Usually yes — but not because EM 385-1-1 says so, and the distinction is not pedantry. If you justify an SSHO on a Navy job by pointing at EM 385-1-1's applicability paragraph, you are pointing at a paragraph that does not mention NAVFAC, and if you assume the requirement applies because the customer is NAVFAC, you will occasionally be wrong.
What EM 385-1-1 actually covers
NAVFAC appears nowhere in EM 385-1-1. The manual is issued by the U.S. Army Corps of Engineers and its front matter applies it to USACE, its subordinate commands, and USACE contracts and those administered on behalf of USACE. That is the scope. The SSHO requirement cannot be sourced to the manual on a contract that is not one of those.
Where the requirement comes from on Navy and Air Force work
From the specification. UFGS Section 01 35 26, Governmental Safety Requirements is a Unified Facilities Guide Specification headed USACE / NAVFAC / AFCEC, with NAVFAC as the preparing activity. The edition current at the time of writing is May 2024, Change 2 of August 2026.
That section does three things that matter here:
- It directs the contractor to comply with the most recent edition of USACE EM 385-1-1 — so the manual arrives by reference, through the contract.
- It defines the same Full Time Level One, Collateral Duty Level Two and Task-Specific Level Three SSHOs.
- It requires the same ENG Form 6282 designation.
So the substance is the same. The authority is different.
Why that changes what you check
A guide specification is tailored project by project. UFGS sections are edited into a particular contract by the designer of record and the government, and what you get is the tailored result, not the guide. So the test is whether Section 01 35 26 is in your contract and what it was tailored to say — not which agency's badge is on the project sign.
Practically:
- Search the specification index for 01 35 26. If it is in there, read it, including the level it calls for.
- Read Division 01 generally. Safety requirements can also arrive through other sections, and the level required may be stated there rather than left to the manual's default.
- Look for an exception. The full-time Level 1 requirement can be modified to another level or combination of levels in the contract documents, by the contracting officer with the local safety office, based on complexity and size. If that happened, it is in your contract, not in the manual.
- Ask the KO or COR in writing if the specification is ambiguous. They are the acceptance authority for the designation anyway.
The same logic for everyone else
Air Force work under AFCEC reaches the requirement the same way, through the same jointly-issued section. And the reverse case exists too: a contract administered on behalf of USACE carries EM 385-1-1 directly even when the eventual user is somebody else. In both directions the contract is the authority and the agency name is a hint.
If Section 01 35 26 is in your contract, everything on this site applies to your job: the qualification bar, the designation letter, and the 2024 changes — because the section points at the most recent edition of the manual, which means the 15 March 2024 edition, not the 2014 one.
NAVFAC and Air Force requirement sourced from UFGS Section 01 35 26, Governmental Safety Requirements (May 2024, Change 2 of August 2026) — the unified guide specification issued jointly for USACE, NAVFAC and AFCEC, with NAVFAC as the preparing activity. Reviewed 2026-10-02.