EM 385-1-1 vs. OSHA Standards: Key Differences Explained

If you’re taking on a government contract, don’t assume your OSHA training is enough. EM 385-1-1 is a separate set of strict safety regulations required by the U.S. Army Corps of Engineers. Failure to follow these guidelines could cost your team the job or, worse, someone's safety. Here’s what sets EM 385-1-1 apart from OSHA and why it matters.

What Is EM 385-1-1?

EM385-1-1 is the Safety and Health Requirements Manual maintained by the US Corps of Engineers (USACE) for Department of Defense (DoD) projects. Compliance with EM385-1-1 is crucial for contractors, project managers, and those who uphold EM385 regulations. It mandates that contractors:

• Fulfill federal and state requirements
• Complete safety, quality, and environmental compliance courses
• Be eligible to manage the contract, including ensuring adherence to safety and health regulations.

EM 385-1-1 is designed to guarantee that personnel obtain the appropriate training to meet USACE safety and health standards. Training covers key topics specifically involving DoD and military standards, such as:

• Identifying inspection regulations
• Applying these standards to prevent hazards and accidents
• Selecting appropriate engineering controls, safety monitoring systems, and personal protective equipment for USACE-contracted work
• Explaining best practices for safe equipment use during various tasks.

When contractors operate under EM385 regulations, they're essentially working directly for the government. This means not only are the standards stricter, but the penalties for not following them are also more severe. Additionally, there's increased scrutiny of the actions of contracted groups compared to when they're not working directly for the DoD or the military. Projects may involve national security, heightening the importance of contractors adhering to regulations and exercising greater caution.

What Is OSHA?

OSHA stands for Occupational Safety and Health Administration. In 1970, Congress established OSHA as a way to guarantee safe and healthy working conditions in every field. OSHA’s objective is to protect workers from occupational injury, illness, and death. Today, OSHA ensures safe workplaces for over 130 million Americans in industries like manufacturing, retail, healthcare, and construction, with mandatory OSHA training for all workers exposed to job hazards.

Health and safety training is crucial for worker safety because it enables effective risk identification and mitigation. OSHA’s standards apply to both private and public sector employees, though there are exceptions for special circumstances and programs.

Employers are directed by OSHA to provide safe working environments and training on necessary safety information, and OSHA enforces its standards as well. They do this by scheduled and surprise inspections, investigations, citations, and fines. If they find a violation and it is not remedied by a certain date, fines can exceed $10,000 per day.

Comparing EM 385-1-1 and OSHA Standards

EM 385-1-1 and OSHA regulations work from different sets of rules. Both focus on occupational safety and health for construction and demolition workers, but EM 385 courses instruct directly from the USACE Engineer's Manual, while OSHA training focuses on 29 CFR 1926 and parts of §1910.

While OSHA and USACE health and safety standards share many similarities, EM 385 regulations are notably more strict, especially regarding planning, documentation, inspections, and safety management. Military operations, equipment, and systems, including military aircraft, missiles, artillery, tanks, and tactical vehicles, are exempt from OSHA standards and thereby fall under EM 385.

All private sector construction workers must complete OSHA training, but private contractors who win federal bids and members of USACE must have EM 385-1-1 training. Some construction workers in the private sector could require both kinds of training.

Technical criteria in some areas are exactly the same as those in EM385 and OSHA's 29 CFR 1926. This includes plumb, level, planked scaffolds, flexible electrical wires approved for harsh service usage, guarding moving equipment and machinery, and personal protective equipment.

As stated previously, stricter technical requirements are required by EM385 to emphasize the need for job site inspections and staff training in averting mishaps. This makes employee education vital, and special attention needs to be paid to training staff members on potential risks and the necessary safety measures to reduce them, especially for those that are not immediately apparent.

A contractor can have their contract canceled if they break any of the provisions of EM385. The handbook is a vital tool since it is intended to assist you in adhering to the particular guidelines and policies of EM385. A contracting officer has the power to halt activities and impose a $2,000 daily penalty if you are discovered to be in violation.

Who Needs EM 385-1-1 Training?

EM 385-1-1 training courses are required for any contractor, subcontractor, or worker on a USACE or DoD construction project. If you are bidding on or managing a government contract involving military construction, EM 385 compliance isn't optional; it’s mandatory. Site Safety and Health Officers (SSHOs), quality control managers, and supervisors must also meet specific training and experience criteria outlined in EM 385-1-1.

Why Training Is Important

Differences aside, OSHA and EM 385-1-1 were founded with the same goal in mind – to keep workers safe. According to the U.S. Bureau of Labor Statistics, the construction industry accounted for over 21% of all workplace fatalities in 2022. Meanwhile, the USACE Safety & Occupational Health website notes that EM 385‑1‑1‑mandated projects "fall far below the national average for accidents," demonstrating that its more stringent inspection, documentation, and training protocols deliver measurable safety improvements.

OSHA and EM385 enforce safe working regulations and correct dangerous or hazardous conditions. The most effective way to combat this is through educating and training businesses and employees on how to prevent accidents and injuries.

That means that both EM385 and OSHA training are vital for employee safety. Effective training and regular training refreshes lower the risk of workplace accidents, increase employee retention, and encourage safe and healthy work practices. Enroll in OSHA.com's 40-hour EM 385-1-1 USACE Safety & Health course to gain a thorough understanding of EM385 standards. We also offer courses on General Industry and Construction for OSHA 10 and OSHA 30. Check out our catalog to find the course that is right for you. Enroll today!