Asphalt Paving Activity Hazard Analysis Example — Free EM 385 Template
Free asphalt paving AHA example for USACE/NAVFAC work: EM 385-1-1 (2024) citations, job steps, hazards, controls, residual RACs in ENG Form 6206 format.
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control to your site's actual conditions before your SSHO signs it. On a phone? Tap the PDF to view it, then use the
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Asphalt paving is a definable feature of work (DFOW) on nearly every horizontal contract — roadway overlays, parking areas, airfield shoulders, patch and repair work. The activity combines several of the highest-frequency killers in road construction: workers on foot around haul trucks, pavers, and rollers; live public traffic adjacent to the work zone; 300°F hot-mix asphalt; and summer production schedules that drive heat stress. There is no dedicated asphalt chapter in EM 385-1-1, so this activity hazard analysis is a composite built from Chapter 18 (Vehicles, Machinery, and Mechanized Equipment), Chapter 8 (Signs, Signals, and Traffic Control), Chapter 6 (Hazardous or Toxic Agents and Environments), Chapter 5 (PPE, including high-visibility apparel), and paragraph 9-8.k for melting kettles used in joint and crack sealing.
This AHA example is written for SSHOs, superintendents, and project engineers preparing submittals on USACE and NAVFAC contracts. Under para 2-6.d(1) of EM 385-1-1, an AHA must be prepared by the Competent Person(s) before each activity, reviewed and accepted by the approval authority before work begins (2-6.c(1)), and signed by every involved employee (2-6.d(2)). The example below follows the ENG Form 6206 (SEP 2024) structure: job steps, hazards, controls in hierarchy order, a residual RAC per step, and the equipment/training/inspection table with written CP designations.
All citations on this page are to EM 385-1-1, 15 March 2024, which applies to solicitations issued on or after 15 March 2024 — contracts awarded under the 2014 edition stay on the 2014 numbering until completion, so verify which edition your contract invokes before you copy any paragraph reference. Use this activity hazard analysis as a starting point and edit it to your actual site: mix temperatures, traffic speeds, night-work provisions, and equipment spread all change the controls and the residual RACs.
Risk Assessment Code (RAC) Matrix — EM 385-1-1 (2024)
Severity ↓ / Probability →
Frequent
Likely
Occasional
Seldom
Unlikely
Catastrophic
E
E
H
H
M
Critical
E
H
H
M
L
Moderate
H
M
M
L
L
Negligible
M
L
L
L
L
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: Asphalt Paving
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))
Mobilization: deliver, unload, and stage paver, rollers, and support equipment
Workers struck by or caught between equipment during unloading and positioning
Establish an exclusion zone around lowboy off-loading; only the operator and one designated signal person inside it.
Use a signal person whenever the point of operation is not in full view of the operator, when backing more than 100 ft, or when two or more vehicles back in the same area (18-8.c(14)).
Verify back-up alarms operate automatically on backward motion and are audible above surrounding noise; never remove or disable an alarm (18-8.b(1)).
All crew in Class 2 high-visibility safety apparel minimum around mobile equipment operations (5-8.f(2)).
L
Equipment mechanical failure in service (brakes, steering, safety devices)
Have a Competent Person inspect all machinery and mechanized equipment before it is placed into use, document the inspection on a checklist, and submit it to the KO/COR (18-5.b(1)); re-inspect at least annually and whenever equipment returns to the project.
Operator checks brakes, parking system, tires, horn, steering, seat belts, back-up alarms/lights, and fire extinguisher before each shift (18-5.a(4)).
Maintain inspection, test, repair, and maintenance records at the site, available to the USACE supervisor/KO or COR on request (18-5.a(5)).
L
Unqualified equipment operators
Every operator must be trained, qualified by license/certificate/permit, and designated by the employer in writing before operating (18-3.a).
Operators carry current proof of qualification for the specific equipment and present it to the KO/COR on request (18-3.b).
Operator qualification includes evaluation by an independently certified examiner and a practical operating exam on the equipment (18-3.e).
L
Set up temporary traffic control and work zone protection
Workers struck by live public traffic while placing signs, cones, and barriers
Implement the Traffic Control Plan, developed before work began by a person knowledgeable in temporary traffic control per the MUTCD and state DOT requirements (8-7, 8-8.e).
Install advance warning signs first and work through the device sequence in the direction of traffic flow, with a shadow vehicle protecting workers on foot.
Wear Class 2 (Type R or P) HVSA for traffic up to 35 mph and Class 3 where traffic exceeds 35 mph or visibility is reduced; at night wear Class 3 jacket plus Class E pants or Class 3 coverall as a minimum (5-8.f(2)-(4)).
