Pro-Bel Reports Building Owners/Property Managers Now Responsible for Anchorages for Window Cleaning - Cite Federal OSHA Final Rule

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Walking Working Surfaces Regulations now requires anchorages to be certified and prohibits window cleaning activities until proof in writing can be provided by the Building Owner.

Pro-Bel Roof Anchors

Anchorages must be identified, tested, maintained and certified at intervals of not greater than 10 years.

OSHA has released a long-awaited update to its standard on walking-working surfaces.

̴ Brent LaPorte, National Inspections Manager, Pro-Bel Enterprises Limited

On Friday November 18, 2016 the Federal Register published proposed amendments to the walking-working surfaces regulations.

The entire document is over 500 pages of explanations, tables, charts and the new regulations.

So what does it all mean and who does it affect?

The Regulation affects anyone in general industry that happens to be working on any surface, vertical or horizontal. So, in short, it affects us all.

The real question most building owners, property managers and employers should be asking is: "What does it all mean to me?"

This article will answer that, specifically with respect to the use of rope descent systems (RDS) and window cleaning.

OSHA has previously required the use of personal fall protection equipment whenever a worker was exposed to a fall hazard of 4' or greater. However, OSHA did not specifically address window cleaning, more specifically the use of RDS (rope descent systems).

Up until now these systems were regulated through a series of memorandums, letters of interpretation and by referencing other more stringent standards (ANSI - I-14).

OSHA has addressed this with amendments to the regulations which make the use of this common equipment more clear.

There are many sections to review and comment on, but the section below is the most pressing and will require planning, budgeting and implementing.

1910.27: Scaffolds and rope descent systems-

(a) Scaffolds. Scaffolds used in the general industry must meet the requirements in 29 CFR part 1926, subpart L (Scaffolds).

(b) Rope descent systems- (1) Anchorages. (i) Before any rope descent system is used, the building owner must inform the employer in writing that the building owner has identified, tested, certified and maintained each anchorage so it is capable of supporting at least 5,000 pounds (268 kg), in any direction, for each employee attached. The information must be based on an annual inspection by a qualified person and certification of each anchorage by a qualified person, as necessary, and at least every 10 years.

(ii) The employer must ensure that no employee uses any anchorage before the employer has obtained written information from the building owner that each anchorage meets the requirements of paragraph (b)(1)(i) of this section. The employer must keep the information for the duration of the job.

(iii) The requirements in paragraphs (b)(1)(i) and (ii) of this section must be implemented no later than November 20, 2017.

This small section of the regulations will have an impact on building owners, property managers and employers who utilize RDS as a means of maintaining their buildings- specifically window washing contractors.

The regulation language is quite strong in that it establishes that it is the building owner's responsibility to do the following, in writing, prior to any RDS being used:

1) Identify the anchorages- (via roof plan showing approved anchorages)

2) Test- (through load testing either in the manufacturing facility or in the field)

3) Certify- (based on inspection, calculations and/or testing)

4) Maintain- (correct any deficiencies during or immediately after annual inspection)

5) Recertify as necessary, at least every 10 years- (load test at the engineer of record's discretion)

Section (ii) then indicates that the employer (window washing contractor) must ensure that no employee uses any anchorages before the requirements above are met.

The last part of this section notes that this must be implemented no later than November 20, 2017; One year away.

Pro-Bel inspects and certifies almost 2000 buildings in the United States annually, however, many buildings where anchorages have been installed have not been inspected or certified in years.

There are other buildings which have no certified anchorages to speak of.

This regulation comes into effect in January 2017 and full compliance must be met by November 2017 so it would be wise to schedule the OSHA mandated annual inspections and 10 Year re-certification now.

Per Marc Lebel - CEO of Pro-Bel Enterprises and ANSI Board Member "Pro-Bel has a team of qualified technicians across the United States who can gather the information required to ensure that when it comes time to clean your windows, you can do so with the peace of mind that your anchorages are certified for use. If reviewed by an OSHA Inspector, it is important to have the correct paperwork to present so that you are not faced with a stop work order or fines. If you want to be ahead of the game it is important that you work with us at being proactive and schdule your inspection today."

"In the event that you do not have identifiable roof anchors Pro-Bel can help you there as well. Working with a reputable firm like Pro-Bel will ensure that you have a plan in place to identify and certify suitable anchorages." Alan Bell - VP Sales Pro-Bel Enterprises.

This regulation does have an impact on building owners, property managers and employers who are working at heights, on ladders or on any walking-working surface. Help is available to assist those affected in navigating this complicated legislation.

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Brent La Porte
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