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					  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

                 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
Improvising became
Dangerously Popular
  forced to
guess where
 and how to
   rig their
  lines on a
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 I-14 focuses it’s safety
          guidelines on the two most
         affected parts of the window
               cleaning industry

The Window Cleaner and the
    Property Manager !!!
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
 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
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
More Reasons for YOU to COMPLY
             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
More Reasons for YOU to COMPLY
    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
Written Assurances You Should
       Provide in Return
      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.
         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.
         What is a Certified Anchor System??

This eliminates the
guesswork which has led
to improper and unsafe
rigging practices.
Sample of a Certified Anchor System
Sample of a Certified Anchor System
What a Certified Anchor System Looks Like
     What is a Certified Anchor System??

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 System
FAQ # 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 System
FAQ # 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 !!!
               Proper Anchoring System
                Anchor Location is CRITICAL !!!

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 !!!

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.
        Proper Anchoring System
         Anchor 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.
            Proper Anchoring System

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

                        Here’s one important reason why…

                         If a horizontal line is run from A
                         to B as shown, and C= 180lb.
A                   B    The force on A & B will be
                         nearly 6000lbs which is over the
        C= 180lbs        5000lb capacity.
                    U.S. Department of Labor
Here’s a more
                    General Duty Standard

important reason    Citation 305549388/01001

why…                            Inspection     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

  Two Window                   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

  Cleaners were                hazards.

                               Among other means, feasible means of abatement would be:

  killed when the              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.

  horizontal line              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
  that was strung              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

  between anchor               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

  points failed.
                               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
  Boston, MA                   equipment and ANSI/IWCA I- 14.1 2001 standard, and related safety

  April, 2003
                               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
                               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.
              Proper Anchoring System
FAQ # 2-ANSWER: If additional anchors were added to
these roofs, the existing fixtures could be included into a
certifiable roof safety anchor system.
             Proper Anchoring 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.
                Proper Anchoring System

If this rope was loaded by the     Because this roof edge is
weight of the worker….it would     concrete, it would abrade
slide down the roof edge to        right through the rope as it
here, (about 30 feet) until it     slides along this edge
came within 15 degrees of a
                                   towards its final resting
straight line from the post it’s
attached to.                       point.
             Proper Anchoring System
FAQ # 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 System
FAQ # 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 System
FAQ # 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.

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