EM 385 AHA Library

Site Clearing & Grubbing AHA Example (EM 385-1-1) — Free Download

Free EM 385-1-1 (15 Mar 2024) AHA example for site clearing and grubbing: job steps, hazards, controls, residual RACs, in ENG Form 6206 format.

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Site clearing and grubbing is usually the first definable feature of work (DFOW) on a USACE or NAVFAC construction contract: felling and removing trees, cutting and chipping brush, ripping out stumps and root mats, and hauling vegetative debris off site before mass grading begins. It concentrates several of the highest-energy hazards on any project into one activity — falling trees, chainsaws, brush chippers, and heavy dozers and excavators working on unimproved terrain — which is why the government approval authority will read this activity hazard analysis closely at the preparatory meeting.

This AHA example is written to EM 385-1-1, 15 March 2024, the current edition for solicitations issued on or after that date; contracts awarded under the 2014 edition stay on the 2014 edition (and its 01.A-style citations) until completion, so confirm which edition your contract invokes before you submit. Per para 2-6, the AHA must be prepared by a Competent Person, list detailed job steps with hazards and controls in hierarchy order, assign a residual Risk Assessment Code (RAC) to each step, carry an overall RAC no lower than the highest step RAC, and be reviewed and signed by every involved employee before work starts.

The download follows the ENG Form 6206 (SEP 2024) layout: the job steps, hazards, controls, and residual RAC table below, plus the equipment, training, and inspection blocks and the employee sign-off sheet. Use it as a starting point for your own activity hazard analysis — edit the steps to match your actual means and methods, your equipment spread, and your named Competent and Qualified Persons before submitting it to the KO or COR.

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: Site Clearing and Grubbing

