AMERICAN SOCIETY
OF SAFETY ENGINEERS
1800 East Oakton Street
Des Plaines, Illinois 60018-2187
847.699.2929
FAX 847.296.3769
www.asse.org
December 21, 2006
Lieutenant General Carl Strock
Commander
Headquarters
US Army Corps of Engineers
441 G. Street, NW
Washington, DC 20314-1000
RE: Updated USACE Manual No. 385-1-1
Dear General Strock:
The American Society of Safety Engineers (ASSE) is the oldest and
largest society of safety professionals in the world. Founded in 1911,
ASSE represents 30,000 dedicated safety, health and environmental
(SH&E) professionals, including Certified Safety Professionals,
Certified Mine Safety Professionals, Certified Industrial Hygienists,
Professional Engineers, academicians, fire protection engineers, and
system safety experts, among others. Our members are committed to
excellence in carrying out their professional responsibilities for
protecting people, property and the environment throughout the world
and in every industry, including the military.
On behalf of its members, ASSE offers the following changes to the
U.S. Army Corps of Engineers’ (USACE) updated Manual No. 385-11, “Safety - Safety and Health Requirements,” and urges the Corps to
adopt these changes to help ensure that the manual serves to meet the
Corps’ goal of protecting its personnel and property.
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O1.B.01 A qualified person(s) shall conduct all training required by this
manual. (page 11)
This provision should reference ANSI Standard Z490.1 for
Accepted Practices for Safety, Health, and Environmental
Training. Z490.1 establishes criteria for safety, health, and
environmental training programs, including development, delivery,
evaluation and program management. Other employers are finding
the standard helpful in determining the value of particular training
programs in an environment where there are so many choices in
training available in the marketplace. As for many of the standards
that we are suggesting for reference in the Manual, ASSE is the
Secretariat for Z490.1. Consistent with ANSI requirements, though,
the Committee operates independently from ASSE and is made up of
members representing a variety of stakeholders.
05.A.08(b) …wear safety-toed footwear meeting ANSI Z41 while
working… (page 41)
ANSI Standard Z41 no longer exists. USACE should look to ASTM
Standard F-13 for Pedestrian/Walkway Safety and Footwear as an
appropriate reference here.
Table 5-1 Eye and Face Protector Selection Guide (page 43)
Table 5-1 is out-of-date. USACE should examine ANSI Standard
Z87.1 for updated information.
0.6.01 …consult the OSHA regional authority to determine if the
requirements of 29 CFR 1910.146 and those provided herein are
sufficient to be considered compliant for the specific confined space work
tasks to be performed. (page 113)
ANSI Standard Z117.1 for Confined Space should also be referenced
here. USACE employees should have a wider range of available
information than that provided in OSHA’s standard.
Section 12 Control of Hazardous Energy (Lockout/Tagout) (page 249)
This section should also cite ANSI Standard Z244.1 for Personnel
Protection - Lockout/Tagout of Energy Sources - Minimum Safety
Requirements and A10.44 for Control of Energy Sources
(Lockout/Tagout) for Construction and Demolition. These are the
latest industry standards on this issue and should be available to
USACE employees.
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Section 23 Demolition (page 477)
This section needs to cite ANSI Standard A10.6 for Safety
Requirements for Demolition.
Section 7, Safety and Health Inspections, of Appendix A,
Minimum Basic Outline for Accident Prevention Plan – The
names of competent and/or qualified person(s) and proof of
competency/qualification to meet specific OSHA competent/
qualified person(s) requirements must be attached. (page A-3)
ASSE urges the Corps to examine its own needs in
determining competency of those who will conduct safety
inspections and not simply look to OSHA. Certified Safety
Professionals (CSPs), Certified Industrial Hygienists (CIHs),
and Certified Hazardous Material Managers (CHMMs)
represent the highest levels of competency in safety and
health management. Each of these certifications is widely
recognized throughout industry for having met the highest
levels of national accreditation available to profe ssional
certifications. The management of inspections requiring
knowledge and experience in dealing with the more complex
safety and health issues should be left to safety and health
professionals who have demonstrated competencies at these
levels. ASSE encourages you to reach out to the Board of
Certified Safety Professionals at www.bcsp.org, the
American Board of Industrial Hygienists at www.abih.org
and the Institute of Hazardous Materials Management at
www.ihmm.org to fully understand the capabilities these
certifications represent. ASSE would be more than happy to
work with USACE to help determine appropriate safety and
health professional qualifications for the tasks envisioned in
this section.
Section 10, Traffic Control, of Appendix B, Emergency
Recovery Operations – …training and certification by the
National Safety Council (NSC) is recommended … (page B-7)
It is wholly inappropriate for a government entity to identify
only one source of safety training, in this case the National
Safety Council (NSC). NSC is highly competent at providing
such training but so are other training organizations. If this
change were allowed to go forward, NS C would be given an
unfair advantage over other organizations. This amendment
cannot be included in the final manual.
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Section 13, Public Safety, of Appendix B, Emergency Recovery
Operations (page B-11)
This section bringing attention to public safety in emergency recovery
operations should reference ANSI Standard A10.34-2001 for
Protection of the Public on or Adjacent to Construction Sites.
Appendix Q, Definitions –
Associate Safety Profession (ASP): an individual who is currently
certified by the Board of Certified Safety Professionals (BCSP) (page Q-5)
According to the Board of Certified Safety Professionals (BCSP), the
ASP is an interim “designation” denoting progress towards the
Certified Safety Professional “certification” offered by BCSP. An
ASP is not “certified.” This definition needs to be amended to reflect
this distinction. More information can be found at www.bcsp.org.
Certified Construction Health and Safety Technician (CHST): an
individual who is currently certified by the BSCP (sic). (page Q-11)
The CHST is not certified by BCSP but by the Council on
Certification of Health, Environmental and Safety Technologists.
(CCHST). Information on CCHST can be found at www.cchst.org.
Certified Safety Trained Supervisor (CSTS): an individual who is
currently certified by the BCSP. (page Q-12)
Again, as above, the CSTS is not certified by BCSP but by CCSHT.
Addition of “Safety Professional” (page Q-60)
ASSE urges inclusion of the term Safety Professional in the Manual’s
definitions. Due to the wide variety of safety, health and
environmental responsibilities safety professionals undertake, a simple
definition has not been widely accepted within the profession. Instead,
industry looks to ANSI Standard Z590.2 for Criteria for Establishing
the Scope and Functions of the Professional Safety Position, which is
available at http://members.asse.org/z590.pdf. We urge USACE to
reference this standard as a definition here.
In conclusion, ASSE appreciates the opportunity to provide these comments.
We commend USACE for its work in helping ensure the Manual provides the
latest information on safety for its personnel. If there are any questions about
any of the changes we have offered, please be sure to contact Tim Fisher,
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ASSE’s Director of Practices and Standards at tfisher@asse.org or 847/7683411 or Dave Heidorn, ASSE’s Manager of Government Affairs and Policy at
dheidorn@asse.org or 847/768-3406.
Sincerely,
Donald S. Jones, Sr., CSP, PE
President
cc: Ellen Stewart
Safety Engineer Project