Demolition Activity Hazard Analysis
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Demolition on USACE and Department of Defense projects is among the highest-risk Definable Features of Work a contractor can perform. The controlled dismantling of buildings and structures involves nearly every category of construction hazard simultaneously: structural collapse, falling objects, hazardous material exposure, electrical contact, fire, dust inhalation, and heavy equipment strikes. EM 385-1-1 Section 23 requires a comprehensive engineering survey before any demolition begins, a written demolition plan prepared by a competent person, and an Activity Hazard Analysis that assigns Risk Assessment Codes to each phase of the operation. The initial RAC for uncontrolled demolition is routinely Catastrophic in severity — a partial structural collapse during demolition is unsurvivable for workers in the impact zone.
Federal demolition projects on military installations carry additional hazards not present on typical commercial sites. Buildings constructed during the World War II era through the 1980s frequently contain asbestos-containing materials (ACM) in insulation, flooring, roofing, and fireproofing. Lead-based paint is common on pre-1978 structures. Some facilities may contain polychlorinated biphenyls (PCBs) in electrical equipment, mercury in switches and thermostats, or radioactive materials in laboratory buildings. The engineering survey required by EM 385-1-1 Section 23.A must identify all hazardous materials present in the structure, and the demolition AHA must include specific controls for each material encountered. On installations with historical ordnance use, the survey must also address the potential for unexploded ordnance (UXO) in soil or embedded in building foundations.
The demolition AHA must address each phase of the operation as a distinct set of work steps: utility disconnection and verification, hazardous material abatement, removal of salvageable items, structural bracing and shoring of elements to remain, selective demolition or mechanical demolition of the structure, debris handling and hauling, and site grading. Each step carries its own hazard profile and RAC rating. The AHA must designate a demolition competent person who understands structural loading, connection types, and the sequence-dependent nature of demolition — removing the wrong element at the wrong time can trigger a progressive collapse that no amount of PPE can protect against.
Disclaimer
This content is provided for general informational and educational purposes only. It is not a substitute for a site-specific Job Safety Analysis conducted by a qualified safety professional familiar with your workplace conditions, equipment, and personnel. OSHA citations, BLS statistics, and hazard controls referenced here may not reflect the most current standards or apply to your specific situation. Always consult current OSHA regulations, manufacturer guidelines, and a competent person before beginning work. Health & Safety Systems LLC assumes no liability for actions taken based on this content.
Definable Feature of Work (DFOW)
Building & Structure Demolition
Complete or selective demolition of buildings, structures, foundations, and site improvements including all preparatory work (hazmat abatement, utility disconnection, structural bracing) through final debris removal and site grading. Excludes explosive demolition, which requires a separate specialized AHA.
Typical Duration: 2-8 weeks
EM 385-1-1 References
Section 23.A: Engineering Survey and Demolition Plan
Requires a written engineering survey by a competent person before demolition begins, covering structural conditions, hazardous materials, utility locations, and the planned sequence of demolition. The survey must be documented and available on site.
Section 23.B: Preparatory Operations
Covers utility disconnection and capping, hazardous material abatement, bracing of walls and floors to be retained, protection of adjacent structures, and installation of dust and debris containment.
Section 23.C: Demolition of Structural Elements
Specifies requirements for removal of floors, walls, steel structures, and concrete elements including the requirement to maintain structural stability throughout the demolition sequence.
Section 23.D: Mechanical Demolition
Covers demolition using excavators, wrecking balls, and other mechanical equipment including equipment positioning, exclusion zones, and operator qualifications.
Section 23.E: Debris Handling and Removal
Addresses chute construction, material dropping zones, dust suppression, truck loading, and environmental controls for demolition debris including segregation of hazardous materials.
Section 23.F: Adjacent Structure Protection
Requires protection of structures, utilities, and site features adjacent to the demolition area including monitoring for settlement, vibration limits, and dust control.
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Start Free TrialRisk Assessment Code (RAC)
The RAC matrix combines hazard severity and probability to assign a risk level before and after controls are applied. This AHA demonstrates risk reduction from initial to residual conditions.
