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When USACE released the 2024 edition of EM 385-1-1, the headline was the complete structural overhaul — 37 chapters, standardized format, decade of updates finally codified. But buried inside that broader narrative are three chapters that deserve special attention because they're entirely new: Chapter 23 (Rope Access), Chapter 33 (Uncrewed Aircraft), and Chapter 37 (Emergency Operations).
These aren't incremental updates to existing sections. They're brand-new frameworks for activities that were already happening on USACE project sites — often without consistent safety governance. For contractors engaged in any of these activities, these three chapters are not optional reading. They're compliance requirements, and the learning curve is real.
Rope access work — using ropes, harnesses, and specialized rigging to access elevated or otherwise difficult-to-reach work areas — has grown steadily in military construction as project complexity has increased. Bridges, dams, water control structures, vertical building facades, and confined mechanical spaces all create scenarios where rope access is more practical than scaffolding or aerial lifts.
For years, contractors performing rope access work on USACE sites were cobbling together safety requirements from the fall protection chapter, the personal protective equipment section, and general industry standards from organizations like SPRAT or IRATA. Chapter 23 ends that inconsistency.
Key areas to review in Chapter 23:
If your company uses drones on USACE projects — for site surveys, progress photography, inspection documentation, or material delivery — Chapter 33 is now your governing document. Given how rapidly drone use has expanded across the construction industry, this chapter affects a wide and growing range of contractors.
The chapter establishes requirements for operator qualifications, including adherence to FAA Part 107 certification where applicable, along with site-specific requirements for flight planning, hazard identification, and pre-flight briefings. It addresses the requirement for a written UAS Site Safety Plan.
Critical operational requirements include:
Before your next drone flight on a USACE project, ensure your operator holds the appropriate FAA certification, your UAS safety plan is approved and on file, and your pre-flight checklist reflects the Chapter 33 requirements.
Of the three new chapters, Chapter 37 on Emergency Operations may have the broadest impact simply because emergency preparedness applies to every project regardless of scope or activity type.
Chapter 37 establishes a unified framework for emergency operations planning on USACE project sites. This includes requirements for written Emergency Action Plans (EAPs) that address the full range of credible emergency scenarios: medical emergencies, fire, hazardous material releases, structural collapse, severe weather, and civil disturbance.
The chapter requires that emergency plans be specific to the project site, not boilerplate copies from a company template. This means identifying the actual evacuation routes, the actual nearest hospital with trauma capability, the actual emergency contact numbers for the installation, and the specific assembly areas designated for the project footprint.
Chapter 37 also establishes requirements for emergency drills, communication protocols during emergencies, coordination with base emergency services for on-installation projects, and documentation of emergency training provided to all site personnel.
The common thread across Chapters 23, 33, and 37 is specificity. USACE is requiring that contractors move beyond generic safety plans and demonstrate site-specific, activity-specific thinking. A rope access work plan that doesn't address the specific anchor points, the specific rescue protocol, and the specific qualification of each technician won't pass muster.
For Safety Officers building or updating their project safety documentation, the practical task is straightforward: review your current APP and supplemental plans against all three new chapters, identify the gaps, and update your documentation accordingly. If your company performs rope access or drone operations, this is not optional — it is a contract compliance requirement.
Ensure your site-specific safety documentation reflects all three new chapters before your next USACE project kickoff or pre-construction safety conference.
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