As a roofing professional, you certainly are familiar with the Occupational Safety and Health Administration's (OSHA's) workplace regulations. However, there are other regulations, especially for government work, that require your compliance and are less well-known. For example, the U.S. Army Corps of Engineers' (USACE's) "EM 385-1-1 Safety and Health Requirements Manual" contains 34 topic sections that specify safety requirements for construction projects managed by USACE. Adherence to EM 385 is backed by law through prescribed regulations or binding contract language.
As another example, a roofing contractor may be obligated by Federal Acquisition Regulation 48 CFR §52.236-13, Accident Prevention, to conform to EM 385 when performing a roof system installation for the Department of Defense (DOD), or compliance may be required under specific contract provisions for other non-DOD projects. Failure to comply with EM 385 requirements can be costly in terms of project safety, time and money.
Accident prevention plan
EM 385 safety and health requirements often track closely with OSHA's construction regulations found in 29 CFR §1926. However, there are significant differences and additional requirements in some areas. Most important is the requirement in EM 385 for a contractor to establish an Accident Prevention Plan (APP) that must be submitted to and approved by the government-designated authority (the senior person in charge of the operation or activity being conducted or his or her representative) before any work can begin.