Initial Risk (Before Controls)
Extremely High (1)
Severity: Catastrophic | Probability: Likely
Residual Risk (After Controls)
Low (5)
Severity: Marginal | Probability: Seldom
Step-by-Step AHA Breakdown
Step 1: Complete engineering survey and demolition plan
Hazards
- Unidentified structural deficiencies
- Unknown hazardous materials
- Unlocated utilities
- Inaccurate as-built drawings
Controls
- Competent person conducts field survey of structural conditions, connections, and load paths
- Environmental consultant performs hazmat survey (asbestos, lead, PCBs, mercury)
- Obtain and verify all utility records; physically trace utilities to disconnection points
- Develop written demolition sequence that maintains structural stability at each phase
Step 2: Disconnect and verify all utilities
Hazards
- Electrocution from live electrical service
- Gas leak or explosion
- Flooding from water or sewer lines
- Telecommunications damage
Controls
- Coordinate utility disconnection with all utility providers and installation DPW
- Physically verify de-energization of electrical service at the meter and at the transformer
- Cap gas lines at the main and verify zero pressure
- Cap water and sewer connections and verify no residual pressure
Step 3: Perform hazardous material abatement
Hazards
- Asbestos fiber release
- Lead dust exposure
- PCB contamination
- Mercury vapor exposure
Controls
- Licensed abatement contractor performs removal per EPA NESHAP and state regulations
- Establish regulated areas with critical barriers and negative air pressure
- Personal air monitoring for workers during abatement
- Waste manifesting and disposal per RCRA at licensed facilities
Step 4: Install structural bracing and shoring
Hazards
- Premature structural collapse during bracing
- Workers exposed to unstable elements
- Inadequate bracing design
Controls
- Structural engineer designs bracing and shoring for elements to remain in place
- Install bracing from outside the potential collapse zone using mechanical means where possible
- Competent person inspects bracing installation before proceeding to demolition phase
- Mark and protect bracing elements to prevent accidental removal during demolition
Step 5: Establish exclusion zones and perimeter controls
Hazards
- Unauthorized entry into demolition zone
- Debris striking bystanders
- Vehicle intrusion
Controls
- Install perimeter fencing with locked access points around entire demolition area
- Establish exclusion zone minimum 1.5 times the building height from the structure
- Post warning signs at all access points
- Assign flaggers at access points during active demolition
Step 6: Selective interior demolition
Hazards
- Floor collapse
- Wall collapse
- Falling debris from above
- Dust inhalation
- Noise exposure
Controls
- Work from top down — never undercut structural supports
- Shore or brace floors above before removing supports below
- Wet methods for dust suppression during interior demolition
- Continuous atmospheric monitoring for dust levels
- Limit number of workers inside structure to essential personnel only
Step 7: Mechanical demolition of structure
Hazards
- Structural collapse in uncontrolled direction
- Equipment rollover or tip-over
- Flying debris striking equipment cab or nearby workers
- Underground obstructions
Controls
- Excavator operator maintains minimum distance equal to equipment reach from the structure
- All personnel cleared from exclusion zone during mechanical demolition
- Demolish from top down, never pull structure toward the machine
- Use excavators with reinforced cabs (FOPS and OPG rated)
- Spotter assists operator with blind spots and overhead hazards
Step 8: Foundation and slab removal
Hazards
- Striking underground utilities missed during survey
- Concrete dust (silica) exposure
- Equipment damage from rebar
- Cave-in of adjacent excavation
Controls
- Pothole all utility crossings before excavating foundations
- Water suppression on concrete breaking to control silica dust
- Respiratory protection (minimum N95, APF 10) during concrete breaking
- Slope or shore excavation walls when removing deep foundations
Step 9: Debris loading, hauling, and disposal
Hazards
- Struck by during loading operations
- Overloaded trucks
- Contaminated debris mishandled
- Traffic hazards on haul route
Controls
- No workers in truck bed during loading
- Verify truck weight does not exceed road limits
- Segregate hazardous materials (ACM, lead, PCBs) for licensed disposal
- Establish haul routes with traffic control plan approved by installation
Step 10: Site grading, erosion control, and demobilization
Hazards
- Uneven terrain creating trip and vehicle hazards
- Soil erosion and stormwater runoff
- Residual hazardous materials in soil
Controls
- Grade site to positive drainage per project plans
- Install erosion and sediment controls per SWPPP
- Conduct final environmental survey of exposed soil for contamination indicators
- Remove perimeter fencing only after site is graded, stabilized, and accepted
Competent & Qualified Persons
EM 385-1-1 requires designated competent and qualified persons for specific activities. These individuals must have the training, experience, and authority to identify hazards and take corrective action.
Demolition Competent Person
Must have demonstrated experience in demolition engineering, structural assessment, and demolition sequencing. Must be capable of identifying structural hazards, evaluating load paths, and recognizing the conditions that precede structural failure. Has authority to stop work immediately when conditions deviate from the demolition plan.
EM 385-1-1 Reference: Section EM 385-1-1 Section 23.A
Site Safety and Health Officer (SSHO)
Must hold 30-hour OSHA Construction certification, have minimum 5 years construction safety experience, complete EM 385-1-1 40-hour training, and be designated in the Accident Prevention Plan. Must be on-site during all demolition operations.
EM 385-1-1 Reference: Section EM 385-1-1 Section 01.A.17
Structural Engineer
Licensed Professional Engineer who designs bracing, shoring, and the demolition sequence for complex structures. Reviews the engineering survey and certifies that the planned demolition sequence will maintain structural stability throughout the operation.
EM 385-1-1 Reference: Section EM 385-1-1 Section 23.A
Hazardous Materials Supervisor
Certified asbestos abatement supervisor (state-licensed), trained in lead abatement per EPA RRP, and knowledgeable in PCB handling per TSCA. Responsible for all hazmat abatement operations during the preparatory phase of demolition.
