A  ccording to OSHA, falls from heights and working surfaces lead to over 200,000 serious injuries and 345 deaths each year. 

To combat these unnecessary losses—and to revise the existing standards, which were last updated in 1971—the agency has codified a new final rule on Walking-Working Surfaces and Personal Fall Protection Systems. The rule, released on November 18^th, 2016, is wide-ranging and covers many different working situations—but there are several changes that apply directly to window-washing and facade-maintenance operations. 

With this rule, OSHA intends to clarify the shared responsibility of building owners/managers and contractors to keep workers safe. Below, we will discuss the changes, how they will impact your business, and the ways in which Point Exteriors can help you ensure OSHA compliance and keep business running smoothly and safely. 

What the new OSHA rule says

OSHA’s new final rule has many important implications for building owners and managers. Most relevant is a new safety standard requiring that buildings be equipped with separate, independent, and safe anchorage to which contractors or employees can harness when deploying rope descent (RDS) or suspended scaffolding systems for the purposes of window-cleaning, façade maintenance, or other tasks. In the past, many window cleaners instead tied off to untested and potentially unsafe structures, a practice that OSHA’s final rule is meant to forbid. On this subject, OSHA will now require that:

1. Designated and permanent anchorages must be “identified, tested, certified, and maintained… [and be] capable of supporting at least 5,000 pounds, in any direction, for each employee attached.” 
2. Anchorages affected by the rule include davit arms, eye bolts, monorail trolley systems, and horizontal life line systems. 
3. Anchorages must be tested and recertified as necessary (at least every ten years).
4. Building owners must provide written verification of anchorages’ certification to contractors before any lines are secured for work to begin. 
5. The deadline for action on these requirements is November 20, 2017. 

With this final rule, OSHA also codified a 1991 memorandum which permitted the use of RDS systems (aka manually controlled bosun’s chairs) for the purposes of window-cleaning. OSHA has recognized RDS as a safe and industry-accepted means of access; and, to further ensure workers’ safety when using these systems, has instituted a 300-foot building-height limit for the use of RDS, unless, for safety reasons, RDS remains the best means of access for such buildings. 

Other Considerations 

The final rule also makes changes to other workplace safety standards that may be relevant to your property or business. Below is a general summary of the final rule’s other stipulations:

1. Employers must protect workers from fall hazards along edges or unprotected sides that are four feet or more above a lower level, and “sets requirements for fall protection in specific situations, such as hoist areas, runways, areas above dangerous equipment, wall openings, repair pits, stairways, scaffolding and slaughtering platforms.” 
2. The rule gives employer’s “greater flexibility in choosing a fall protection system” that is appropriate for the particular area or situation including guardrail, safety net, personal fall arrest, positioning, travel restraint, and ladder safety systems.  
3. The rule also changes ladder safety requirements, mandating that fixed ladders extending over 24 feet be equipped with personal fall arrest or ladder safety systems (thus phasing out the use of cages or wells). Within two years from the rule’s publication, all existing ladders in this category must be equipped with a cage, well, ladder safety or personal fall arrest system, and new ladders over 24 feet must be equipped with a ladder safety or personal fall arrest system (i.e., wells and cages phased out for new ladders). Within twenty years of the rule’s publication (November 18, 2036), all ladders over 24 feet—both new and existing—must be equipped with a ladder safety or personal fall arrest system (i.e., wells and cages must be completely phased out). 
4. Employers must take action to train any workers who use personal fall protection systems (or otherwise work in specific, danger-prone situations), in the use, storage and inspection of relevant equipment. This requirement must be completed within six months following the rule’s publication (May 17, 2017).  

What the Changes Mean for You

Building owners and managers will need to ensure that their properties meet certain standards before allowing workers to perform hazardous tasks, including work involving rope descent (RDS) or suspended scaffolding systems:

• If your building is already equipped with designated, permanent anchorages, they’ll need to be identified, tested and certified as being capable of supporting at least 5,000 pounds in any direction. 
• Certification must be completed by a “qualified individual” (see note below*).
• New or existing buildings that do not have adequate anchorage must be updated to meet the new OSHA standards. 
• Written verification (i.e., a “Letter of Assurance”) that a building’s anchorages have been certified and maintained must be provided to any contractor (for example, window-washers or building maintenance workers) before RDS or suspended scaffolding work can be performed. 

In addition, businesses should be sure to address the final rule’s other stipulations, including the ladder and elevated-surface changes discussed above. 

Doing Our Part 

Window cleaning and façade maintenance contractors are also subject to new requirements under OSHA’s final rule, and Point Exteriors is committed to carefully adhering to all the pertinent regulations. Going forward, in accordance with the final rule, Point Exteriors will continue to:

1. Be responsible for ensuring that new hires and existing employees who are “exposed to fall hazards” are fully trained, certified and competent in the use of relevant safety equipment.
2. Ensure that all safety equipment being used on the job is safe and has been inspected according to OSHA’s final rule and other compliance standards.
3. Keep written verification information supplied by the building owner on hand until the job is complete. 

By working together, we can ensure that your building remains beautiful, and that all work completed on your property is safe and OSHA-compliant. 

*Qualified Individuals

At Point Exteriors, we understand that compliance with the new OSHA final rule will be a challenge for some building owners, but we are here to help. Our team has the expertise, equipment, and dedication to customer service necessary to help you make all the required updates to your building. Point Exteriors can ensure that you meet compliance within the allotted timeframe by:

• Inspecting your property to identify areas that will need to updated or modified to meet OSHA compliance.
• Installing new hardware to meet compliance, such as anchorage, personal fall arrest systems, or guardrails. 
• Providing testing and certification for new or existing anchorages (carried out by qualified engineers) to ensure workplace safety and OSHA compliance. 

Point Exteriors is your one-stop shop for meeting compliance on the new OSHA final rule. With several of the compliance deadlines looming, building owners and managers should waste no time in taking steps to ensure that their properties meet the new standards—otherwise, important work may be delayed and compliance issues may arise. 

To set up a consultation, please call 717-766-9121.