Display yellow flashing lights on machinery parked on or moving slower than traffic on haul roads (18-8.g(12)).
M
Flagger struck by errant vehicle
Use only flaggers trained per the MUTCD and applicable state DOT requirements (8-3.b).
Flaggers wear hard hat, safety-toed footwear, and high-visibility apparel, and maintain communication with each other and the foreman (8-4.c).
Position flagger stations with an identified escape route, ahead of the taper, never inside the paving train's travel path.
Inspect and correct signage and device deficiencies throughout the shift and document inspections (8-5.a, 8-5.b).
M
Surface preparation: sweeping, milling cleanup, and tack coat application
Dust and particulate exposure during sweeping and cleanup
Have an IH or equivalent Competent Person evaluate operations with potential exposure to hazardous agents and document the evaluation in a written report (6-8.a).
Use vacuum-equipped or water-suppressed sweeping equipment to keep exposures below OELs (6-8.b; 29 CFR 1926.55).
Position workers on foot upwind of sweeping operations where practical.
L
Skin and eye contact with asphalt emulsion tack coat
Keep the product SDS on site and review it in the pre-shift huddle.
Wear chemical-resistant gloves, long sleeves, and safety glasses during distributor operation and hand-wand spraying (Ch 5).
Do not use flammable liquids with a flash point below 100°F to thin material or clean equipment (9-8.k(14)).
L
Hot-mix asphalt delivery: haul truck cycling and truck exchange
Workers on foot backed over by haul trucks
Designate one trained truck-exchange spotter; no other worker on foot behind a backing truck (18-8.c(14)).
Confirm every dump and cargo truck whose body blocks the rear view has an automatic, audible back-up alarm before it enters the site (18-8.b(1)).
Inspect dump trucks brought onto the site for compliance with 18-8.h before they are placed in service and document the inspection (18-5.a(3)).
Establish a marked truck staging area outside the paving train and pedestrian routes.
M
Raised dump bed contact with overhead lines or uncontrolled bed lowering
Survey the haul route and dump zone for overhead power lines before paving begins; prohibit raising beds under lines.
Equip dump trucks with a physical holding device before anyone works under a raised body, and secure hoist levers against accidental tripping (18-8.h(1), 18-8.h(2)).
Arrange tailgate trip handles so the operator stays clear of interference and the truck's crush path (18-8.h(4)).
L
Paving operations: paver, screed, and material transfer
Workers caught between haul truck and paver during hookup
Truck stops short of the paver; the paver moves forward to make contact — never the reverse.
Prohibit standing between the truck and paver hopper during approach; screed operators and dump man stay at their stations.
Do not get on or off the paver or any equipment while it is in motion (18-8.c(1)).
M
Asphalt fume inhalation at the screed and hopper
Base fume controls on the IH/CP hazard evaluation for the operation (6-8.a); exposure above the OEL is prohibited (6-8.b; 29 CFR 1926.55).
Use pavers with engineering fume extraction at the screed/auger where available; position workers upwind of the hopper when spotting trucks.
Institute regular housekeeping and personal decontamination procedures in areas generating fume hazards (6-8.a(4)).
L
Burns from 275-325°F hot-mix asphalt and hot screed surfaces
Wear long-sleeved shirts, long trousers, heat-resistant gloves, and safety-toed boots; no synthetic garments that melt against skin (Ch 5).
Keep non-essential personnel clear of the hopper, auger chamber, and screed; treat all screed surfaces as hot.
Brief burn first aid at the preparatory meeting: cool with water, do not pull hardened asphalt off skin, transport for medical care.
M
Heat stress from combined ambient heat and hot-mix radiant load
Implement the written Thermal Stress Management Plan covering symptoms, first aid, controls, and exposure monitoring (6-7.g); train all employees on thermal stress (6-3.c).
Use a buddy system so workers monitor themselves and co-workers for symptoms (6-8.m(1)).
Provide readily available potable drinking water and allow workers to acclimatize to conditions (6-8.m(2), 6-8.m(3)).
Monitor weather and schedule high-exertion tasks to minimize thermal exposure where possible (6-8.m(4)).
M
Compaction: breakdown, intermediate, and finish rolling
Roller rollover at pavement edges, shoulders, and slopes
Inspect road and shoulder conditions in advance to assure clearances and load capacities are safe for equipment passage (18-5.c).
ROPS required on rollers and compactors with an operator's station (18-8.b(15)); operators wear seat belts (18-8.b(11)).
Keep the drum a safe offset from unsupported edges and drop-offs; mark edge hazards identified in the shoulder inspection.
