USACE and NAVFAC APP Requirements: What Changed and What Remains

The Accident Prevention Plan (APP) is more than a regulatory requirement — it's the foundational document that establishes how safety will be managed on a USACE or NAVFAC project. The 2024 EM 385-1-1 revision introduced the new ENG Form 6293 cover sheet and restructured APP requirements across multiple chapters.

The New APP Cover Sheet: ENG Form 6293

The most visible change to APP requirements is the new eight-page cover sheet (ENG Form 6293). This form replaces the previous cover page format and establishes a standardized structure for APPs across all USACE and NAVFAC projects.

The new cover sheet requires more detailed information upfront, including explicit identification of SSHO qualifications, competency verification methods, and the CE-SOHMS framework for projects subject to that requirement.

Key sections of the new cover sheet include: project identification and contract information, SSHO and alternate SSHO credentials, APP preparer information, emergency contact procedures, and CE-SOHMS compliance certification.

The cover sheet must be signed by a company official with authority to commit the contractor to the safety commitments contained in the APP — not just the SSHO. This changes the approval dynamic for many contractors.

What Remained the Same

The core APP structure remains intact. You still need Activity Hazard Analyses (AHAs) tied to each major scope of work, competent person designations, and site-specific safety provisions. The AHA format and required content haven't fundamentally changed — they've been clarified and reorganized.

The requirement for AHA submittal 15 days prior to beginning work continues, though districts may have different interpretations of what "submittal" means in practice (some accept verbal notification followed by written confirmation, others require formal written approval before start).

Medical and first aid provisions, accident reporting requirements, and emergency procedures continue to be APP requirements. The formatting has been updated, but the underlying requirements persist.

What Changed

SSHO Qualifications: The new manual requires explicit documentation of SSHO qualifications, including specific training course completions, experience requirements, and competency verification for the specific project scope.

CE-SOHMS Integration: For projects requiring the Contractor Environmental and Safety and Occupational Health Management System, the APP must now explicitly reference how the APP integrates with CE-SOHMS elements.

New Technology Provisions: The APP must address drone operations, rope access work, and emergency operations if those activities will occur on the project — even if they're not the primary scope of work.

Competency Verification: The APP must describe how competency will be verified for personnel performing hazardous work, not just that training was completed.

NAVFAC-Specific Considerations

NAVFAC projects follow the same EM 385-1-1 requirements as USACE, with some additional procedural requirements specific to naval facility construction. The new APP cover sheet applies equally to NAVFAC contracts, and districts typically expect the same level of documentation.

For NAVFAC projects, pay particular attention to the Marine Operations chapter requirements if your work includes waterfront construction, vessel work, or diving operations. These have specific APP requirements that may not be obvious from the general provisions.

Aviation-related work at naval air facilities introduces additional requirements from Chapter 32 (Airfield and Aircraft Operations) that typically require separate approval processes and additional documentation in the APP.