EM 385 AHA Library

HVAC Installation Activity Hazard Analysis Example — EM 385-1-1

HVAC installation activity hazard analysis (AHA) example for EM 385-1-1 (2024): job steps, hazards, controls, and RACs for USACE and NAVFAC contractors.

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HVAC and mechanical equipment installation is a definable feature of work (DFOW) on nearly every federal vertical construction project: setting air handlers, RTUs, chillers, and condensing units; hanging ductwork; brazing refrigerant piping; running hydronic lines; making electrical tie-ins; and pressure testing the completed systems. There is no single dedicated chapter in EM 385-1-1 for HVAC work — this activity hazard analysis is a composite that pulls its requirements from Chapter 14 (material handling), Chapter 16 (load handling equipment), Chapter 10 (welding, cutting, and brazing), Chapters 11 and 12 (electrical work and control of hazardous energy), Chapter 20 (pressurized equipment and systems), Chapters 21, 22, and 24 (fall protection, work platforms, and safe access), and Chapter 34 (confined space entry for plenums and mechanical pits).

This AHA example is written for mechanical contractors and their SSHOs working on USACE and NAVFAC projects, where an accepted AHA is required before work begins on each activity (para 2-6.c(1)) and every involved employee must review and sign it (para 2-6.d(2)). The page walks through a realistic eight-step installation sequence with the hazards, controls written to the hierarchy in para 2-6.b (elimination through PPE), and residual Risk Assessment Codes for each step, plus the equipment, training, inspection, and competent person entries the ENG Form 6206 format calls for. One trap specific to this DFOW: para 20-8.e(3) requires a supplemental preparatory meeting to re-review the test procedures and AHA when pressure testing occurs two or more months after the initial piping preparatory meeting — a gap that is almost guaranteed on an HVAC scope.

All citations on this page use the EM 385-1-1, 15 March 2024 edition (chapter-paragraph format, e.g., 20-8.e(3)); contracts solicited before 15 March 2024 generally remain on the 2014 edition with its old section-style numbering (e.g., 01.A.14) until completion, so verify which edition your contract invokes before copying any AHA example.

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: HVAC / Mechanical Equipment Installation

