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OSHA Regulations
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| THE FOLLOWING DOCUMENT IS COPYRIGHT PROTECTED! |
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 Building Owners and Managers Association (BOMA) International
1201 New York Avenue, NW
Suite 300
Washington, DC 20005
www.boma.org
Telephone: 202-408-2662
International Window Cleaning Association (IWCA)
7801 Suffolk Court
Alexandria, Virginia 22315
www.iwca.org
Telephone: 703-971-7771
ISBN: 0-943130-33-6 |
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Introduction
On October 25, 2001, the American National Standards Institute (ANSI) approved the IWCA I-14.1 Window Cleaning Safety draft standard for publication as an American National Standard.
The action is a result of nearly five years of work by members of the IWCA I-14.1 Committee who have worked diligently toward achieving this goal. Throughout this time frame outside parties affected by the Standard were able to take advantage of several opportunities to provide input and submit comments on the draft. This enabled the committee to review hundreds of comments, statistics and technical reports and make numerous changes to the draft standard in order to achieve a consensus for the window cleaning industry.
The IWCA I-14.1 Committee is comprised of twenty-four members that are divided into three categories of interest. These Interest Categories are an ANSI requirement and include "User" (window cleaners), "Producer" (manufacturers of equipment) and "General Interest." Some of the members of the general interest category are safety consultants and designers, officials from the California and New York Departments of Labor, the Building Owners and Managers Association (BOMA), the Illinois Association of Building Maintenance Contractors (IABMC) and the International Window Cleaning Association (IWCA).
The ANSI/IWCA I-14.1 Window Cleaning Safety Standard is a two-part document. Part A focuses on safety guidelines for the use of window cleaning access equipment while Part B is geared toward those who manufacture, design or install the equipment. Some of the access equipment addressed in the Standard includes rope descending systems (also known as RDS, CDE, or CDA), transportable and permanent suspended scaffolds, ladders and man-lifts. The Standard will also serve as a guide for regulatory agencies, architects and building owners.
What Does the I-14.1 Standard Mean to Property Professionals?
There are actually two different groups of professionals immediately affected by the new Standard: property professional and window cleaners. Building owners and managers are required to provide a safe building from which to work, and window cleaners are required to ply their trade within specific safe guidelines.
Although ANSI standards do not have the force of law, they are cited in court as the standard of care any reasonable business would use in conducting its affairs. The IWCA I-14.1 Standard is the national standard that identifies specific window cleaning safety operations.
Most industry-recognized safety hazards are related to the use of transportable suspended access equipment on office buildings. With that in mind, there are several key issues within the ANSI/IWCA I-14.1 Window Cleaning Safety Standard that require the attention and participation of building owners, managers and their operating agents.
Under the ANSI/IWCA I-14.1 Window Cleaning Safety Standard, both the property manager and the window cleaning contractor are required to exchange written assurances to ensure worker safety and public protection.
Assurances by the Property Professional
Property professionals are required to provide documentation to their window cleaning contractor that covers the following areas of concern:
Permanent window-cleaning equipment installed on buildings such as a powered platform, platform supports, roof anchors, window cleaner belt anchors, permanent ladders or any other equipment that may be used during the course of window cleaning has been inspected and maintained by the building owner, manager or operating agent according to state and local codes and the manufacturers' recommendations.
A copy of the maintenance records and inspection documents must be provided to the window cleaning contractor prior to the equipment being used. This will ensure that the equipment is safe and ready to use.
All applicable information from the manufacturers of the devices, including load ratings intended use and limitations and instructions will also need to be supplied to the window cleaning contractor.
Note that if the window cleaning contractor uses their own transportable equipment that requires tie back anchorages attached to the building or uses parts of the building for support, the areas of the building where the equipment is attached must be inspected to verify that it will hold the equipment and loads. A copy of this inspection and/or verification must be given to the window cleaning contractor prior to services being performed. Structural or civil engineers may be needed for this type of inspection and verification.
Assurances by the Window Cleaning Contractor
The ANSI/IWCA I-14.1 Standard also requires a window cleaning contractor to provide the following written assurances to the building owner, managers or operating agent contracting their services:
That they will perform their services in compliance with all applicable local, state and federal laws, licensing requirements, regulations, codes and standards. It is recommended that this statement be placed on their proposal or separately on company letterhead.
That their workers are adequately trained in operating any or all equipment intended to be used. Verifiable training documents or proof of certification should be presented.
That any equipment brought to the building by the contractor is designed, maintained and inspected in accordance with industry standards. It is also recommended that this statement be placed on their proposal or separately on company letterhead.
Anchors and Anchorage
Most of what has been described pertains to the use of suspended access equipment, which is equipment that hangs down from the roof of a building. The most critical component in suspended access equipment system is what the suspension lines and safety lines are attached to on the roof of the building. An inspection of the roof of a building will reveal whether or not there are structural elements that can be used as adequate anchors or that the building may need to have anchors installed. A building cannot comply with any of the requirements mentioned here and in the ANSI/IWCA I-14.1 Window Cleaning Safety Standard unless adequate anchor points on the roof are in place or installed.
Why is this Issue So Critical?
Currently, adequate roof anchors -- which provide fall protection and/or structural support for the actual window cleaning operation -- do not exist on a large percentage of buildings in the United States because many architects did not appreciate their importance. What was not realized in the design phase is that sections of tall buildings whose windows cannot be reached from the ground can only be reached by roof suspension apparatus, utilizing techniques such as davit/sockets, counterweighted outriggers, parapet clamps or Rope Descent Systems (RDS). Virtually all of these methods require roof anchors.
The Consequences of Insufficient Anchors
When roof anchors are nonexistent or exist in insufficient quantities around the periphery of the roof, a dangerous condition is created. Common mistakes made to rectify the lack of proper anchorages include attaching to non-structural parts of the building and creating a horizontal lifeline on a roof by stringing a fiber or wire rope line between two anchor points and securing the vertical lifelines at different points along the length of the horizontal line. These applications are extremely unreliable and are, in fact, quite dangerous.
The Solution
In order for window cleaning operations to be conducted properly, buildings must have properly identified anchorage points. These can be either roof anchors or other existing anchorage points that are certified. This is important to note because if a building is not fit with roof anchors as pictured, many buildings still may comply with the I-14.1 Standard because other structural elements existing on rooftops can be easily utilized and converted into "certified roof anchors" with the assistance of a structural engineer. For example, vertical columns for roof screens or structural framing supporting mechanical equipment are likely candidates for roof anchors.
Buildings without any form of anchorage must be retrofitted with roof anchors. The anchors must be designed by a registered professional engineer (P.E.) and inspected annually by a qualified person. |
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