Question:
Is certification of anchors required?
Answer:
The ANSI/IWCA I-14.1 (3.9 Anchorages) clearly states
“Building owners and window cleaning contractors
shall not allow suspended work to be performed unless
it has been determined that the building has provided
identified and certified anchorage”.
Although the ANSI/IWCA I-14.1 Window Cleaning Safety
Standard is a voluntary standard, it has been cited
by OSHA officers and in litigation when a window cleaner
has been hurt or killed.
Question:
To what standard should anchors be certified?
Answer:
Rope descent systems and other suspended access systems
should be certified to meet the ANSI/IWCA I-14.1 Window
Cleaning Safety Standard. This standard is an accepted
industry standard that contains inspection and testing
criteria (see section 8 of ANSI/IWCA I-14.1 Window Cleaning
Safety Standard).
Other standards and applicable regulations
are as follows:
OSHA “Procedures and Precautions
for Employees Using Descent Control Equipment”
OSHA Regulation 29 CFR 1910.28 applies
specifically to the “Safety Requirements for Scaffolding”
OSHA regulation 1910.66 specifically
applies to “Powered platforms for building maintenance”
and “does not apply to suspended scaffolds (swing
scaffolds) used to service buildings on a temporary
basis”.
ASME A120 “Safety Requirements
for Powered Platforms for Building Maintenance”
also contains inspection and testing criteria for powered
platforms.
Question:
Does having roof anchorages certified to OSHA 1910.66
mean that the entire building is safe for rope descent
and window cleaning operations?
Answer:
No. This standard specifically applies to “Powered
platforms for building maintenance”
(Click
here to see the interpretation letter)
Although this standard states that
anchorages are required to “be capable of supporting
5,000 pounds” it does not address anchor spacing
issues which are addressed in ANSI/IWCA I-14.1. Anchor
spacing is critical to providing a safe working environment.
Question:
Can existing buildings that have anchors (davit or outrigger
bases) spaced at least 20 ft. apart be certified as
I.14.1 compliant for rope descent?
Answer:
Perhaps, but it is unlikely because window cleaners
are forced to rig a horizontal line between the two
anchors. This configuration, which has not been certified,
changes the question to:
Question:
Can a horizontal line slung between two anchor points
spaced at 20 ft. be considered acceptable anchorage?
Answer:
When anchors are spaced more then 12 ft. apart a “horizontal
line” is often slung between two anchor points.
Not only do the anchors need to be certified to support
5,000 lbs., but the system including the horizontal
line also needs to be certified. The requirements for
these systems are as follows:
“A horizontal (rope) may be used as an anchorage
or may be a fundamental part of a fall arrest system.
In all cases, horizontal lines shall be designed
by or under the direct supervision of a registered professional
engineer experience in such designs." ANSI/IWCA
I-14.1 Window Cleaning Safety Standard in section 9.1.11
“Horizontal lifelines may, depending
on their geometry and angle of sag, be subjected to
greater loads than the impact load imposed by an attached
component. When the angle of horizontal lifeline sag
is less than 30 degrees, the impact force imparted to
the lifeline by an attached lanyard is greatly amplified.
For example, with a sag angle of 15 degrees, the force
amplification is about 2:1 and at 5 degrees sag, it
is about 6:1. Depending on the angle of sag, and the
line's elasticity, the strength of the horizontal lifeline
and the anchorages to which it is attached should be
increased a number of times over that of the lanyard. Extreme care should be taken in considering a horizontal
lifeline for multiple tie-offs. The reason for this
is that in multiple tie-offs to a horizontal lifeline,
if one employee falls, the movement of the falling employee
and the horizontal lifeline during arrest of the fall
may cause other employees to also fall. Horizontal lifeline
and anchorage strength should be increased for each
additional employee to be tied-off. For these and other
reasons, the design of systems using horizontal lifelines
must only be done by qualified persons. Testing
of installed lifelines and anchors prior to use is recommended.”
OSHA 1010.66 Personal Fall Arrest System (Section I
- Mandatory; Sections II and III - Non-Mandatory Para.
6).
The above quoted OSHA regulation is
for powered platforms, however, the basic principle
of horizontal lines is applicable. When building anchorages
are certified to meet OSHA 1910.66 should not the horizontal
lines should also certified?
