EM 385 AHA Library

Asbestos Abatement Activity Hazard Analysis Example — EM 385-1-1

Free asbestos abatement AHA example for USACE/NAVFAC work: EM 385-1-1 (2024) Ch 6 citations, job steps, residual RACs, training and inspection tables.

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Asbestos abatement is a definable feature of work (DFOW) on most federal renovation and demolition contracts, and it carries some of the tightest regulatory overlap on any project: EM 385-1-1 Chapter 6 (Hazardous or Toxic Agents and Environments), OSHA 29 CFR 1926.1101, the asbestos NESHAP at 40 CFR 61 Subpart M, and the contract specification (typically UFGS 02 82 00). Under EM 385-1-1 para 6-8.f(1), every project must be evaluated for the potential to contact asbestos-containing material (ACM), all ACM must be labeled or mapped, and any work that may disturb ACM triggers a written Asbestos Management Plan under para 6-7.d before the first barrier goes up.

This activity hazard analysis example is written for SSHOs, CIHs, abatement supervisors, and project engineers preparing AHAs for USACE and NAVFAC contracts. It follows the ENG Form 6206 (SEP 2024) structure: sequenced job steps from mobilization and notification through containment, removal, clearance, and demobilization, with hazards, hierarchy-of-controls entries, and a residual Risk Assessment Code (RAC) for each step. Citations use the 15 March 2024 edition of EM 385-1-1 (chapter-paragraph format, e.g. para 6-7.d); contracts solicited before 15 March 2024 generally remain on the 2014 edition with its old section-style numbering (e.g. 06.B), so confirm which edition your contract invokes before copying citations.

Use this AHA example as a starting point, not a finished submittal. Your site-specific version must reflect the actual asbestos survey, the OSHA work class (Class I through IV), the containment and decontamination design in your accepted Asbestos Management Plan, and the named Competent and Qualified Persons on your crew. Work may not begin until the AHA is accepted and signed and every involved employee has reviewed and signed it (EM 385-1-1 para 2-6).

Risk Assessment Code (RAC) Matrix — EM 385-1-1 (2024)

Severity ↓ / Probability →FrequentLikelyOccasionalSeldomUnlikely
CatastrophicEEHHM
CriticalEHHML
ModerateHMMLL
NegligibleMLLLL

E = Extremely High Risk · H = High Risk · M = Medium Risk · L = Low Risk (per EM 385-1-1 2024, para 2-2.u/2-2.w and ENG Form 6206). Controls must reduce the residual RAC to a level the approval authority accepts before work proceeds.

Sample AHA: Asbestos Abatement

On a phone, swipe the table sideways to see the controls and residual RAC columns →

Overall RAC: M — Medium Risk (highest residual step RAC, per EM 385-1-1 2024 para 2-6.d(4)(f))

