EM 385-1-1: The Corps of Engineers Dive Safety Manual
By Ray Whitfield, ADCI-certified commercial dive supervisor. Reviewed by Dana Whitcombe, technical reviewer.
Cathodic Protection & Anodes | Offshore & Subsea Diving I remember a cold morning in 2009, working a Corps lock on the Monongahela. The resident engineer wanted to know why we needed two stand-by divers for a straightforward downstream inspection. I pulled the EM 385-1-1 from the truck and opened to the diving chapter. He thought it was a suggestion. It wasn't. EM 385-1-1 is the US Army Corps of Engineers' safety and health requirements manual. Every contractor on a Corps project signs up to it, and for divers that means a whole lot more than just showing up with a tank and a sense of adventure. It's the manual that tells you how to run a commercial dive operation on federal waterways, dams, and buildings. If you're doing work for USACE, it's the rules of the game, and it's on your contract. Don't make the mistake of thinking it's just another reference. The Corps enforces it. They'll stop the job over a missing signature or a bad air test, and they're right to. I've seen too many close calls that were preventable with thirty minutes of paperwork and a real dive plan.
What EM 385-1-1 Covers
The manual runs about 1,400 pages, call it. The diving section is long, and it's not a standalone code. It doesn't replace OSHA's 29 CFR 1910 Subpart T, which governs commercial diving in general industry. It also pulls in 29 CFR 1926 Subpart Y for construction-related diving. What EM 385-1-1 does is add a layer of Corps-specific requirements on top of those. It forces you to be specific about your dive plan, your equipment, your personnel, and your emergency procedures. For a typical inspection job - say an underwater bridge inspection, which falls under 23 CFR 650.311 for the engineering side - the diving side still runs through EM 385-1-1. The manual requires an ADCI-accredited dive contractor, an ADCI-certified dive supervisor on site, and divers with current commercial diver cards, not recreational certifications. It also requires you to have the Supervisor's Manual, the dive plan, and the emergency action plan at the dive location, not back in the office. The manual also says what constitutes acceptable breathing air, how to test it, and how often. Most of that matches OSHA, but the Corps is picky about documentation. You have to log air tests, equipment inspections, and daily diver check-ins. It's not just a good idea; it's a contractual requirement.
The Dive Plan and the People Who Sign It
Every USACE dive job needs a written dive plan that says what you're doing, where, when, how deep, what mixture, who's handling the gas, what the standby diver is doing, and what the emergency recovery procedure looks like. The manual wants the dive supervisor to sign it, and the company to have a formal safety program that backs it up. You don't get to make it up on the fly. I've worked for contractors who think a dive plan is a checklist you fill out at the dock. On Corps work, that plan gets reviewed, and if it's sloppy, they'll send it back. They also require a pre-dive site assessment and have you identify hazards like overhead loads, currents, and differential pressure. The Corps knows delta P gets people killed. They've had their own divers in lock chambers and intakes. You learn to respect it. One thing that surprises guys coming from non-Corps jobs: the manual requires the dive supervisor to be an ADCI-certified dive supervisor specifically. A lot of states don't require that level of training. On USACE work, it's in the contract, and they check. Same for the divers themselves. They want to see ADCI commercial diver certification, not a PADI rescue card. I've had arguments about that more than once.
How EM 385-1-1 and the Contract Work Together
Think of EM 385-1-1 as the baseline safety code for all Corps contracts. It covers everything from excavation to hazardous energy control. The diving chapter is the one I care about, but it lives in a bigger book. Your contract also might invoke other standards like AWS D3.6M for underwater welding, or NFPA 70E for electrical work near water. The manual ties it together. It's also worth noting that the Corps regularly updates the manual. EM 385-1-1 gets revised, and the current version includes a bunch of changes from earlier editions. You've got to be working from the latest edition, not the one you trained with in 2005. I keep a couple copies in the truck, and a PDF on my phone. It's that important. In practice, this means you need a safety program that actually addresses the work site. The manual requires a site-specific Hazard Assessment and a job safety analysis (JSA). For missions, a contractor might try to copy a generic JSA from a different job. The Corps folks see right through that. They want your name, your site, your equipment, your water.
Where I See Guys Go Wrong
The most common mistake is treating EM 385-1-1 as optional if the water is shallow or the 'job is simple'. A quick bridge inspection at 15 feet still needs a commercial diver, a functioning comms setup, a standby, and a real plan. The depth doesn't change the standard. A close second is not verifying equipment inspection records. The manual says your diving hat and other gear have to be inspected per the manufacturer's instructions. I've seen Kirby Morgan helmets with expired service tags on jobs. That's a stop-work event. Another one: the standby diver. EM 385-1-1 requires a standby diver who is dressed and ready to enter the water, not just 'available'. I've been on sites where the standby was in the truck, and that's a failure. If the working diver has an umbilical, the standby should be a dressed diver with a separate supply. And the surface crew needs to know how to manage the situation without panicking. Also, don't ignore the paperwork. The manual requires daily log entries, including date, time, location, personnel, gas volumes, and any incidents. It might seem like overhead, but that log is what saves you in a dispute or an audit. It also shows the Corps you're running a professional operation. If you can't produce the paperwork, you can't prove you did anything right.
Frequently Asked Questions
Is EM 385-1-1 the same as OSHA 1910 Subpart T? No. OSHA 1910 Subpart T is federal regulation. EM 385-1-1 is a USACE manual that adds to it. On Corps jobs, you have to meet both. The manual explicitly requires compliance with Subpart T, and then adds its own requirements for dive plans, supervisor certification, and site safety. Do I need an ADCI certification for every diver on a USACE project? In practice, yes. The manual requires the dive contractor to be ADCI-accredited and the dive supervisor to be ADCI-certified. It also expects divers to hold commercial diver certification, and ADCI is the recognized standard. A recreational cert like PADI or NAUI will not cut it. How do I get the current version of EM 385-1-1? You can download it as a PDF from the public USACE publication site. Look for EM 385-1-1, Safety and Health Requirements Manual. The edition changes, so check the publication date. Contractors and agencies also carry it in hard copy. What happens if I don't follow EM 385-1-1? The Corps can issue a stop-work order, fine the prime contractor, or remove the dive contractor from the job. More seriously, it can get someone killed. These requirements aren't there to make paperwork. They're based on fatalities and serious accidents.