Understanding Workplace Safety & Building Compliance For Exterior Maintenance Contractors.

Understanding Workplace Safety & Building

Compliance

For Exterior Maintenance Contractors

Rope Descending Systems were introduced to the window cleaning

industry in the late 1950’s

When one window cleaning company in a

city started using RDS, all the other companies

quickly followed to stay competitive

Today they’re probably being used at all your mid to high rise buildings

Window Cleaner’s developed the components and use of RDS without any real

influence from regulatory agencies or professional expertise

Unfortunately, a lot of bad habits and techniques were

created

Because so many window cleaning companies were using RDS and a lot of bad practices were going on, OSHA got involved

in 1991 to create a safety regulation for the use of the equipment.

OSHA published a Memorandum and sent it to all Regional Offices in the US to assist in regulating the use of Rope Descent Systems

The Memo was basic in nature and addressed the following 8 important RDS techniques:Training of employees in the use of the

equipment before it is used;

Inspection of equipment each day before use;

Proper rigging, including sound anchorages and tiebacks, in all cases, with particular emphasis on providing tiebacks when counterweights, cornice hooks, or similar non-permanent anchorage systems are used;

Use of a separate fall arrest system (including, sit harness, or full body harness; rope grab or similar device; lifeline; and anchorage (all of which are completely independent of the friction device and its support system), so that any failure in a friction device, support seat (or harness), support line, or anchorage system will not affect the ability of the fall arrest system to operate and quickly stop the employee's fall;

All lines installed (such as by using knots, swages or eye splices) when rigging descent control devices shall be capable of sustaining a minimum tensile load of 5,000 pounds.

Provisions are made for rescue;

Ropes are effectively padded where they contact edges of the building, anchorage, obstructions, or other surfaces which might cut or weaken the rope;

Provisions are made for intermittent stabilization for descent in excess of 130 feet.

The OSHA Regulations helped but they didn’t address all the known hazards

faced by the window cleaning industry & user’s of RDS

Especially when it comes to PROPER RIGGING !!!

Improvising became Dangerously Popular

Window Cleaners

were economically forced to

guess where and how to rig their lines on a roof

Accidents Were Occurring on a Regular Basis

The Industry needed to remedy itself and a new American National Safety Standard was published recently and it is going to affect the way windows

are cleaned at your property !!

Published in December of

2001, the ANSI/IWCA I-14 Standard was

developed to help raise the level of

safety in the window cleaning

industry

The Window Cleaner and the Property Manager !!!

The I-14 focuses it’s safety guidelines on the two most

affected parts of the window cleaning industry

Because Window Cleaners perform their trade at numerous worksites, the I-14

Standard helps to point out that workplace safety is a “shared

responsibility” Window cleaning

contractors can only control the safety of the equipment they bring to the site or

building

Building & Property Managers have control of the

overall safety of their building

An Even BIGGER CONCERN is that window cleaners may perform their

services at your building 2, 3, 4, even up to 6 times a year !!!

Are you prepared for that much exposure ???

One Important Reason for You to COMPLY

Is to Help Prevent

Accidents

More Reasons for YOU to COMPLY

To Prevent OSHA

Citations

And to Reduce Exposure to

Costly Litigation that may arise if an accident were

to occur


Since it’s publication, OSHA is now enforcing window cleaning safety by referencing the I-14 Safety Standard and they have done so numerous times. Samples can be viewed at the OSHA Website at www.osha.gov


If you feel that your building meets OSHA requirements, remember that OSHA now enforces the I-14 Standard. As a result, you’ll want to be sure your facility is in compliance with this new safety standard.

Work with your Contractor by Exchanging Written

Assurances These are as simple as documents on company letterhead that verify:

•The Contractors Safety Ability and;•The Safety of Your Facility

Written Assurances You Should have from the Window Cleaning Contractor

1. Proof the Contractor will perform services in accordance with all applicable Local, State and Federal Regulations.2. Documented, well trained and competent personnel to perform the services.