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, utility locates, and pre-clearing site surveyStrike on unknown underground utilities (electric, gas, communications, water) while grubbing stumps and ripping root mats
  • Obtain a dig permit from the local public works organization or other authority having jurisdiction before any ground-disturbing work, processed through the USACE supervisor/KO or COR (25-8.f(1)).
  • Contact utility companies and responsible authorities to locate and mark all underground utilities within the clearing limits before mobilizing equipment (25-8.f(2)).
  • If grubbing or root ripping will occur within 3 ft of a marked utility, physically verify the utility location by non-destructive methods (hand digging or vacuum excavation) and neutralize the system before mechanical work (25-8.f(3)).
M
Contact with overhead power lines during tree survey and equipment mobilization
  • Have the Qualified Tree Worker make a visual inspection for electrical hazards before any tree maintenance or removal activity begins; treat all conductors as energized (31-8.b).
  • Establish and brief a minimum 10 ft separation distance from energized conductors for all tree workers who are not qualified line-clearance trimmers (31-8.b(4)).
  • Where trees cannot be safely cleared of electrical hazards, arrange with the power company to de-energize, test, isolate, and ground the conductors before work (31-8.b(1)).
M
Exposure to poisonous plants, ticks, and stinging insects during walking survey
  • Instruct all employees exposed to poison ivy, poison oak, and similar irritant plants on the hazards, protective clothing, and first aid, per OSHA 1926.604(a)(1).
  • Require long sleeves, gloves, and insect repellent for ground crews; identify and flag heavy irritant-plant areas during the pre-work walkdown.
  • Stock the first-aid kit with wash/decontamination supplies and brief the crew on reporting any allergic reaction immediately.
L
Establish work zone, access control, and staging areasUnauthorized personnel or public entering the felling and equipment operating area
  • Implement access control to the work site as required by the Tree Maintenance and Removal Plan (31-7.e): flag or barricade the clearing limits and post signage at access points.
  • Instruct each worker on the exact tasks to be performed; workers not directly involved in felling must keep clear of the work area (31-8.f(3)).
  • Establish felling paths at least twice as long as the height of the tallest tree being felled, to account for limbs and debris thrown after impact, before any felling starts (31-8.f(2)).
L
Slips, trips, and falls on uneven, vegetated, or muddy terrain
  • Walk down and flag holes, drop-offs, and unstable ground before equipment and foot traffic enter the area.
  • Require leather safety-toe boots with ankle support for ground crews and maintain cleared walking paths to work locations.
  • Suspend ground operations on steep or saturated slopes until conditions are evaluated by the Competent Person.
L
Equipment inspection and setup (dozers, excavators, chipper, chainsaws)Operating defective or unguarded clearing equipment
  • Have the Competent Person inspect all machinery and mechanized equipment before it is placed into use, document the inspection on a checklist, sign it, and submit it to the USACE supervisor/KO or COR (18-5.b(1)).
  • Operator checks each vehicle and machine before each use (not more than once per shift) for brakes, tires, horn, steering, seat belts, operating controls, and safety devices such as back-up alarms (18-5.a(4)).
  • Verify dozers and similar clearing equipment have FOPS guards, canopies, or grills appropriate to the clearing operation, certified by the manufacturer or a licensed engineer (18-8.b(14)), and ROPS with seat belts (18-8.b(15), 18-8.b(11)).
  • Immediately tag out and remove from service any equipment found unsafe until corrected by a Qualified Person (18-8.a(2)).
L
Chainsaw or chipper mechanical failure and missing safety devices
  • Inspect and test chainsaws before each use per the manufacturer's instructions; remove defective saws from service (13-5.a).
  • Verify each chainsaw has a functioning clutch, automatic chain brake, throttle trigger latch, stop switch, rear hand guard, chain catcher, and spark arrestor per ANSI/OPEI B175.1/A1 (13-8.i(1)).
  • Verify the chipper's infeed protection: an 85-inch infeed hopper with flexible anti-kickback device, or a quick-stop and reversing device on mechanical infeed models, plus an ignition locking device (31-8.g(2)(b), (c), (f)).
  • Chock or otherwise secure trailer-mounted chippers when detached from the truck (31-8.g(2)(h)).
L
Caught-in equipment during field repairs and adjustments
  • Do not remove guards or safety devices except for immediate repairs, and only after the equipment is de-energized and hazardous energy control (LOTO) procedures are implemented (18-8.b).
  • Restrict tests, maintenance, and repairs to a Qualified Person working per the manufacturer's instructions, with all work documented (18-8.a(1)).
L
Tree felling and removalStruck by falling tree, limbs, or thrown debris
  • Before felling, the Qualified Tree Worker inspects each tree and the surrounding area for hangers, dead limbs, lean, root-mass stability, barber-chair potential, lodged trees, and foreign objects such as fence wire or nails (31-5.c).
  • Work to an accepted Tree Maintenance and Removal Plan identifying tree sizes, direction of fall, landing zone, and a retreat path for the sawyer (31-7.a(1), 31-7.d).
  • Establish felling paths at least twice the height of the tree; where that distance cannot be secured, limb the tree first (31-8.f(2)).
  • On trees over 5 inches diameter, use a proper notch and back cut — never slicing or ripping cuts — with notch depth no more than one-third the trunk diameter (31-8.f(5)).
  • Give an audible warning just before the tree falls and confirm all personnel are out of range; workers move away from the butt as the tree starts to fall (31-8.f(8), (11)).
M
Chainsaw cuts and kickback
  • Only operators trained per the manufacturer's recommendations in PPE, fueling, cutting techniques, kickback avoidance, and binding reaction may run chainsaws (13-3.c).
  • Start saws on the ground with the chain brake engaged — never drop start — and only after all co-workers are clear (13-8.i(4), (5), (3)).
  • Hold the saw with both hands during all cutting and never cut above shoulder height (13-8.i(8), (10)).
  • Wear chainsaw PPE: hard hat, eye protection, cut-resistant leg chaps, safety boots, and hearing protection; anyone assisting the sawyer at a stump wears the same level of PPE (31-8.a(1)-(3)).
