What Is an Activity Hazard Analysis (AHA)?
Updated 2026-06-23
An Activity Hazard Analysis (AHA) is a structured, written hazard analysis prepared for each definable activity of work on USACE and many federal construction projects — breaking the activity into steps, identifying the hazards in each step, and assigning the controls, required equipment, and competent persons before the activity begins. It is the federal government's formal, required version of the hazard analysis that general industry calls a JHA or JSA. This guide explains what an Activity Hazard Analysis is, what it must contain, when it applies, and how it differs from a standard JHA.
What an AHA actually is
An Activity Hazard Analysis is required by name and format under EM 385-1-1, the U.S. Army Corps of Engineers safety and health manual. Like a Job Hazard Analysis, it breaks an activity into its steps, identifies the hazards in each step, and assigns controls. What distinguishes the AHA is that it is mandatory, it follows a defined format, and it must be prepared, reviewed, and accepted before the relevant activity starts.
The AHA is built around the concept of a "definable feature of work" or activity — a discrete phase of the project such as excavation, steel erection, or concrete placement. Each such activity gets its own AHA, prepared by the contractor responsible for it, reviewed by the appropriate parties, and accepted before that activity can begin. The AHA is a living document: when the scope, conditions, or personnel change, it is updated and re-reviewed.
What an AHA must contain
EM 385-1-1 specifies the elements an AHA must address, which go beyond a basic JHA. A complete AHA typically includes:
- The activity or definable feature of work being analyzed
- The principal steps of the activity, in sequence
- The hazards associated with each step
- The controls for each hazard, following the hierarchy of controls
- The equipment to be used, and any inspection requirements for it
- The training and certifications required for the workers performing the activity
- The competent and qualified persons required for the activity
- The applicable standards and requirements
The inclusion of required equipment, inspections, training, certifications, and named competent persons is part of what makes the AHA more prescriptive than a typical JHA — it documents not just the hazards and controls, but the qualifications and resources required to perform the activity safely.
A simple AHA structure
| Element | What it captures |
|---|---|
| Activity | The definable feature of work (e.g., trenching, steel erection) |
| Steps | The principal steps in sequence |
| Hazards | The hazards in each step |
| Controls | The control for each hazard, per the hierarchy |
| Equipment / inspections | Equipment used and its inspection requirements |
| Training / competent persons | Required certifications and named competent/qualified persons |
The format may be a Corps-provided template or a contractor format that captures the required elements, but the content requirements come from EM 385-1-1.
When an AHA applies
An AHA is required when EM 385-1-1 governs the work — most commonly on USACE contracts, on federal contracts that incorporate EM 385-1-1 by reference, and where a project owner or prime contractor requires it as a contract condition. On these projects, an accepted AHA must be in place for each definable activity before that activity begins, and work cannot proceed on an activity until its AHA is reviewed and accepted.
Because the AHA is a contract requirement on Corps work, satisfying OSHA is not enough — the AHA must meet EM 385-1-1's specific content and format requirements. This is one of the most visible places where federal-project safety documentation goes beyond the general-industry baseline.
How an AHA differs from a JHA
The AHA and the JHA share the same core method, but the AHA is more prescriptive in several ways: it is required by name rather than encouraged, it follows a defined format, it must be formally reviewed and accepted before work, and it documents required equipment, inspections, training, certifications, and competent persons that a basic JHA may omit. In short, the AHA is the JHA's more formal, more detailed, contract-mandated cousin. For a full comparison of the terms, see JHA vs JSA vs AHA.
From the field: getting an AHA accepted
In fourteen years across federal, heavy civil, and industrial projects — including extensive USACE and federal work — the AHA is where contractors new to Corps projects most often stumble, because they treat it like the JHA they are used to and find it rejected in review. The recurring gaps are the elements that go beyond a basic JHA: the AHA that names hazards and controls but omits the required equipment inspections, the training and certifications for the crew, and the specific competent and qualified persons for the activity. A Corps reviewer expects all of these, and an AHA missing them gets sent back.
The AHAs that get accepted cleanly share a few traits. They are tied to a real definable feature of work, not a vague catch-all. They name the actual competent persons by role and confirm their qualifications. They list the equipment and its inspection requirements. And they cite EM 385-1-1 and the relevant standards correctly for the activity. On the projects I have run, the practical advice is to build the AHA from the EM 385-1-1 requirements outward — start from what the manual requires the AHA to contain, and make sure every element is addressed — rather than starting from a general-industry JHA template and hoping it satisfies the Corps. The AHA that is built to the manual's requirements is the one that gets accepted and keeps the activity on schedule.
The bottom line
An Activity Hazard Analysis is the required, formatted hazard analysis that EM 385-1-1 mandates for each definable activity on USACE and many federal projects — covering the steps, hazards, and controls like a JHA, but adding required equipment, inspections, training, certifications, and named competent persons, and requiring formal review and acceptance before work begins. It is the JHA's more prescriptive federal cousin, and on a Corps job, building it to the manual's specific requirements is what keeps the work moving.
Frequently asked questions
What is the difference between an AHA and a JHA?
They use the same method — breaking an activity into steps, identifying hazards, and assigning controls — but the AHA is the formal, required version under EM 385-1-1 on federal projects. The AHA follows a defined format, must be reviewed and accepted before work, and documents required equipment, inspections, training, certifications, and competent persons that a basic JHA may not include.
When is an AHA required?
When EM 385-1-1 governs the work — most commonly on USACE contracts, on federal contracts that incorporate the manual by reference, or where an owner or prime contractor requires it. On those projects, an accepted AHA must be in place for each definable feature of work before that activity begins.
What is a "definable feature of work"?
A discrete phase or activity of the project, such as excavation, steel erection, or concrete placement. Each definable feature of work gets its own AHA, prepared by the responsible contractor and accepted before that activity starts.
Does meeting OSHA satisfy the AHA requirement?
No. On a Corps job, the AHA must meet EM 385-1-1's specific content and format requirements, which go beyond OSHA's general expectations. An analysis that satisfies OSHA but omits the AHA's required equipment, training, and competent-person elements will not be accepted.
Related JHAs
- What Is a JHA? — the general-industry equivalent
- What Is EM 385-1-1? — the manual that requires the AHA
- JHA vs JSA vs AHA — how the three terms compare
- What Is a Pre-Task Plan? — applying the analysis at the point of work
Written by Mustafa Tok, CSP, ASP, CHST — OSHA Authorized Outreach Trainer with 14+ years of international construction safety experience across federal, heavy civil, and industrial projects.