To complete ENG 6206, the U.S. Army Corps of Engineers Activity Hazard Analysis form, the contractor’s Competent Person breaks a single work activity into sequential job steps, identifies the hazards at each step, lists the specific controls that eliminate or reduce those hazards, assigns a Risk Assessment Code to each step and to the activity as a whole, collects signatures from every worker involved, and submits the form to the Contracting Officer or Contracting Officer’s Representative for acceptance before work begins. The current version is dated September 2024 and aligns with the March 2024 revision of EM 385-1-1.
Download the Current Form
The fillable PDF lives on the USACE Publications site under Engineer Forms, listed alphabetically as “ENG 6206 — Activity Hazard Analysis (AHA).”1U.S. Army Corps of Engineers. Engineer Forms Confirm the revision date reads September 2024 before you start. You need Adobe Reader 8 or higher to fill it in digitally. Some districts and prime contractors circulate expanded versions with extra fields, but the USACE-published form is the baseline the Contracting Officer expects.
One activity per form. Don’t merge multiple Defined Features of Work onto a single AHA, even when the tasks look related.
Who Prepares and Signs the Form
Under EM 385-1-1, the Competent Person (CP) develops the AHA.2U.S. Army Corps of Engineers. EM 385-1-1 – Safety and Occupational Health Requirements A CP is authorized by the employer to identify existing and predictable hazards and to stop work immediately when conditions are unsafe. The same CP typically develops and signs the site-specific Accident Prevention Plan, so keep the two documents consistent.
A Qualified Person (QP) covers specialized technical work: scaffold design, excavation shoring review, engineered rigging, and similar tasks. When the activity depends on engineered controls, the QP’s name and proof of qualification go on the form. If several CPs or QPs are involved, attach a list of names and qualifications.
The Site Safety and Health Officer reviews the AHA for technical adequacy before it goes forward. Above the SSHO, the acceptance authority is the Contracting Officer (KO) or Contracting Officer’s Representative (COR). The 2024 revision of EM 385-1-1 eliminated the older term “Government Designated Authority.”2U.S. Army Corps of Engineers. EM 385-1-1 – Safety and Occupational Health Requirements If your contract still references the GDA, read that as the KO or COR.
Filling In the Form Section by Section
Header
Enter the activity or task name, the work location, the date of preparation, and the name and title of the preparer. Add the name and title of the acceptance authority who will sign off on the residual risk. Keep the activity name specific enough that a reader can tell which portion of the work it covers.
Job Steps
In the first column, list each job step in the order the crew will perform it, from setup through cleanup. Be concrete. “Set up scaffolding” is more useful than “prepare work area.” Someone unfamiliar with the task should be able to follow the sequence.
Hazards
In the second column, identify every hazard tied to that step: falls, struck-by, caught-between, electrical contact, silica dust, chemical vapors, heat stress, noise, and anything else that could realistically injure a worker or damage equipment. Cite the applicable EM 385-1-1 sections for the type of work — Section 11 for electrical, Section 25 for excavation, and so on.
Controls
In the third column, spell out the controls that address each hazard. EM 385-1-1 sets a hierarchy: engineering controls first (guardrails, ventilation, machine guarding), then administrative controls (safety briefings, buddy systems, rotation schedules), and personal protective equipment last, used where the first two categories cannot fully close the gap.2U.S. Army Corps of Engineers. EM 385-1-1 – Safety and Occupational Health Requirements “PPE required” is not a control. Name the PPE, the protection rating, and when workers put it on.
Equipment, Training, and Inspections
The lower portion of the form captures the equipment involved (cranes, power tools, welding machines), the training each worker must have completed before starting, and inspection requirements. For a crane lift, that means the pre-lift inspection, the operator’s certification, and the rigging inspection. List the required CPs and QPs here with their qualification documentation.
Assigning the Risk Assessment Code
Every job step gets a Risk Assessment Code (RAC) that reflects the residual risk after your controls are in place. The RAC comes from the EM 385-1-1 risk matrix, which cross-references severity against probability.2U.S. Army Corps of Engineers. EM 385-1-1 – Safety and Occupational Health Requirements
Severity has four categories:
- Catastrophic: death or permanent total disability, or system loss.
