If you are checking an SSHO against a summary written before 2024 — a consultant's one-pager, a staffing agency's job description, or most of what a search turns up on this subject — you are checking them against a manual that no longer applies. The current edition of USACE EM 385-1-1 is dated 15 March 2024 and says on its own face that it supersedes the 30 November 2014 edition. It did not tidy the SSHO requirement up. It rewrote it.
Here is every change that affects who you are allowed to put on a site, what training they need, and what paperwork has to exist before anyone breaks ground.
The changes, side by side
| Under the 2014 edition | Under the 15 March 2024 edition | Paragraph |
|---|---|---|
| One SSHO per site, a competent person | Three levels exist. One Level 1 SSHO at each project site, and the contract sets the level | 2-2.x, 2-8.b(2) |
| The requirement lived in Section 01.A.17 | It moved to Chapter 2 — 2-2.x, 2-3.b, 2-4.b and 2-8.b | Ch. 2 |
| OSHA 30-hour construction | OSHA 30-hour general industry or construction, and web-based delivery is allowed where OSHA permits | 2-3.b(1)(a) |
| 5 years continuous safety experience; 4 with an ANSI or NCCA certification | 5 years cumulative within the last ten, on projects similar in industry type, size and complexity; 3 with a safety-related degree or an ANSI-, NCCA- or CESB-accredited certification | 2-3.b(1)(c) |
| — | Level 2: 3 years of that same experience, or 2 with the equivalent credential | 2-3.b(2)(c) |
| 8 hours of continuing education every year | 24 hours every three years, plus 24 within the past five. The initial OSHA 30-hour course does not count toward it | 2-3.b(1)(b) |
| An employee other than the site supervisor | A Level 1 SSHO may not supervise non-safety personnel at the site of work | 2-8.b(2)(a) |
| Reports to a senior project or corporate official | Reports to the corporate safety official, the senior project manager, or a corporate official | 2-4.b(1) |
| A Designated Representative could cover an absence of up to 24 hours | The DR no longer exists. A Level 1, 2 or 3 SSHO covers up to 24 hours; beyond that an additional or alternate Level 1 is required | 2-8.b(2)(c), (d) |
| — | ENG Form 6282 designation letter is mandatory, signed by the corporate safety official and the SSHO, and accepted by the contracting officer or COR before work is conducted | 2-8.b(1) |
| AHAs on file 6 months | AHAs available on site 12 months, or the length of the contract | 2-6.d(3) |
| A carve-out for dredging | Framed as exceptions to the full-time Level 1 requirement, granted by the contracting officer with the local safety office in the contract documents, based on complexity and size. Dredging, maintenance, service and limited-scope contracts are the examples given | 2-8.b(3) |
The four that actually cost people money
The designation letter. ENG Form 6282 is the one with a hard gate attached: work must not be conducted until the government has accepted it. It sits between award and the first day of work, which is exactly where nobody is looking. We wrote it up separately in ENG Form 6282, and why work cannot start without it.
The continuing education cadence. Twenty-four hours every three years is the same volume as eight hours a year, so people assume nothing changed and keep producing annual records. The problem is the five-year look-back and the fact that the OSHA 30 does not count toward either figure. See what counts toward the 24 hours.
Recency on the experience. Five years within the last ten, on similar projects, is a much narrower test than five years ever. A long career with a gap in the middle of it, or a career spent on work unlike the contract, does not automatically clear the bar.
The Designated Representative. If a staffing agency or a safety consultant offers you a DR to cover your SSHO's absence, they are quoting the 2014 manual at you. The term is gone. What replaced it is in who covers when your SSHO leaves site.
How to check what you are reading. The current manual is titled EM 385-1-1 and dated 15 March 2024 on its cover, and its front matter states that it supersedes the 30 November 2014 edition. If the document in front of you says 30 November 2014, or cites Section 01.A.17, or uses the phrase Designated Representative, it is out of date for this purpose.
What to do with this
- Pull the ENG Form 6282 for every active site and confirm the government accepted it, and that the accepted copy is at the site of work.
- Re-check each SSHO's experience against the ten-year window and against the industry type, size and complexity of that contract.
- Count their documented training hours over the past five years, and over the current three-year period, leaving the OSHA 30 out of the count.
- Check what level your contract actually calls for before you assume Level 1, and check whether an exception was written into the contract documents.
Sourced from USACE EM 385-1-1, edition of 15 March 2024 (which supersedes the 30 November 2014 edition) — paragraph 2-2.x for the SSHO levels, 2-3.b for training and experience, 2-4.b for roles and responsibilities, and 2-8.b for designation and site requirements. Reviewed 2026-10-02.