  • Do not fuel a running or hot saw, and do not start it within 10 ft of the fuel container (13-8.i(7)).
L
Electrocution felling trees near energized lines
  • Assign only a Qualified Line-Clearance Tree Trimmer (or supervised trainee) to work in close proximity to conductors that cannot be de-energized (31-8.b(2)).
  • All other tree workers maintain at least 10 ft separation from energized conductors per table 11-4 (31-8.b(4)).
  • Use wedges, block and tackle, rope, or cable to control fall direction away from lines — except where an electrical hazard exists — and limb trees so they fall clear of wires (31-8.f(9)).
M
Brush cutting and chippingCaught in brush chipper infeed
  • Operate the chipper per the manufacturer's instructions with all operators trained per para 31-3.d (31-8.g(2)(a)).
  • Never place hands, arms, feet, or any body part on the feed table while the chipper is operating or the rotor is turning; feed with push-sticks that can be consumed by the chipper or with long branches (31-8.g(2)(j)).
  • Feed from the side of the centerline (curbside on roadways) and turn away immediately as the brush is taken into the rotor (31-8.g(2)(k)).
  • Workers feeding the chipper wear eye protection and must not wear loose clothing, gauntlet gloves, rings, or watches (31-8.g(2)(i)).
  • Never raise or remove the discharge chute or cutter housing cover while any part of the chipper is turning (31-8.g(2)(m)).
M
Struck by flying chips and ejected material
  • Do not feed stones, nails, sweepings, or other foreign material into the chipper (31-8.g(2)(l)).
  • Verify the chipper is equipped with a discharge chute of sufficient length or design to prevent contact with the blade (31-8.g(2)(e)).
  • Keep cutting bars and blades sharp, properly adjusted, and maintained per the manufacturer's recommendations (31-8.g(2)(g)).
L
Struck by hand-carried brush and hand tool injuries
  • Keep the site clear of accumulated brush and logs so no hazards are created at the work site (31-8.g(1)).
  • Organize and position multiple workers cutting on the same area so the actions of one worker do not create a hazard for another (31-8.h(2)(a)); give an audible warning before limbs are dropped (31-8.h(1)(b)).
  • Carry hand tools in bags, belts, or sheaths designed for them — not in pockets or boot tops (31-8.c(2)).
L
Grubbing — stump and root removal with dozer/excavatorEquipment rollover on slopes, stumps, and uneven ground
  • Grub with crawler equipment fitted with ROPS (18-8.b(15)) and require operators to wear seat belts at all times (18-8.b(11)).
  • Work slopes up-and-down rather than across where practicable, and have the Competent Person evaluate steep or unstable areas before equipment enters.
  • Comply with OSHA 1926.602 for earthmoving equipment operations, including brakes, access, and audible alarms.
L
Operator struck by falling or flying objects (springing roots, thrown stumps, falling snags)
  • Equip all dozers, tractors, and similar equipment used in clearing operations with guards, canopies, or grills appropriate to the nature of the clearing work, certified by the manufacturer or a licensed engineer (18-8.b(14)).
  • Fell or remove dead snags and lodged trees identified in the pre-work tree inspection before grubbing beneath them (31-5.c(1)(k)).
  • Keep ground personnel outside the swing radius and travel path of grubbing equipment; use a warning device or signal person where persons are endangered by moving equipment (18-8.b(2)).
L
Underground utility strike while ripping roots and pulling stumps
  • Grub only within areas cleared by the dig permit and utility markout (25-8.f(1), (2)).
  • Within 3 ft of any marked utility, stop mechanical grubbing and physically verify the utility by non-destructive means before continuing (25-8.f(3)).
  • Brief operators on the utility markings daily and stop work immediately if unidentified pipe, conduit, or cable is uncovered; notify the SSHO and the USACE supervisor/KO or COR.
M
Ground personnel struck by reversing equipment
  • Verify back-up alarms are installed, audible above surrounding noise, operate automatically through the entire backward movement, and are never removed or disabled (18-8.b(1)).
  • Use a signal person when the point of operation is not in full view of the operator, when backing more than 100 ft, on hazardous terrain, or when two or more vehicles back in the same area; otherwise the operator walks behind the vehicle before backing (18-8.c(14)).
  • Require high-visibility apparel for all ground personnel working around equipment.
L
Loading and hauling debris off siteWorkers struck by loaders and dump trucks during loading
  • Workers stand clear of vehicles being loaded to avoid being struck by spillage or falling material (25-8.e(2)).
  • Drivers leave the cab during loading when exposed to danger from suspended loads or overhead loading equipment unless the cab is adequately protected (18-8.c(16)(a)).
  • Use a signal person for truck backing in the loading area when the operator's view is obstructed (18-8.c(14)).
L
Unstable or oversized loads and unsafe dump trucks on haul routes
  • Do not load vehicles in a manner that obscures the driver's view ahead or to either side or interferes with safe operation (18-8.c(16)(b)).
  • Inspect and document all dump trucks brought onto the project before they are placed in service (18-5.a(3)).
  • Secure logs and debris loads per DOT requirements before entering public roads and confirm the designated haul route with the KO or COR.
L
Demobilization and site cleanupResidual brush, logs, and stump holes left as hazards for follow-on trades
  • Keep the site clear of brush and logs so no hazards are created at the work site; complete debris removal before releasing the area (31-8.g(1)).
  • Backfill or barricade and flag stump holes and depressions before demobilizing, and document remaining hazards in the turnover to the next DFOW.
  • Update the AHA and notify the approval authority if site conditions at turnover differ from those assumed (2-6.d(5)).
L
Caught-in/struck-by while loading equipment onto transport trailers
  • Use a signal person to guide equipment onto trailers whenever the operator's view of the point of operation is not full (18-8.c(14)).
  • Keep all personnel clear of the loading ramp path and between towed and towing vehicles except when hooking or unhooking (18-8.c(12)).
  • Distribute, chock, tie down, and secure the equipment on the trailer (18-8.c(16)(c)); do not move unusually heavy loads until the driver has the required permits, verified vehicle and load weights, and a designated route (18-8.c(13)).
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 site clearing and grubbing?

