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OSHA Military: How do OSHA Standards Apply to the Military?

osha military standards

The Occupational Safety and Health Administration (OSHA) protects American workers' safety and health from workplace hazards. There are exceptions–when OSHA regulations don't apply or are handled by another agency–but federal employees are firmly under their purview.

Have you ever wondered what this means for our troops? They're federal employees, and they certainly have plenty of workplace hazards.

How Do OSHA Standards Apply to the Military?

Well, they don't. At least not to "military personnel and uniquely military equipment, systems, and operations." These activities were excluded from OSHA's jurisdiction by Presidential Executive Order (EO) 12196, which was issued in 1980.

On the other hand, the Department of Defense employs 700,000 civilian personnel, many of which work on equipment, systems, and operations that are "not military unique."

OSHA does apply to those employees under those conditions. For example, OSHA can inspect U.S. Coast Guard facilities where civilians do office work without advanced notice, just as they can with a private-sector workplace.

It's not a grudging relationship, either. In 2003, the Army formed a strategic partnership with OSHA to reduce civilian worker fatalities, injuries, and illnesses by 3% annually.

What's the Line Between OSHA & Military Jurisdictions?

This distinction can get a little complicated. Under OSHA's jurisdiction, activities include vehicle repair, medical services, construction, civil engineering, public works, supply services, and administrative work.

However, even these activities are only under OSHA's jurisdiction when compared to private-sector activities. For example, vehicle repair is considered "uniquely military" when you're working on tactical vehicles like tanks so OSHA regulations wouldn't apply.

The line is drawn short of DoD equipment and systems unique to the national defense mission. OSHA's Field Operations Manual provides examples of exempt equipment and activities, including:

  • Military aircraft, ships, and submarines
  • Artillery, tanks, and tactical vehicles
  • Naval operations, military flight operations, and associated research test and development activities
  • Missiles and missile sites
  • Military space systems
  • Field maneuvers

Do Military OSHA Standards Exist?

OSHA's jurisdiction ends with the military's civilian workforce, but that doesn't mean the military doesn't have its workplace safety procedures.

"OSHA" military standards – that is, occupational safety and health standards that belong to the military rather than the dedicated federal agency – exist. The DoD incorporates OSHA requirements into the Army Safety Program and other branch-specific safety and health regulations.

What Incorporates OSHA Requirements into the Army Safety Program?

The Army Safety Program regulations are laid out in Army Regulation 385-10, which was introduced in 2000. It incorporates OSHA standards and applies to the Active Army, the Army National Guard of the United States, the U.S. Army Reserve, Army civilian employees, and the U.S. Army Corps of Engineers and Civil Works.

How are Military OSHA Standards Different?

Army Regulation 385-10 incorporates OSHA requirements into the Army Safety Program, but many of military OSHA standards provide a higher degree of protection.

For example, the Army has a strict hearing loss prevention program, and safety requirements for U.S. Army Corps of Engineers (USACE) construction projects go well beyond §1926 standards.

USACE safety standards are also the ones that non-military personnel are most likely to interact with. Construction crews that land a military or federally funded project must comply with Engineering Manual (EM) 385-1-1. It's the Engineering Corps' version of military OSHA standards. Even some state and local projects require EM 385 compliance.

USACE safety requirements incorporate §1926 OSHA requirements but are stricter in many ways. The fall standards in EM 385 are one example of more stringent safety requirements.

However, the most significant differences appear in the administrative and managerial requirements. USACE standards require full-time project oversight by a Site Safety and Health Officer whose only job is to be responsible for on-site safety and health. EM 385 also requires a written Accident Prevention Plan (APP) and an Activity Hazard Analysis for each job performed.

In addition to the paperwork, contractors must conduct "frequent and regular" inspections and designate certain point persons (called Collateral Duty Safety Officers or CDSOs) to ensure that safety protocols are followed.

Finally, the safety training requirements are more specific and thorough. In addition to pre-project indoctrination, EM 385 mandates holding a topically-relevant toolbox talk at least once a week. The regs even require documenting attendance.

Military OSHA Training

To comply with Army Corps of Engineers' safety standards, workers must take a specific EM 385-1-1 safety indoctrination course. This training is extensive.

Most workers without supervisory responsibilities need the 16-hour EM 385 orientation. Managers, supervisors, crew leaders, and CDSOs need the 24-hour EM 385 training instead.

By far, the most extensive training requirement is for SSHOs. They need an initial 40-hour course followed by an annual 8-hour refresher.

Workers may also be required to have an up-to-date OSHA 30 card.

Our OSHA and EM 385 courses are online and self-paced for your convenience. Enroll today to get started!