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, equipment delivery, offloading, and staging of HVAC units and materialsStruck-by or crushed-by during forklift/telehandler offloading of AHUs, RTUs, and duct bundles
  • Permit only operators trained, qualified, and designated according to 29 CFR 1910.178 — classroom plus practical operation, on the same type of truck used on the job — to operate forklifts or telehandlers (18-3.f, 18-8.i(3)).
  • Verify each forklift and telehandler meets ANSI/ITSDF B56.1 and has its rated capacity posted, clearly visible to the operator; never exceed the ratings (18-8.i, 18-8.i(2)).
  • Establish a marked exclusion zone around the offloading area and prohibit workers from standing between the load and fixed objects or under any raised load.
  • Use a trained spotter with agreed hand signals when the operator's view of the travel path or set-down point is obstructed.
L
Back and shoulder strains from manually handling duct sections, VAV boxes, and pipe
  • Train all crews on safe lifting techniques before manual handling begins (14-3.a).
  • Substitute mechanical handling — pallet jacks, duct lifts, carts — for manual carries wherever the route allows.
  • Enforce two-person lifts for duct sections and equipment over roughly 50 lb and plan carry routes clear of debris before the lift.
L
Collapse of stacked materials or failure of storage racking in the laydown area
  • Inspect storage systems, racking, blocking, and pallets per the manufacturer's instructions and remove from service any component showing deterioration or weakness (14-5.a).
  • Stack duct and equipment on level, compacted ground with blocking, and limit stack heights so materials cannot topple into walkways.
  • Inspect work and laydown areas daily for housekeeping and record the findings in daily inspection reports (14-5.c).
L
Crane and hoist operations — setting RTUs, chillers, and AHUs on roofs and padsDropped or shifted load from rigging failure or improper hitch during equipment picks
  • Document the crane operator's certifications, qualifications, and written designation in the AHA and submit it for KO/COR acceptance before the pick (16-6.a); notify the KO or COR within 24 hours of the crane entering the site (16-5.c).
  • Have a CP perform and document the shift inspection of the crane before every operation, at the beginning of each shift, and after any operator change; do not lift until deficiencies are corrected (16-5.e(2)(a)).
  • Verify rigging capacity against the manufacturer's certified equipment weight, use safety latch-type hooks and shackles (15-5.g(8)), and control the load with tag lines (16-8.v(6)).
  • Immediately remove from service any LHE found unsafe until the condition is corrected (16-5.d).
M
Workers struck by the swinging load or caught in the swing radius
  • Barricade accessible areas within the swing radius of the rotating superstructure and mounted items before hoisting begins (16-8.v(11)(b)).
  • Prohibit all personnel from working or passing under suspended loads; sequence other trades out of the lift zone during picks.
  • Maintain continuous, agreed communication between the operator, rigger, and signal person using a standard signal system — hand signals within 100 ft, radio beyond or without line of sight (16-8.v(4)).
M
Crane contact with overhead power lines or rooftop obstructions
  • Identify overhead lines and rooftop obstructions in the lift planning and AHA before mobilizing the crane, and define the operating envelope for the LHE (16-8.v(8); Ch 11).
  • Coordinate with the installation to de-energize or maintain required clearance distances from any energized lines near the pick path, using a dedicated spotter when working near the clearance limit.
L
Installing ductwork, piping, and equipment at height from MEWPs, scaffolds, and laddersFalls of 6 ft or more from MEWPs, scaffolds, mezzanines, roof edges, and floor openings
  • Provide fall protection at the 6-ft (1.8 m) threshold for all work covered by the manual — 4 ft on USACE-owned or operated permanent facilities (21-8.a(1) and 21-8.a(2)).
  • Apply the fall protection hierarchy of controls when selecting the protective method for each task (21-8.b), preferring elimination and passive barriers such as guardrails over personal fall arrest.
  • Have each authorized person inspect personal fall protection equipment before each use, with documented CP inspections at least semi-annually, and remove from service any equipment subjected to a fall (21-5.a).
  • Verify MEWP operators have both general and equipment-specific training (22-3.d) and that the operator surveys the area and confirms a firm, level surface, manufacturer loading, and any required outriggers before elevating (22-4.c).
M
Scaffold collapse or ejection from an incomplete or defective scaffold
  • Have the scaffold CP inspect all scaffold components for visible defects before each work shift and after any occurrence that could affect structural integrity (22-5.a).
  • Tag every scaffold before use with the CP's name, signature, and inspection dates, stating whether it is safe, incomplete, or unsafe (22-5.c).
  • Train every employee who works from a scaffold on its hazards, maximum intended load, and proper material handling (22-3.a).
L
Falls from damaged or misused ladders during hanger and trim work
  • Inspect ladders for visible defects before each use and immediately tag damaged ladders 'DO NOT USE' and withdraw them from service (24-5.b).
  • Inspect all accessways daily to ensure they are free of hazards and obstructions (24-5.a).
  • Substitute podium ladders or MEWPs for extension ladders on repetitive overhead duct-hanger work where floor conditions allow.
L
Brazing, soldering, and welding of refrigerant and hydronic piping (hot work)Fire ignition of combustible construction materials by brazing flame, sparks, or slag
  • Obtain a hot work permit before hot work on federal installations unless the USACE supervisor/KO or COR indicates otherwise (10-8.d(2)).
  • Survey the area before starting to confirm no combustible materials within 35 ft (10.7 m) and no flammable vapors or oxygen-enriched atmospheres; move the work or the combustibles, or shield what cannot be moved (10-8.d(3), 10-8.d(4)).
  • Identify the CP for welding and the fire watch in the AHA; maintain the fire watch a minimum of 30 minutes after the exposure ends (10-6.d).
  • Keep suitable fire extinguishing equipment in the immediate vicinity, in a constant state of readiness (10-8.d(1)).
L
Toxic fume and oxygen-displacement exposure when brazing in mechanical rooms or shafts
  • Develop the AHA to identify the metals, filler alloys, and welding process in use so fume hazards can be evaluated (10-6.a, 10-6.b).
