of the project to reflect changes in the scope of work, key personnel, equipment, or conditions. Be prepared as such to provide an updated APP for each preparatory phase ensuring that it aligns with each of your developed AHAs.
Keep in mind that no defined area of work (DFOW) should be started until changes to the APP have been revised and submitted to the Government Designated Authority (GDA) for acceptance. Failure to follow this process may result in project downtime until this requirement can be met.
In addition to being site-specific, the APP should also address “any unusual or unique aspects of the job for which it is written.” As the APP is designed to eliminate or reduce the likelihood and severity of accidents through detailed pre-job planning, be as thorough as you are able as you navigate through each required element listed under Appendix A.
Once completed and accepted, a copy of the APP must be present and immediately available on the worksite.
Following the Mandatory APP Format
As clearly outlined in Appendix A, make sure that each element within the APP format is listed within the body of your APP. It is recommended that you give each section its own header to clearly identify each required section. Be prepared to provide detailed information relating but not limited to:
· Major phases of work
· Responsible lines of authority including appropriate Competent Persons
· (For Projects requiring safety oversight) Proof of competency including updated resume and training certificates
· Responsibilities for safety inspection processes and incident investigations
These are but a select few of the initial APP requirements that must be listed prior to providing specific plans, programs, and procedures associated with your specific scope.
As you go through the list of items under Appendix A and identify specific controls for each, ensure that each area is listed regardless of applicability. Section 1, Program Management provides further clarification:
01.A.12(a) The Contractor shall address each of the elements/sub-elements in the outline contained in Appendix A in the order that they are provided in the manual. If an item is not applicable because of the nature of the work to be performed, the Contractor shall state this exception and provide a justification.
Given the breadth of this document, you may feel overwhelmed completing this for the first time. The ultimate key to developing a successful APP that the GDA will accept the first time through the submittal process is ensuring that each of the elements has been adequately addressed. Time must be taken to ensure that project-specific risks associated with each element have been effectively assessed for risk mitigation measures. This process does not have to be burdensome, but it does need to be thorough. By taking the time to do it correctly the first time, it will minimize extra administrative work, limit project downtime, and most important of all, set your project up for success by establishing effective controls to protect your workers from harm.
Please reach out to us at GovGig if you need guidance working through the APP process.