There is no single clearing-and-grubbing chapter — the 2024 manual never even uses the word "grubbing." The activity is governed by a combination of Ch 18 (Vehicles, Machinery, and Mechanized Equipment — including 18-8.b(14) FOPS guards and canopies specifically for equipment used in clearing operations), Ch 31 (Tree Maintenance and Removal, including 31-8.f felling and 31-8.g brush removal and chipping), and Ch 13 (Hand and Power Tools, for chainsaws). OSHA's 1926.604 Site Clearing and 1926.602 apply in parallel.

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; contracts awarded under the 2014 edition remain on that edition until completion. The two editions number requirements completely differently (2024 uses chapter-paragraph cites like 31-8.g; 2014 used cites like 01.A.14), so check your contract before copying citations. This example is written to the 2024 edition.

Do I need a Tree Maintenance and Removal Plan in addition to the AHA?

Yes, if your clearing involves tree maintenance or removal — which almost all clearing does. Para 31-7 requires a plan developed by or under the direction of a Qualified Tree Worker covering the activity description, tree sizes and fall directions, anticipated hazards, personnel assignments, a retreat path, and access control, submitted for USACE approval or KO/COR acceptance before work. The AHA does not substitute for it.

What should the overall RAC be for clearing and grubbing?

The overall RAC must not be lower than the highest residual step RAC (2-6.d(4)(f)). With the controls in this example, tree felling near structures or power lines, chipper operations, and utility strikes during grubbing typically remain Medium after controls, so most clearing and grubbing AHAs carry an overall residual RAC of M. Remember the 2024 severity scale is Catastrophic/Critical/Moderate/Negligible — "Marginal" is 2014 language.

Do I need utility locates just to clear vegetation?

Cutting brush at grade may not disturb soil, but grubbing does — stump pulling and root ripping penetrate well below grade. Para 25-8.f requires a dig permit, utility company locates and markings, and physical verification by non-destructive means when working within 3 ft of a marked utility, before that mechanical work starts. Treat the grubbing phase like any other excavation for locate purposes.

Who has to sign the clearing and grubbing AHA?

The Competent Person who prepared it, the approval authority who accepts it before work begins (2-6.c(1)), and every employee involved in the activity, who must review and sign it before starting work (2-6.d(2)). New crew members sign before they join the work, and the AHA stays on site for 12 months or the life of the contract (2-6.d(3)).

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