  • Naturally or mechanically vent all brazing so exposures stay within acceptable limits, with local exhaust ventilation in enclosed or confined spaces (10-8.c(2)); where ventilation cannot control exposure, use respiratory protection selected under the Ch 5 program (10-3.a).
  • Never braze on piping or vessels under pressure or containing refrigerant; recover and purge lines first.
L
Compressed gas cylinder fire or violent release (oxy-fuel and nitrogen cylinders)
  • Inspect torches, cables, shut-off valves, couplings, and tips before each use and remove defective equipment from service (10-5).
  • Keep oxygen cylinders, valves, regulators, and fittings free of oil and grease and never handle them with oily hands or gloves (20-8.d(17), 29 CFR 1926.350).
  • Secure all cylinders upright, cap them when not in regulator service, and segregate oxygen from fuel gas in storage.
L
Electrical rough-in and equipment tie-ins to building powerShock or arc flash from unexpected energization while connecting units, VFDs, and disconnects
  • Before any tie-in on a system that produces, uses, or stores hazardous energy, develop the Site-Specific Energy Control Plan with its Hazardous Energy Isolation Procedures (HIPs) and AHAs and obtain KO or COR acceptance; all Authorized Individuals must review them (12-8.a(3)).
  • Lock out every energy isolating device capable of being locked out; use tagout with equivalent supplementary protection only where lockout is not possible (12-8.b(1)).
  • Assign electrical connections only to Qualified Persons trained at a minimum to NFPA 70E, with documented, verifiable training (11-3.b).
  • Verify zero energy at the point of work with a rated tester before contact, per the accepted isolation procedure and 29 CFR 1926.417.
M
Shock from damaged cords and temporary power feeding drills, threaders, and vacuum pumps
  • Provide GFCI protection for personnel on all 125-volt, 15-, 20-, and 30-amp receptacle outlets supplying temporary power and on all circuits serving portable and semi-portable electric tools (11-8.l(9)).
  • Inspect all portable flexible cords and cables before use on each shift and remove damaged cords from service (11-5.d).
  • Test GFCIs monthly, and test temporary distribution systems for polarity, ground continuity, and ground resistance before initial use and after modification (11-5.e).
L
Work inside air plenums, ducts, crawl spaces, and mechanical pitsHazardous atmosphere or engulfment/entrapment in confined spaces (plenums, large ducts, pits)
  • Evaluate and classify each plenum, duct section, crawl space, and pit against the Ch 34 confined space criteria before anyone enters; identify all existing and potential hazards in the AHA (34-6.a).
  • For permit-required spaces, have the Entry Supervisor develop and submit a written Site-Specific Confined Space Plan — including the permit process, atmospheric monitoring procedures, communication methods, and rescue plan — for acceptance before work begins (34-7.b).
  • Conduct documented pre-entry inspections of atmospheric testing and monitoring equipment, including calibration records, plus ventilation, retrieval, and rescue equipment (34-5.a through 34-5.j).
  • Train all personnel working in or around confined spaces before first assignment and at least annually, including permit completion and rescue exercises (34-3.a, 34-3.b).
M
Contact with unidentified in-duct hazards (energized heaters, rotating dampers/fans) during interior duct work
  • Apply the SSECP and equipment-specific isolation procedures to lock out duct heaters, fan motors, and damper actuators before interior work (12-8.a(3)).
  • Instruct all incidental personnel in the prohibition against restarting or reenergizing locked- or tagged-out equipment (12-3.d).
L
Pressure testing of refrigerant piping and hydronic systemsViolent release of stored energy — fitting blow-off, pipe whip, or projectile failure during pneumatic testing
  • Do not use pressurized gases or air for structural integrity or leak testing except when permitted by the manufacturer's specifications or an applicable code (20-8.e(1)); use hydrostatic testing where the system allows.
  • Have a CP develop the test procedures, submit them to the KO or COR for acceptance, and supervise the testing; all workers performing the test must know the procedures, hazards, and controls (20-8.e(2)).
  • If acceptance testing occurs two or more months after the initial piping preparatory meeting, conduct a supplemental preparatory meeting to re-review the test procedures and AHA before testing (20-8.e(3)).
  • Barricade an exclusion zone around the test section sized to the stored energy, and never exceed design pressure or defeat relief devices (20-8.a(3), 20-8.a(4)).
M
Failure of regulators, hoses, or gauges on nitrogen test rigs
  • Inspect and performance-test pressurized equipment before placing it in service and after any repair or modification (20-5.a(1)).
  • Have a CP perform and document visual inspections of temporary or portable pressurized equipment at least every six months (20-5.a(3)).
  • Tag any pressurized equipment found unsafe as 'UNSAFE PRESSURIZED SYSTEM - DO NOT USE' at the controls and remove it from service until corrected (20-8.a(1)).
L
System startup, refrigerant charging, commissioning, and demobilizationRefrigerant release causing frostbite injury or oxygen displacement in mechanical rooms
  • Charge and recover refrigerant only with trained technicians using recovery equipment rated for the refrigerant, following the SDS handling requirements.
  • Ventilate mechanical rooms during charging and monitor enclosed spaces where a large release could displace oxygen (see Ch 34 for enclosed-space evaluation).
  • Wear insulated gloves and eye protection when connecting or breaking charging hoses.
L
Contact with rotating fans, belts, and drives during commissioning checks
  • Apply the accepted hazardous energy isolation procedures before removing guards or working on drives; only Authorized Individuals may perform LOTO (12-8.b(2)).
  • Reinstall all guards and verify interlocks before functional testing, and keep hands, tools, and clothing clear during rotation checks.
L
Slips, trips, and lacerations during cleanup and demobilization
  • Inspect work areas daily for adequate housekeeping and record findings in the daily inspection reports (14-5.c).
  • Remove scrap duct, banding, and pipe cutoffs to designated containers daily; sheet metal edges are cut-resistant-glove work.
  • Inspect accessways daily to keep exit routes clear through demobilization (24-5.a).
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 HVAC installation?

