Tech Talk Blog

Does OSHA Require Anchorages for All Suspended Window Washing Applications?

Much confusion exists over the OSHA regulations pertaining to Rope Descent Systems (RDS) and Industrial Rope Access Systems (IRAS) used for high rise façade maintenance and window washing applications.  OSHA’s recently updated 1910 Subpart D standard includes specific language to ensure window washing safety when rope descent systems are used and requires the building owner to provide written assurances to the window washing contractor as outlined in 1910.27(b).

These assurances document the capacity of the anchorage system used to support window washing operations and safeguard employees working at height.  But because the new OSHA regulations speak specifically to the certified anchorage requirement for rope descent systems while making clear these provisions do not apply to industrial rope access or suspended scaffolds, what are the responsibilities of building owners when a window washing application requires an alternative means of suspended access?

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Are Window Washing Contractors Responsible for Anchorage of their Equipment and Safety Lines?

Window washing anchorPrior to recent updates to the Walking Working Surfaces regulations, OSHA had little to say regarding  rope descent system (RDS) commonly utilized by window washing contractors.  The absence of specific regulations pertaining to RDS often put building owners and contractors at odds over which party was responsible for window washing anchor inspection and certification.    In some instances, building owners would include contractual provisions requiring window washing contractors to supply their own means of anchorage and fall protection.  The absence of clearly worded regulations created unsafe working conditions since delineation of responsibilities between the building owner and window washing contractor was not well defined.

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New OSHA Regulations for Window Washing Anchors and Rope Descent Systems

By now, you’ve probably heard about OSHA’s revised Walking-Working Surfaces regulations.  Many of the articles published on this topic explore the deadlines to convert from ladder cages to ladder safety systems (we recently published an e-book that discusses the new ladder regulations).  Make no mistake—the revised fixed ladder requirements are significant, but the new OSHA regulations cover additional ground that will impact employers and property owners nationwide.    In this post, we’ll look at the new Walking-Working Surfaces regulations as they relate to the use rope descent systems (RDS) and window washing anchors. 

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Is Your Anchor Point Safe?

If you have ever taken a fall protection training class or read much on the topic, you’ve heard references to the ABC’s of personal fall protection systems:  anchorage, body harness and connecting device.  Sometimes folks also include the letter D, which stands for the descent and rescue component.  The ABCD mnemonic is easy to remember, but its proper application can be a challenge.  To make our point, let’s take a look at some commonly used anchor points in the window washing industry.

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Did You Know?

A Horizontal Lifeline System must be engineered for two times the applied load in the event of a fall?