Notice OSHA citation below:
Violation |
Quish Wc |
Standard Cited: 5A0001 |
Text For Citation: 01 Item/Group: 001 Hazard: FALLING |
| 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. Location - 420 Boylston Street,
Boston: On or about 04/12/04, a horizontal line
used as anchorage for supporting a rope descent
system, consisting of a polyester and polyolefin
fiber did not conform to ANSI/IWCA I-14.1 2001 Standard
for Window Cleaning, thereby exposing an employee
to fall hazards. Feasible abatement methods include
but are not limited to the following: 1. Consult
a qualified professional engineer to design a horizontal
line and determine that is capable of supporting
the load factor based on the nominal strength of
wire rope, its end terminations and anchorages.
2. Implement a comprehensive safety program that
includes hands-on employee training in the proper
use of approved rigging, fall protection systems,
and rescue techniques. 3. Perform an evaluation
of all employees to have full comprehension of the
safety training program, manufacturers’ instructions
and limitations of the RDS equipment and the ANSI/IWCA
I-14.1 2001 Standard for Window Cleaners. 4. Ensure
a competent person inspects all anchor points and
rigging components being used prior to 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.
5. 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
service being performed. 6. Remove from service
any defective components of the RDS system that
supports human life. 7. Ensure all ropes are protected
from contact with any surface that may abrade, sever,
weaken or damage it. |
Question:
If anchors are certified is the system safe to use?
Answer:
Certification anchors in and of itself does not guarantee
safety. Often window cleaners use davit bases or outrigger
bases spaced at 20 ft. apart are 2 ft. or less from
the roof edge. With no fall protection such as a guardrail
or other anchors to tie off to before approaching these
anchors, such a system could not be considered safe.
OSHA has cited many an employer whose worker fell from
the roof edge because of not having proper fall protection.
A case in point is as follows
Violation |
Dedden's Window Cleaning,
Inc. |
Standard Cited:19100132 A Personal Protective Equipment, General Requirements |
Text For Citation: 01 Item/Group: 001 Hazard: FALLING |
| Section 5(a)(1) of the Occupational
Safety and 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 40 foot fall: a) On or about August 9, 2002,
two employees were at the edge of a roof approximately
40 feet up from a dock platform pulling up a mule
in preparation for cleaning the building's windows.
As they were pulling up the second mule, one of
the employees fell and landed on the dock ramp after
striking the ramp handrail. The roof parapet was
29 inches high and the employer did not ensure that
fall protection was used. Among other methods, a
feasible and acceptable method to correct this hazard
would be to ensure and enforce a fall protection
policy as written in ANSI IWCA I-14.1-2001, including
a personal fall arrest system and/or fall restraint
system. |
:
Question:
Is testing of roof-suspended access equipment required?
Answer:
Although some of the OSHA regulations do not require
testing of equipment, most of the OSHA regulations and
other consensus standards do. The following paragraph
indicates that when certifying anchors it is assumed
that those anchors were tested before certification.
Furthermore, much of the equipment is not visible. What
is buried beneath the roof may be improperly installed.
Add to this the very corrosive environment found under
many roofs and the question becomes, how could one certify
that equipment without testing?
A case in point is as follows:
Inspection: 306812165 - Quish
Wc |
Text For Citation: 01 Item/Group: 001 Hazard: FALLING |
| Nevada Revised Statute 618.375(1):
The employer did not furnish employment and a place
of employment which was free from recognized hazards
that were causing or likely to cause death or serious
physical harm to employees: The employer did not
ensure that anchor points were approved prior to
use by a window washer at the following location:
a. Balconies, north and south sides of the Ghost
Bar, davit arm support boxes and wall eye bolts
that were used as anchor points for the work line
of a boatswain's chair and a lifeline for a contractor's
employee were not tested and certified to be capable
of handling these loads. If the anchor points failed,
the employee could have been exposed to a fall of
up to approximately 400 feet to the ground. Reference:
ANSI/IWCA 1-14.1-2001, Section 3.9 -Building owners
and window cleaning contractors shall not allow
suspended work to be performed unless it has been
determined that the building has provided, identified
and certified anchorages complying with Section
9 or 10 for: independent safety lines, tie-backs
for outriggers, parapet clamps, and cornice hooks;
primary support anchorages for powered and manual
boatswain's chairs; primary support anchorages for
rope descent systems; horizontal (rope) lines or
lifelines; and wherever else required. One feasible
method of abatement would be for the building owner
to arrange for a recognized testing laboratory to
test and certify the anchorages used by window washers
in accordance with ANSI/IWCA 1-14.1-2001. |
Question:
What is the safest course for a building owner to follow?
Answer:
Having an evaluation of your suspended maintenance equipment
is a good place to begin. Summit Anchor Co. is available
to evaluate your roof to see if it is compliance with
current safety regulations such as ANSI/IWCA I-14.1
Window Cleaning Safety Standard. Our evaluation will
be confirmed in writing. Contact us for details.
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