There is no dedicated HVAC chapter in the 2024 edition. HVAC installation is a composite activity: Ch 14 governs material handling and storage, Ch 16 the crane and hoist picks, Ch 10 brazing and welding hot work, Chs 11 and 12 the electrical tie-ins and energy isolation, Ch 20 pressure testing, Chs 21/22/24 work at height and access, and Ch 34 any plenum or pit that meets the confined space definition. Your AHA should cite the specific paragraphs from each chapter that apply to your scope.

Does pressure testing need its own AHA or preparatory meeting?

Pressure testing belongs in the HVAC AHA, but Ch 20 adds two gates: a CP must develop the test procedures and submit them to the KO or COR for acceptance (20-8.e(2)), and if acceptance testing happens two or more months after the initial piping preparatory meeting, you must hold a supplemental preparatory meeting to re-review the test procedures and the AHA before testing (20-8.e(3)). Pneumatic testing is only allowed where the manufacturer's specifications or an applicable code permit it (20-8.e(1)).

Do I need a hot work permit to braze refrigerant lines?

Yes — hot work permits are required on federal installations when hot work is performed, unless the USACE supervisor/KO or COR indicates otherwise (10-8.d(2)). The AHA must also identify the CP for welding and the fire watch, and the fire watch must remain in place a minimum of 30 minutes after the exposure ends (10-6.d).

Is an air plenum or large duct a confined space?

It can be. Evaluate each plenum, duct section, crawl space, and mechanical pit against the Ch 34 confined space criteria before entry. If a space is permit-required, the Entry Supervisor must develop a written Site-Specific Confined Space Plan and submit it for acceptance before work begins (34-7.b), and each entry needs an AHA identifying all existing and potential hazards (34-6.a).

What should the overall RAC be for HVAC installation?

The overall RAC must not be lower than the highest job step RAC on the AHA (para 2-6.d(4)(f)). For a typical HVAC installation with crane picks, work at height, energized tie-ins, and pneumatic testing, several steps reasonably carry a residual M even after controls, so the overall RAC is usually Medium. An overall L would suggest the hoisting, fall, and stored-energy hazards were underrated.

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

Solicitations issued on or after 15 March 2024 fall under the 2024 edition; existing contracts generally remain on the 2014 edition until completion. The two editions use completely different numbering — the 2024 manual cites chapter-paragraph (e.g., 20-8.e), while 2014 used section style (e.g., 01.A.14) — so confirm the edition in your contract before reusing citations from any AHA example.

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