Compliance

Federal Construction Safety Requirements: Complete Guide 2025

Guide to safety requirements for federal construction contractors. Learn OSHA standards, EM 385-1-1 compliance, safety plans, and how to maintain safe jobsites on government projects.

BidFinds Government Contracting Team
December 22, 2025
11 min read

Safety on Federal Construction Projects

Federal construction contractors must comply with OSHA standards plus additional requirements like EM 385-1-1 (USACE/NAVFAC projects). Safety violations can result in contract termination, debarment, and criminal penalties. A strong safety program is both a compliance requirement and competitive differentiator.

OSHA
Baseline Standard
EM 385-1-1
DOD Construction
AHA
Activity Hazard Analysis

OSHA Construction Standards

All federal construction contractors must comply with OSHA construction standards (29 CFR 1926), which cover general safety and health provisions for construction sites.

Key OSHA Construction Standards

Subpart C: General Safety

  • • PPE requirements
  • • First aid and medical
  • • Fire protection
  • • Housekeeping

Subpart M: Fall Protection

  • • 6-foot trigger height
  • • Guardrails, nets, harnesses
  • • Leading edge work
  • • Hole covers

Subpart P: Excavations

  • • Competent person
  • • Sloping and shoring
  • • Trench boxes
  • • Soil classification

Subpart L: Scaffolding

  • • Capacity requirements
  • • Guardrails
  • • Access provisions
  • • Inspection requirements

EM 385-1-1 Requirements

EM 385-1-1 is the Safety and Health Requirements Manual used by USACE, NAVFAC, and other DOD agencies. It goes beyond OSHA in many areas.

Key EM 385-1-1 Requirements

Accident Prevention Plan (APP)

Comprehensive site safety plan required before work begins

Activity Hazard Analysis (AHA)

Detailed hazard analysis for each work activity

Site Safety and Health Officer (SSHO)

Qualified safety professional required on site

Competent Person

Required for specific activities (excavation, scaffolding, etc.)

30-Hour OSHA Training

Required for supervisors and safety personnel

Check Contract Requirements

Not all federal construction contracts require EM 385-1-1. Check your specific contract for applicable safety requirements. Many DOD contracts incorporate it by reference, while civilian agency contracts may have different standards.

Safety Plan Requirements

Accident Prevention Plan (APP) Contents

  • Company safety policy and goals
  • Responsibilities (management, SSHO, employees)
  • Training requirements and documentation
  • Hazard communication program
  • Personal protective equipment program
  • Emergency response procedures
  • Incident reporting and investigation
  • Activity Hazard Analyses

Activity Hazard Analysis (AHA)

An AHA breaks down each work activity to identify hazards and controls before work begins.

Work ActivityHazardsControls
ExcavationCave-in, falling materialsShoring, protective systems, competent person
Steel erectionFalls, struck-byFall protection, hard hats, tag lines

Key Safety Requirements

Training Requirements

  • OSHA 30-hour for supervisors
  • OSHA 10-hour for workers
  • Competent person training
  • Equipment-specific certification
  • First aid/CPR

Documentation

  • Training records
  • Inspection logs
  • Safety meeting minutes
  • Incident reports
  • Equipment certifications

Enforcement & Penalties

Consequences of Non-Compliance

Stop Work Orders

Government can halt work until violations are corrected

OSHA Citations

Fines up to $156,259 per willful violation

Contract Termination

Serious or repeated violations can result in termination for default

Debarment

Exclusion from future federal contracts

Frequently Asked Questions

What is a competent person?

A competent person is someone who can identify existing and predictable hazards and has authorization to take corrective measures. Required for excavations, scaffolding, fall protection, and other hazardous activities.

When is an SSHO required?

EM 385-1-1 contracts typically require a Site Safety and Health Officer when specific hazards are present or contract value exceeds thresholds. Check your specific contract requirements for SSHO qualifications and presence requirements.

How do I report safety incidents?

OSHA requires reporting fatalities within 8 hours and hospitalizations within 24 hours. Federal contracts typically have additional reporting requirements to the Contracting Officer. Check your contract for specific requirements.

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