L
Workers on foot struck by rollers reversing in the rolling pattern
Keep raking and layout crews out of the active rolling pattern; establish a positive eye-contact rule before anyone crosses it.
Verify back-up alarms function on every direction change and are audible over paving-train noise (18-8.b(1)).
All crew in high-visibility apparel per the traffic speed and visibility conditions on site (5-8.f).
L
Handwork and joint sealing: raking, luting, and kettle operations
Burns and fire during melting kettle operation for joint/crack sealant
Never locate asphalt or tar kettles on roofs (9-8.k(8)(c)); place kettles on firm, level, non-combustible foundations, downwind of workers, protected from traffic and tipping (9-8.k(2)).
Maintain at least two fire extinguishers rated 2A:20B:C within 25 ft of working kettles, with a fire-retardant tarp under the kettle (9-8.k(3), 9-8.k(4)).
Kettle must have a tight-fitting lid and calibrated thermometer; hold temperature at least 25° below the material flash point (9-8.k(8)).
Never leave a working kettle unattended — operator on the same level, within eyesight, no more than 25 ft away (9-8.k(7)); operators trained per 9-3.b.
Obtain a hot work permit when on a government installation unless the KO/COR indicates otherwise (9-8.k(5)).
M
Ergonomic strain from repetitive raking, luting, and shoveling of hot mix
Have a CP evaluate lifting, carrying, and repetitive handwork tasks and document hazards and controls in this AHA (6-8.n).
Rotate rakers and lute operators through lower-exertion tasks across the shift.
Pre-stage material with the paver or skid steer to minimize hand-shoveling distance.
L
Demobilization: equipment cleaning, load-out, and traffic control pickup
Workers struck during traffic control device removal
Remove devices in reverse order of installation per the Traffic Control Plan and MUTCD, working against exposure, with a shadow vehicle where traffic remains live (8-7, 8-8.e).
Maintain HVSA class appropriate to traffic speed until all personnel are clear of the roadway (5-8.f).
Use yellow flashing lights and warning devices on any vehicle parked on the highway or shoulder during pickup (18-8.c(15)).
M
Fire and chemical exposure while cleaning asphalt equipment
Do not use flammable liquids with a flash point below 100°F to clean equipment (9-8.k(14)); use approved citrus- or emulsion-based release agents.
Shut down equipment before and during fueling (18-8.g(7)).
Fully lower screeds, blades, and buckets, place controls in neutral, stop engines, and set brakes before cleaning or repair; block equipment held apart by jacks or hoists before working beneath it (18-8.g(8), 18-8.g(21)).
L
Equipment To Be Used
Asphalt paver with screed (fume extraction preferred)
Steel-drum and pneumatic-tire rollers (ROPS and seat belts per 18-8.b(11)/(15))
Dump/haul trucks with automatic back-up alarms and bed holding devices (18-8.b(1), 18-8.h)
Tack coat distributor truck and hand wand
Power broom / vacuum sweeper
Melting kettle with tight-fitting lid and calibrated thermometer, plus two 2A:20B:C extinguishers within 25 ft (9-8.k)
Hand tools: rakes, lutes, shovels, infrared thermometer
Temporary traffic control devices: signs, cones, barricades, arrow board per MUTCD (Ch 8)
10-B:C fire extinguisher on each piece of heavy equipment (18-8.g(19))
Class 2/Class 3 (Type R or P) high-visibility safety apparel per ANSI/ISEA 107 (5-8.f)
Potable drinking water and shaded break area (6-8.m(2))
Training Requirements
Equipment operator training, qualification, and written designation by the employer for each machine type (18-3.a); evaluation by an independently certified examiner including a practical exam (18-3.e)
Current license/permit in the operator's possession for the equipment being operated (18-3.b)
Defensive driver training for operators of government motor vehicles — 4 hours per 4-year period (18-3.d)
Flagger training per the MUTCD and applicable state DOT requirements (8-3.b)
All employees trained on the meaning of workplace signs, tags, and labels (8-3.a)
Thermal stress training for all employees exposed to thermal stressors (6-3.c)
Kettle operator training in proper kettle operation (9-3.b)
Hazard communication on asphalt, tack coat, and sealant SDSs (Ch 6)
AHA review and signature by every involved employee before starting work (2-6.d(2))
Inspection Requirements
CP inspection of all machinery and mechanized equipment before initial use, documented on a signed checklist submitted to the KO/COR; re-inspection at least annually and on return to the project (18-5.b(1))
Daily documented CP inspection of machinery in use — date, inspector, items, PASS/FAIL (18-5.b(2))