Job StepHazardsControls (hierarchy: elimination → engineering → administrative → PPE)Residual RAC
Mobilization, survey review, and regulatory notificationUnidentified or mischaracterized ACM disturbed because survey data is incomplete or not keyed to the work areas
  • Obtain and review the asbestos survey required by EM 385-1-1 para 17-8.b, performed by trained and licensed inspectors, before pricing or sequencing any disturbance work.
  • Describe each activity that will disturb ACM in the written Asbestos Management Plan — OSHA class of work, crew size, procedures, and ACM components keyed to the project drawings (para 6-7.d(1)).
  • Treat any suspect material not covered by the survey as presumed ACM; stop work and sample before disturbance (29 CFR 1926.1101(k)).
  • Label all ACM as an asbestos hazard not to be disturbed without proper protection; where ACM is inaccessible to label, create and post a site map identifying hazard locations (para 6-8.f(1)(c)).
L
Regulatory violation from missing NESHAP notification or uncoordinated site employers
  • Submit the 40 CFR 61 Subpart M notification to the administering agency at least 10 working days before regulated renovation/demolition work begins.
  • Implement the Asbestos Management Plan method for notifying other employers at the work site of regulated areas and scheduled abatement (para 6-7.d(2)).
  • Verify the AHA with its identified RAC has been reviewed, accepted, and signed by the approval authority (para 2-6.c(1)) and the Asbestos Management Plan has been accepted before mobilizing abatement crews.
L
Regulated area setup: critical barriers, containment, and decontamination unitFiber release beyond the work area from incomplete containment or unsealed penetrations
  • Establish the regulated area, containment type, and decontamination unit exactly as described in the accepted Asbestos Management Plan (para 6-7.d(3)); demarcate and sign the regulated area per 29 CFR 1926.1101(e).
  • Isolate and seal HVAC intakes, grilles, and duct penetrations serving the work area before disturbing any ACM; coordinate system shutdown and lockout with the facility.
  • Post environmental (perimeter) air monitoring to demonstrate the absence of fiber migration outside the regulated area (para 6-7.d(4)(c)).
L
Electrical shock from temporary power, wet methods, and negative air machines in a wet enclosure
  • Feed all containment power tools, negative air machines, and lighting through GFCI protection and inspect cords before each shift.
  • Route cords overhead and off wet floors; de-energize and lock out circuits within the containment that will be wetted or cut.
  • Use low-voltage or double-insulated lighting inside shower and wash-down areas.
L
Falls from ladders and baker scaffolds while hanging poly on ceilings and critical barriers
  • Select ladders and rolling scaffolds rated for the task; maintain three points of contact and do not stand on the top two ladder steps.
  • Keep floor poly taut and taped, and dry-mop slick surfaces before repositioning ladders.
  • Provide fall protection for any barrier work at 6 ft or more above lower levels per EM 385-1-1 Ch 21.
L
Pre-abatement verification: negative pressure, smoke test, and worker clearanceContainment failure not detected before disturbance work starts
  • Verify negative pressure enclosures hold the design pressure differential (typically -0.02 in. w.g.) on a recording manometer and smoke-test barriers and airlocks before first disturbance.
  • Evaluate the ventilation (negative air) system to confirm it functions as designed (para 6-5.c) and inspect filtration units per the manufacturer's instructions.
  • Document the pre-abatement inspection in the daily log per the inspection frequency set in the Asbestos Management Plan.
L
Unqualified or medically unfit workers entering the regulated area
  • Verify every entrant holds current asbestos training for their role and exposure potential per OSHA/EPA standards — typically EPA/AHERA worker and supervisor accreditation for Class I/II work (para 6-3.h(2)).
  • Confirm current medical surveillance and respirator medical clearance for each worker before donning (paras 6-7.d(9), 5-7.b(3)).
  • Confirm current fit tests for tight-fitting respirators and document them in the RPP records (para 5-7.b(4)).
  • Have every involved employee review and sign the AHA before starting work (para 2-6.d(2)).
L
ACM removal (Class I/II work) inside containmentAirborne asbestos fiber exposure above the 0.1 f/cc PEL during gross removal
  • Keep ACM adequately wetted with amended water from spray equipment before, during, and after removal; do not use compressed air to remove ACM unless it is used with an enclosed capture ventilation system (29 CFR 1926.1101(g)(1)).
  • Run HEPA-filtered negative air continuously and use HEPA vacuums for pickup — the filters must trap at least 99.97% of 0.3 micrometer particles (para 6-2.k).
  • Conduct the initial exposure determination and continued personal air monitoring per the air monitoring plan (para 6-7.d(4)(a)-(b)).
  • Use respirators selected under the written site-specific RPP per 29 CFR 1910.134 (para 5-7.b), upgrading protection factor whenever monitoring or work class requires it.
  • Bag or wrap removed material while wet as work progresses; do not allow dried debris to accumulate (housekeeping per para 6-7.d(6)).
M
Heat stress from impermeable coveralls and respirators inside a sealed enclosure
  • Establish a work/rest schedule based on monitored heat stress conditions and adjust for the added burden of PPE per the Thermal Stress Management Plan (paras 6-8.m, 6-7.g).
  • Stage cool potable water and a shaded rest area immediately outside the decon unit; require hydration at each exit.
  • Schedule gross removal for cooler parts of the shift where feasible and rotate crews through high-exertion tasks.
  • Implement a buddy system and train workers to recognize heat illness signs in themselves and co-workers; empower any worker to call a break (para 6-8.m(1)).
M
Slips, trips, and cuts on wet poly, hoses, and sharp lath or mechanical edges
  • Maintain clear pathways to airlocks; coil hoses and cords against walls between uses.
  • Wet-mop and pick up debris continuously rather than allowing piles to build under foot.
  • Use cut-resistant gloves for scraping and demolition of jagged substrates; keep utility knives retracted when not cutting.
L
Waste bag-out, decontamination, and load-outContamination spread beyond the regulated area during bag-out and worker exit
  • Double-bag or wrap waste in labeled 6-mil bags/poly, HEPA-vacuum and wet-wipe bag exteriors in the airlock before transfer out of containment (paras 6-7.d(6), 6-7.d(10)).
  • Require full decontamination sequence — HEPA vacuum of suits, suit drop, shower, clean change — for every exit through the decon unit (para 6-7.d(7)).
  • Clean, inspect, and maintain reusable PPE before reissue; inspect all PPE visually before each use and tag defective equipment out of service (para 5-5.b).
  • Restrict load-out routes and secure the waste accumulation area per the plan's security procedures (para 6-7.d(11)).
L
Manual handling injuries from lifting saturated waste bags and drums
  • Limit bag fill so wet waste remains a one-person lift or assign two-person lifts and carts for heavier containers.
  • Stage waste close to the airlock and use drum dollies or carts for transport to the lockable container.
  • Train crews in lifting technique and rotate bag-out duty during long shifts.
L
Final cleaning, visual inspection, and clearance air monitoringResidual contamination left in place and released to building occupants after teardown
  • Perform sequenced final cleaning (HEPA vacuum and wet wipe of all surfaces) followed by a documented visual inspection by the abatement CP before clearance sampling.
  • Have clearance monitoring conducted by an independent IH or a QP per contract specifications (para 6-7.d(4)(d)); do not remove critical barriers until clearance criteria are met.
  • Keep negative air units running through final cleaning, settling, and clearance sampling.
  • Apply lock-down encapsulant to substrate surfaces per the specification before reoccupancy where required by UFGS 02 82 00.
L
Containment teardown and demobilizationFiber release from contaminated poly and equipment during teardown
  • Remove containment layers only after written clearance; mist, fold contaminated side inward, and bag all poly as asbestos waste.
  • HEPA-vacuum and wet-wipe negative air machines, tools, and cords before removal from the regulated area; change or seal filters per the manufacturer's instructions.
  • Maintain respiratory protection and decon procedures for teardown crews until the last critical barrier and airlock are removed.
L
Falls during removal of overhead barriers and scaffold breakdown
  • Reverse the erection sequence with the same ladder/scaffold controls used during setup; maintain three points of contact.
  • Keep teardown areas clear of loose poly and debris underfoot before working overhead.
L
Waste transport and disposalImproper transport or disposal of regulated asbestos-containing waste
  • Containerize, label, manifest, and dispose of waste at a landfill approved for asbestos per 40 CFR 61 Subpart M, following the plan's waste generation, containerization, transportation, and disposal procedures including recordkeeping (para 6-7.d(10)).
  • Assign a QP to oversee storage of the waste prior to transportation (para 6-4.b).
  • Line and enclose transport containers; keep waste adequately wet and secured against release in transit.
  • Retain waste shipment records and disposal receipts with the project files for the durations required by the NESHAP and the contract.
L