3. Specifications for their transportable equipment along with maintenance and inspection criteria.

4. A Written Work Plan that Identifies:

a) Where suspended access equipment will be used;b) Where ground barricades will be placed;c) What anchor points on the roof will be used;d) Any other recognized safety hazards

Written Assurances You Should Provide in Return

1. That any permanent equipment (i.e., powered platform) on the building has been inspected and maintained in accordance with industry standards.

How To: If your facility has a permanent powered platform, its manufacturer can provide inspections and maintenance…your window cleaning contractor may also be able to assist you with finding the manufacturer or another company that could provide these services.

2. If transportable suspended equipment is being used at your building, you need to have a “certified” anchor system in place. This enables workers to have separate and properly located anchors for both their primary work line and backup safety line.

Written Assurances You Should Provide in Return

What is a Certified Anchor System??

Since OSHA now enforces the I-14 Safety Standard, a “certified” anchor system needs to meet I-14 guidelines.

According to the I-14 Standard, roof safety anchors must be easily identifiable; provide adequate fall protection; in the proper location for the suspended worker; able to support 5000lbs and; used correctly.

To become “certified” a licensed professional engineer needs to provide their stamp on a roof layout drawing that shows the anchors are properly located; that they meet the load requirements and; how they are to be used.This engineer stamped drawing

constitutes a Certified Anchor System and this certification lasts for 10 (ten)

years.


This eliminates the guesswork which has led to improper and unsafe rigging practices.

Sample of a Certified Anchor System

What a Certified Anchor System Looks Like


Once your Anchor System is “Certified” for the 10 year period, the anchors should be

inspected annually by a competent person. An engineer or their stamp is not required

for annual inspections.

Proper Anchoring SystemFAQ # 1: The Contractor brings rigging equipment to my building. Do I need a “certified anchor system” if they use their own anchoring equipment?

Proper Anchoring SystemFAQ # 1-ANSWER: Because the equipment is transportable, the contractor is required to attach the rigging equipment to a “sound” anchor on the roof (aka-tieback). Furthermore, the suspended worker needs an additional and separate anchorage for their safety or backup line. A certified anchor system would still be required.

Proper Anchoring System

FAQ # 2: There are steel fixtures on my roof that I think are being used, can they be certified for 10 years ?

Location…..Location…..Location !!!


Anchor Location is CRITICAL !!!

Ideally, the anchors should be in a straight line from where the worker goes over the side of the roof or building. However, engineering calculations allow for a variance of 15 degrees in each direction from a true straight line off the anchorage point.

This ensures that the weight of the worker will not cause any movement of the rope on the roof edge once they’re suspended.

As stated earlier, users of RDS need two completely separate and independent anchors. One for their primary descending or work line. The other is for the secondary backup or safety line.

This provides double protection for the worker !!!

Proper Anchoring SystemAnchor Location is CRITICAL !!!

If anchorage points are too close to the building edge and/or too far apart, workers may string them together using a horizontal line as demonstrated by diagram on the left, and shown in use on the right.


A

A

B

B

C= 180lbs

C

If a horizontal line is run from A to B as shown, and C= 180lb. The force on A & B will be nearly 6000lbs which is over the 5000lb capacity.

The I-14 Standard states that a horizontal line must be designed by and; installed under the supervision of a licensed professional engineer.

Here’s one important reason why…

Here’s a more important reason why…

U.S. Department of Labor

www.osha.gov

General Duty Standard Citation 305549388/ 01001

I nspection Reporting ID Open Date SIC Establishment Name

305549388 0111400 05/15/2003 7349 Unicco Integrated Facilities Services

Section 5(a)(1) of the Occupational Safety & Health Act of 1970: The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees, in that employees were exposed to a fall hazard.

(a) Location: Centre Plaza, Pemberton Square, Boston On 05/15/03, The anchorages for personal fall arrest systems and descent control devices consisted of a singe 5/16 inch horizontal wire rope static line and this single line was improperly secured, thereby exposing employees to fall hazards.