Dump truck compliance inspection before placing in service on the site (18-5.a(3), 18-8.h)
Advance inspection of roads and shoulders for clearances and load capacity (18-5.c)
Traffic control signage and device inspections with timely correction of deficiencies, documented (8-5.a, 8-5.b)
Kettle checks each use: thermometer working, lid tight, extinguishers in place, temperature 25° below flash point (9-8.k)
Thermal stressor monitoring per the Thermal Stress Management Plan (6-7.g(4), 6-8.m)
Maintenance, test, and repair records maintained on site and available to the KO/COR (18-5.a(5))
Competent / Qualified Person Requirements
Mobile equipment inspection Competent Person — performs and signs the initial and daily documented equipment inspections (18-5.b); designate in writing by name on the AHA (2-6.d(4))
Industrial hygienist or equivalent CP in industrial hygiene — performs the hazard evaluation for asphalt fume, dust, and thermal exposure (6-8.a) and the ergonomics evaluation (6-8.n)
Person knowledgeable in temporary traffic control — develops the Traffic Control Plan per the MUTCD and state DOT before work begins (8-7)
Trained flaggers per MUTCD/state DOT — qualified persons for signaling and flagging operations (8-3.b, 8-4.c)
Trained kettle operator when joint/crack sealing kettles are used (9-3.b, 9-8.k(1))
Ch 8 — Accident Prevention Signs, Tags, Labels, Signals, and Traffic Control (8-3.b flagger training; 8-7 Traffic Control Plan; 8-8.e/8-8.f traffic control and flagging per MUTCD)
Ch 6 — Hazardous or Toxic Agents and Environments (6-8.a hazard evaluation by IH/CP; 6-8.b exposure standards/OELs; 6-7.g Thermal Stress Management Plan; 6-8.m thermal stressor controls)
Ch 5 — Personal Protective and Lifesaving Equipment (5-8.f high-visibility safety apparel per ANSI/ISEA 107)
Ch 9 — Fire Prevention and Protection (9-8.k heating devices and melting kettles — never located on roofs; 9-3.b kettle operator training)
Applicable OSHA Standards
29 CFR 1926.601 — Motor vehicles (Subpart O)
29 CFR 1926.602 — Material handling equipment (Subpart O)
29 CFR 1926.200-.203 — Signs, signals, and barricades (Subpart G)
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There is no dedicated asphalt paving chapter in the 2024 manual. A paving AHA is a composite of Chapter 18 (Vehicles, Machinery, and Mechanized Equipment), Chapter 8 (traffic control), Chapter 6 (fumes and heat stress), Chapter 5 (PPE and high-visibility apparel), and paragraph 9-8.k if you run a melting kettle for joint or crack sealing.
Does the 2014 or 2024 edition apply to my contract?
Solicitations issued on or after 15 March 2024 fall under the 2024 edition; contracts awarded under the 2014 edition remain on it until completion. The numbering is completely different between editions (2014 used cites like 01.A.14; 2024 uses chapter-paragraph cites like 18-5.b), so never mix them in one AHA. Check your contract's safety clause before writing citations.
Do I need a Traffic Control Plan in addition to this AHA?
Yes, whenever the work affects the normal function of a public or private road. Para 8-7 requires a Traffic Control Plan developed before work begins by a person knowledgeable in temporary traffic control, following the MUTCD and state DOT requirements. The AHA references the plan; it does not replace it.
What should the overall RAC be for asphalt paving?
The overall RAC must not be lower than the highest job step RAC on the AHA (2-6.d(4)(f)). For paving, that is typically M (Medium) driven by struck-by exposure to live traffic and hot-asphalt burn hazards, which stay Moderate-severity even with good controls. An L overall RAC on a paving AHA next to live traffic will usually draw a rejection from the reviewer.
Do I need air monitoring for asphalt fumes?
EM 385-1-1 requires an IH or equivalent CP to evaluate any operation with potential exposure to hazardous or toxic agents and document the evaluation in a written report (6-8.a). Exposure above the OEL is prohibited (6-8.b, 29 CFR 1926.55). For typical open-air paving with modern screed fume controls, the documented evaluation may conclude sampling is unnecessary — but the evaluation itself is not optional.
What class of high-visibility apparel does the paving crew need?
Per 5-8.f, Class 2 (Type R or P) HVSA is the minimum around mobile equipment and traffic up to 35 mph. Class 3 is required when traffic exceeds 35 mph, when visibility is under 50 ft, or when tasks divert attention from approaching traffic. Night work requires at minimum a Class 3 jacket with Class E pants, or a Class 3 coverall.