- Critical: permanent partial disability, temporary total disability, or major property damage.
- Moderate: lost workday injury or minor property damage.
- Negligible: first aid injury or minimal property damage.
Probability runs across five bands: frequent, likely, occasional, seldom, and unlikely. Plotting one against the other produces a letter code: Extremely High (E), High (H), Medium (M), or Low (L). The 2024 manual moved away from the older 1-through-5 numerical system, so if you are working from a legacy template, switch to the current letter designations.
Enter the RAC for each job step in the designated column, then assign an overall RAC to the whole AHA. The overall RAC cannot be lower than the highest individual step RAC. If any single step is H, the AHA is at least H.2U.S. Army Corps of Engineers. EM 385-1-1 – Safety and Occupational Health Requirements That overall code determines which level of authority can accept the risk and let work go forward.
Getting It Accepted
Route the AHA through the contractor’s internal risk acceptance process first. Then submit the accepted form to the KO or COR for government review and acceptance.2U.S. Army Corps of Engineers. EM 385-1-1 – Safety and Occupational Health Requirements Work cannot begin until the AHA is reviewed, accepted, and signed by the proper acceptance authority.
The manual does not set a fixed lead time. It simply prohibits starting the activity without acceptance. Build in enough runway for the government to review, especially on complex or high-risk tasks, and set expectations with your COR at the pre-construction conference. Submit each AHA together with any APP updates before the preparatory phase meeting for that activity.2U.S. Army Corps of Engineers. EM 385-1-1 – Safety and Occupational Health Requirements
Worker Signatures
Every employee performing the activity, including subcontractor employees, must review the AHA and sign either the form or a separate signature sheet.2U.S. Army Corps of Engineers. EM 385-1-1 – Safety and Occupational Health Requirements The signature is the worker’s acknowledgment of the hazards and controls. Anyone joining the activity after it has started signs before they begin work.
Keeping It Onsite
Accepted AHAs stay readily available at the job site, in the trailer or equivalent, accessible to all employees for at least 12 months or the length of the contract. The crew actively performing the work must have the current AHA in their possession while the task is underway.2U.S. Army Corps of Engineers. EM 385-1-1 – Safety and Occupational Health Requirements The document belongs where the work is happening, not in a file cabinet.
When to Update or Resubmit
Treat the AHA as a living document. Modify it whenever site conditions change, the operation changes, or the assigned CP or QP is replaced.2U.S. Army Corps of Engineers. EM 385-1-1 – Safety and Occupational Health Requirements Whether you have to resubmit depends on what happens to the risk level:
- If the RAC increases, stop the activity and resubmit the revised AHA for acceptance before resuming.
- If the RAC stays the same or drops, update the AHA and have affected employees review the changes. No resubmission for government acceptance is required.
- If work was stopped for safety non-compliance, revise the AHA, get it accepted, and have all employees re-review and re-sign before resuming.
Adding a new CP or QP who was not on the original list is an administrative update. Attach the new qualification information, and have the new person acknowledge in writing that they have reviewed the AHA and are familiar with current site conditions.
What Happens If You Skip It
Starting work without an accepted AHA violates EM 385-1-1 and the contract. Under FAR 52.236-13, if the contractor fails to correct a safety hazard or comply with safety requirements, the Contracting Officer can issue a stop-work order halting all or part of the work.3Acquisition.gov. 52.236-13 Accident Prevention The contractor gets no schedule extension and no equitable price adjustment for time lost to a safety-related stop-work order. Persistent failures can escalate to termination for default under FAR 49.4, which carries potential liability for excess reprocurement costs.4Acquisition.GOV. FAR Subpart 49.4 – Termination for Default Safety performance also feeds into CPARS evaluations, which follow the firm into future proposal competitions.5U.S. Army Corps of Engineers. Construction Contractor Performance Evaluations