Among other means, feasible means of abatement would be: 1) Anchorage points for personal fall protection must be independent of the descent control device and its support system, and the horizontal lifeline must be adequate for the intended load. 2) Consult a qualified professional engineer to design a horizontal line and determine that it is capable of supporting the anchorage load factor by horizontal dynamic loading of the cable, based on the nominal strength of the wire rope and end terminations. 3) Ensure a competent person follows the manufacturer's instructions for wire rope clips regarding proper arrangement of the wire rope clips, correct spacing between each clip, and installation torque when forming turnback eyes. Always include the use of thimbles when forming eyes with wire rope clips, and ensure that malleable cast iron clips shall not be used. 4) Implement a comprehensive safety program that includes hands on employee training in the proper use of approved rigging, fall protection systems, and rescue techniques. 5) Perform an evaluation of all English speaking and non-English speaking employees to

have full comprehension of the company safety training manual, manufacturer's instructions, warnings and design limitations of the RDS equipment and ANSI / IWCA I - 14.1 2001 standard, and related safety regulations. 6) Ensure supervisors are qualified and proficient in safe working procedures and training in the use of equipment in accordance with the manufacturer's instructions, warnings and design limitations. 7) Ensure a competent person inspects all anchor points and rigging being used prior to the start of work, before each use, and ensure all working practices and procedures for window cleaning operations are performed under supervision of a competent person. 8) Remove from service all wire rope with distorted structure such as crushed or kinking conditions.

9) Submit a Plan of Service to the building owner or his agent to address all safety concerns and to identify the use of anchorage points, prior to the service being performed. Nothing precludes the company from using alternative abatement methods which are as equally or more protective for the employee.

Two Window Cleaners were killed when the horizontal line that was strung between anchor points failed. Boston, MA April, 2003


FAQ # 2-ANSWER: If additional anchors were added to these roofs, the existing fixtures could be included into a certifiable roof safety anchor system.


FAQ # 3: There are steel supports on my roof that I think are being used, can they be certified for the 10 year period ?

If the supports are tied to directly and not strung together, they may be to far away from

where the worker needs to be suspended to perform their work, as shown in this photo.


If this rope was loaded by the weight of the worker….it would slide down the roof edge to here, (about 30 feet) until it came within 15 degrees of a straight line from the post it’s attached to.

Because this roof edge is concrete, it would abrade right through the rope as it slides along this edge towards its final resting point.

Proper Anchoring SystemFAQ # 3-ANSWER: There are steel supports on my roof that I think are being used, can they be certified for the 10 year period ?

If additional anchors were added to this roof and identifiable anchors added to the existing

supports, all could be included into a certifiable roof safety anchor system.

Proper Anchoring SystemFAQ # 4: I receive an engineer stamped letter every year that says the steel supports on my roof meet the OSHA 1910.66 Regulation for Fall Arrest…Is that a roof certification ??

First, a roof certification requires that a licensed professional engineer needs to provide their stamp on a roof layout drawing that shows the anchors are properly located; that they meet the load requirements and; how they are to be used. Once you receive this, it is a compliant roof certification and does not need to be done each year because it actually lasts for a 10 year period.

Proper Anchoring SystemFAQ # 4: I receive an engineer stamped letter every year that says the steel supports on my roof meet the OSHA 1910.66 Regulation for Fall Arrest…Is that a roof certification ??

Second, the OSHA 1910.66 Regulation is for Permanent Powered Platforms and their fall arrest anchor points on a building. If Rope Descent Systems are being used at your building, this Regulation can’t be applied mainly because the anchors are located far apart (20-30 ft.) for a powered platform and not where they need to be for a Rope Descending System.

How To: If transportable suspended equipment such as Rope Descending Systems are being used at your building, you should have a roof and building survey done. A proper survey will address all areas of your building for fall protection, anchor placement, load requirements and most importantly, compliance with the ANSI I-14 Standard which is now being enforced by OSHA.

Understanding Workplace Safety & Building Compliance For Exterior Maintenance Contractors.

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