EM 385-1-1 Reference: Section EM 385-1-1 Section 06.G
Equipment, Training & Inspection Requirements
Required Equipment
Training Requirements
- OSHA 10-hour Construction Safety (minimum for all workers; 30-hour for supervisors and competent persons)
- EM 385-1-1 40-hour training for SSHO and demolition competent person
- Demolition-specific training covering structural assessment, demolition sequencing, and hazard recognition
- Asbestos awareness training (2-hour minimum) for all workers; 32-hour abatement worker training for those performing abatement
- Equipment operator certification for excavators and loaders used in demolition operations
Inspection Requirements
- Daily structural assessment by demolition competent person before work begins, verifying no overnight changes in structural conditions
- Continuous monitoring of structure during mechanical demolition for signs of unplanned movement or instability
- Daily air monitoring results reviewed by SSHO for silica, asbestos (if ACM present), and lead (if LBP present)
- Pre-shift equipment inspection of excavators, attachments, and rigging per EM 385-1-1 and manufacturer requirements
- Weekly documented inspection of perimeter controls, exclusion zones, and warning signage
Applicable OSHA Standards
29 CFR 1926.850
Preparatory Operations
Requires an engineering survey of the structure by a competent person before demolition begins, covering the condition of framing, floors, and walls, and the possibility of unplanned collapse.
29 CFR 1926.852
Chutes
Requires enclosed chutes for debris removal when material is dropped more than 20 feet and specifies chute design, gate operation, and the requirement to barricade the discharge area.
29 CFR 1926.854
Removal of Walls, Masonry Sections, and Chimneys
Prohibits workers from working on top of a wall being demolished and requires that masonry walls over 25 feet in height not be permitted to fall uncontrolled on floors or structures unless designed to resist the impact.
29 CFR 1926.856
Removal of Walls, Floors, and Material with Equipment
Covers mechanical demolition requirements including equipment positioning, minimum safe distances from the structure, and the prohibition on workers in the structure during mechanical demolition.
29 CFR 1926.858
Removal of Steel Construction
Requires that steel construction be dismantled column length by column length, with connections not removed until members are supported, and prohibits cutting structural supports until the area above is cleared.
Required Personal Protective Equipment
Frequently Asked Questions
What is an engineering survey for demolition and who performs it?
An engineering survey is a formal assessment of the structure to be demolished, required by both OSHA 29 CFR 1926.850 and EM 385-1-1 Section 23.A. It covers the structural condition of framing, floors, walls, and connections; the presence of hazardous materials (asbestos, lead, PCBs, mercury); the location of all utilities; and any conditions that could cause unplanned collapse. On USACE projects, the survey must be performed by a competent person with demolition experience, and complex structures typically require a licensed Professional Engineer. The survey results drive the demolition plan and AHA.
Why is demolition typically rated Extremely High on the initial RAC?
Uncontrolled demolition involves Catastrophic severity (potential for multiple fatalities from structural collapse) combined with Likely probability (structural failures during demolition are common when controls are absent). This combination produces an Extremely High (1) initial RAC on the EM 385-1-1 risk assessment matrix. The high initial rating reflects the reality that demolition without engineered controls — no survey, no sequence plan, no exclusion zones, no competent person — has a high likelihood of catastrophic failure. The purpose of the AHA is to demonstrate that systematic controls reduce this to an acceptable residual RAC.
How does the demolition AHA address hazardous materials like asbestos?
The AHA must include work steps for hazardous material identification (the engineering survey), abatement before demolition begins, and controls for any residual contamination discovered during demolition. Asbestos abatement is typically a separate DFOW with its own AHA, but the demolition AHA must reference it and establish stop-work procedures if previously unidentified ACM is encountered during demolition. Air monitoring for asbestos fibers during demolition is required when the structure contained ACM, even after abatement is complete, to verify that residual material is not being disturbed.
What is the exclusion zone requirement for mechanical demolition?
EM 385-1-1 requires an exclusion zone around any structure being mechanically demolished. The minimum recommended distance is 1.5 times the height of the structure or the portion being demolished, measured from the base of the structure. All personnel except the equipment operator must be outside this zone during active mechanical demolition. The zone must be physically marked with barricades or fencing — tape alone is not acceptable. Flaggers or signal persons are required at access points to prevent unauthorized entry.
Can selective demolition and mechanical demolition happen simultaneously?
No. EM 385-1-1 Section 23 and OSHA 29 CFR 1926.856 prohibit workers from being inside a structure while mechanical demolition equipment is operating on it. The demolition sequence in the AHA must clearly delineate phases: interior selective demolition (with workers inside) must be complete in a given area before mechanical demolition begins in that area. This is a frequent violation on demolition projects and a common trigger for OSHA citations and USACE stop-work orders.