Equipment To Be Used

Training Requirements

Inspection Requirements

Competent / Qualified Person Requirements

Applicable EM 385-1-1 (2024) Sections

Applicable OSHA Standards

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Frequently Asked Questions

What EM 385-1-1 chapter covers asbestos abatement?

Chapter 6, Hazardous or Toxic Agents and Environments, in the 15 March 2024 edition. Para 6-8.f(1) requires evaluating every project for potential ACM contact and labeling or mapping asbestos hazards, para 6-7.d requires a written Asbestos Management Plan whenever work may disturb ACM, and para 6-3.h(2) sets training tiered by exposure potential. Chapter 5 governs the respiratory protection program, and Chapter 17 applies when abatement supports demolition or renovation.

Do I need an Asbestos Management Plan in addition to the AHA?

Yes. The AHA and the plan are separate documents with separate acceptance paths. Para 6-7.d requires the written plan — covering work descriptions by OSHA class, regulated areas and containment, the air monitoring plan, hygiene facilities, training, medical surveillance, waste handling, and emergency procedures — while para 2-6 requires the AHA for the activity itself. The AHA should reference the accepted plan and attach SDSs for chemicals in use (para 6-6).

What should the overall RAC be for asbestos abatement?

The overall RAC must not be lower than the highest residual RAC of any job step (para 2-6.d(4)(f)). For a typical Class I/II abatement with full containment, wet methods, negative air, and a compliant RPP, the removal step usually carries a residual RAC of M (Medium) for fiber exposure and heat stress, making the overall activity RAC M. If your controls are weaker — for example, no negative exposure assessment and unverified containment — the pre-control assessment will be H or E and the AHA should show how controls bring it down.

Does the 2014 or 2024 edition of EM 385-1-1 apply to my contract?

Contracts solicited on or after 15 March 2024 use the 2024 edition; existing contracts generally remain on the 2014 edition until completion. The editions are numbered completely differently — the 2024 manual uses chapter-paragraph cites like para 6-7.d, while the 2014 edition used section-style cites like 06.B — so never mix citation styles in one AHA. Check your contract clauses or ask the KO/COR if the edition is not stated.

Who has to be on site as the competent person during abatement?

OSHA 29 CFR 1926.1101(o) requires an asbestos competent person — trained to the EPA/AHERA contractor-supervisor level for Class I and II work — to supervise the work and inspect the regulated area. EM 385-1-1 para 2-6.d(4)(g) additionally requires the employer to designate the CP/QP in writing by name for the activity, and clearance monitoring must be run by an independent IH or QP per para 6-7.d(4)(d), not by the abatement crew itself.

Do I need a separate AHA for containment setup versus removal?

Usually no — one AHA for the abatement DFOW with distinct job steps (mobilization, containment setup, removal, clearance, teardown, disposal) is the normal approach and matches the ENG Form 6206 format. Prepare a separate AHA when a distinct activity with its own hazards and crew is involved, such as scaffold erection for elevated ACM or roofing ACM removal. Update and re-sign the AHA whenever conditions change, and resubmit it if the RAC increases (para 2-6.d(5)).

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