SECTION 5 – DUTIES
(a) Each employer
- shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees;
- shall comply with occupational safety and health standards promulgated under this Act.
(b) Each employee shall comply with occupational safety and health standards. Find all rules, regulations, and orders issued pursuant to this Act which are applicable to his own actions and conduct.
Note: a) Your company can be cited and fined under the above standard if there is no specific standard in the OSHA 1910 or 1926 rules.b) Also, You can be cited under the general duty clause even if another standard does call for a specific safety control measure or allows a certain activity, if it can be shown that you understood there to be hazard that the standard didn’t adequately cover and you failed to properly address it
OSHA Regulations that apply to window cleaning operations:
- Transportable Suspended Scaffolding – OSHA CFR 29-1910.28(F), (G)
- Permanent Suspended Scaffolding – OSHA CFR 29.1910-66
- Mobile Lifts (vehicle mounted) – OSHA CFR 29-1910.67
- Manually Propelled-High Lifts, Etc. – OSHA CFR 29-1926.556
- Ladders – OSHA CFR 29-1910.25 thru 1910.26
- Tower Scaffolding – OSHA CFR 29-1910.29 and OSHA CFR 29-1926.451 (E)
- Overall Employee Safety & Chemical Use OSHACT, OSHA CFR 29- 1910.1200 (HAZ-COM)
Rope Descent System *OSHA policy March 12,1991- Memo by Patricia Clark, Director of Compliance Programs
OSHA OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION
To obtain copies of the entire Codes of Federal Regulations as listed, contact 1-202-783-3238. They are also available from their website at www.osha.gov.
ANSI Regulations that apply to window clean/building maintenance:
- Permanent Suspended Scaffolding & Powered Equipment ANSI – A-120.1
- Mobile Lifts – ANSI A-92.3 (Manual) – ANSI A-92.2 (Vehicle) – ANSI A-92.5 (Boom)
- Ladders – ANSI A-14.2 (Metal) – ANSI A-14.1 (Wood) – ANSI A-14.3 (Plastic)
- Tower Scaffolding – ANSI A-10.8
- Harnesses, Lanyards, Lifelines – ANSI Z-359
- Rope Descent System – ANSI 114-1
AMERICAN NATIONAL STANDARDS INSTITUTE
To obtain ANSI Standards that are held by ASME, call 1-800-843-2763. Their website is: www.ansi.org
To obtain ANSI Standards that are held by SIA, call 818-786-3027. Their website is: www.scaffold.org
To obtain a copy of the ANSI 114 Draft go to www.iwca.org
U.S. Department of Labor Occupational Safety and Health Administration Washington, D.C.
March 12, 1991
Memorandum to: REGIONAL ADMINISTRATORS – PATRICIA K. CLARK DIRECTOR
From: DIRECTORATE OF COMPLIANCE PROGRAMS
Descent control equipment (friction devices such as “Sky Genies, racks” and “figure eights”) is not covered by existing Occupational Safety and Health Administration (OSHA) standards. Therefore, the Agency addresses the safety of descent control devices through its enforcement of section 5 (a) (1) of the OSHA Act. Under this approach. OSHA references the safety principles applicable to similar equipment (in this case, boatswain’s chair,. single point and two-point suspended scaffolds) and national consensus standards (such as ANSI A39.1-1987, with addenda A through C, “Safety Requirements for Window Cleaning”) in so far as they are pertinent to the subject matter.
As indicated in the December 5, 1989 letter, OSHA allows the employees to use descent control equipment, provided that the equipment is used in accordance with the instructions, warnings and design limitations set by manufacturers or distributors. In addition, the Agency expects employers whose employees use descent control devices to implement procedures and precautions as follows:
- Training of employees in the use of 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 bodybelt, 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 employees fall;
- All lines installed (such as by using knots, swages or eye splices) when rigging descent control devices shall be capable of sustaining a minimal 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 rope;
- Provisions are made for intermittent stabilization for descent in excess of 130 feet.
SUSPENDED SYSTEM – All equipment that hangs from the support system. A 30′ aluminum walkboard (deck) with two 1000 pounds maximum rated load Spider SC-40 Traction Hoists mounted on each end. 5/16″-8.3mm diameter 6119 Seale construction IWRC, right regular lay, preformed, improved plow steel wire rope are threaded through the hoists and terminated at the suspension eye bolt in the end of the outrigger beam. The motors are powered by 220 Volt, single phase, 6 amp current supplied by the building. This system may include a powered stage, wire rope, electrical cord, hoists, Rope descent system (RDS), tools, equipment and the worker(s). This system always includes the fall arrest equipment.
As the Safety Director for Martin’s Window Cleaning Corporation, my responsibility is to stay current on all applicable federal, state, and local codes, regulations, and standards as they apply to window cleaning, transfer that information through our safety and training program to our employees, insure that all applicable codes, regulations, and standards are being applied on the job site through daily inspections, and assure our customers through written and verbal communications that our operations are in compliance.
No matter what type of equipment is being used, when men are working more than six feet off the ground, their equipment, their lives, and the life of the public below the work zone is only as sound as the anchor to which their equipment and their independent fall arrest is attached. It is the goal of Martin’s Window Cleaning Corp. to partner with our customers to provide sound, identified, certified anchors on every job site.
-Cassandra Huffman, Safety Director, Martin’s Window Cleaning Corp.