USACE published the 2024 edition of EM 385-1-1 on 15 March 2024. It supersedes the 30 November 2014 manual, carries a new title (Safety and Occupational Health Requirements), and reorganizes the book into 37 chapters. If you write AHAs for Corps work, three changes reach your paperwork directly: chapter numbers, RAC wording, and what the AHA itself must name. Here is each one, with the paragraph to check it against.
Which contracts use the 2024 edition
The edition follows the solicitation date, not the start of work. Preamble paragraph 5.b(1) of the 2024 manual says contractors must comply with the version of the manual in effect on the date of solicitation, and adds: “Existing contracts will continue to apply the provisions of the previous edition of this manual until contract completion.”
So a contract solicited on or after 15 March 2024 is a 2024-edition contract. A contract solicited before that date stays on the 2014 manual until it closes out, even if you mobilize today. Check the solicitation date on your contract before you cite anything.
Five chapters moved; most kept their numbers
The 2014 manual was organized in 34 sections; the 2024 manual has 37 chapters. That sounds like a full renumbering, but most numbers held. Five 2014 sections moved:
| 2014 section | 2024 chapter | What happened |
|---|---|---|
| 01 Program Management | 1 and 2 | Split: Chapter 1 covers USACE personnel; Chapter 2 covers contractors, including the AHA rules |
| 02 Sanitation | 35 Sanitation | Moved to the back of the manual |
| 17 Conveyors | 14 Material Handling, Storage, Disposal, and Conveyors | Merged into Chapter 14 |
| 23 Demolition, Renovation, and Re-Occupancy | 17 Demolition, Renovation, and Re-Occupancy | Moved; Chapter 23 is now Rope Access |
| 33 HAZWOPER | 36 Hazardous Waste Operations and Emergency Response | Moved; Chapter 33 is now Uncrewed Aircraft |
Five of the most-cited numbers did not move:
| Number | 2024 chapter title |
|---|---|
| 16 | Load Handling Equipment |
| 20 | Pressurized Equipment and Systems |
| 21 | Fall Protection |
| 25 | Excavation and Trenching |
| 34 | Confined Space (formerly Confined Space Entry) |
Three chapters are new: 23 Rope Access, 33 Uncrewed Aircraft, and 37 Emergency Operations. The risk is not the five moves themselves. It is an AHA that cites “Section 23” for demolition on a 2024-edition contract, where Chapter 23 is rope access. A reviewer who checks the citation will send it back.
Paragraph numbers changed format too. The 2014 style read like 21.A.01; the 2024 style reads like 2-6.d. A 2014-style paragraph number on a 2024-edition AHA points at nothing.
The RAC wording changed
The Risk Assessment Code itself works the same way: severity against probability, read off a matrix, with the overall RAC no lower than the highest job-step RAC. The words changed. Definitions 2-2.u and 2-2.w of the 2024 manual say:
- Severity is “catastrophic, critical, moderate, or negligible.” The third level used to read Marginal on most AHA forms.
- The risk levels are “extremely high (E), high (H), medium (M) and low (L).” M used to read Moderate Risk.
- Probability is unchanged: frequent, likely, occasional, seldom, or unlikely.
The manual does not print its own matrix grid. It points to ENG Form 6206, the non-mandatory AHA format, so the E/H/M/L grid on that form still applies. What should change on your AHA is the vocabulary: Moderate severity, Medium risk.
What an AHA must now name
Paragraph 2-6.d(4) lists what a contractor's AHA must include. Several items are names, not hazards, and older forms often had no line for them:
- The contractor and the contract. Item (a) asks for the contractor name and contract number with the activity, location, date, and preparer.
- The acceptance authority. Item (a) also asks for the name and title of the AHA acceptance authority. Paragraph 2-6.c(2) has prime contractors set out that authority in the APP, and notes that USACE does not accept contractor risk.
- Competent and qualified persons, by name. Item (g) has the employer designate any required CPs and QPs in writing, by name, with proof of competency.
- A RAC per job step and an overall RAC. Items (e) and (f): the overall RAC must not be lower than the highest job-step RAC.
Two more rules sit around the list. Every involved employee reviews the AHA and signs it, per 2-6.d(2). The AHA stays available on site for 12 months or the length of the contract, per 2-6.d(3). If a change raises the RAC, the AHA goes back for acceptance before work starts, per 2-6.d(5).
What AHA Generator does about it
Every AHA the generator writes is built on the 2024 edition. Citations are at chapter level, in one format you can check against the table of contents, for example “EM 385-1-1 (2024), Ch. 21 Fall Protection”. The RAC matrix uses the manual's Moderate and Medium Risk wording. The form has lines for the contractor, the acceptance authority, and the competent and qualified persons, and blank lines print ready for hand completion. Crew sign-off by QR code covers the signature requirement. If your contract was solicited before 15 March 2024, ask us for a 2014-edition document.
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