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OSHA Response: Standard Interpretations/RDS Anchorage Testing Certification

January 25, 2019

Mr. Reg Ranahan
GSS Corporation
80 Hudson Road, Ste. 100
Canton, Massachusetts 02021

Dear Mr. Ranahan:

Thank you for your letter to the Occupational Safety and Health Administration (OSHA)[. Your letter has been referred to the Directorate of Enforcement Programs for an answer to your specific question] regarding 29 CFR 1910.27(b)(1)(i). [This letter constitutes OSHA’s interpretation only of the requirements herein, and may not be applicable to any question not delineated within your original correspondence.] Your letter requests clarification of the requirements for rope descent system anchorages under 29 CFR 1910.27(b)(1)(i). Your paraphrased question and OSHA’s response are below.

Question: International Window Cleaning Association/American National Standards Institute (IWCA/ANSI) I-14.1-2001 Section 8.1.3 requires that anchorages “be tested by applying a minimum static load of twice the design load in each (primary) direction that a load may be applied. For example, an anchorage with an ultimate capacity of 5000 pounds (2268 kg) has a four to one safety factor. Therefore the anchor’s design load is 1,250 pounds (567 kg) and it shall be tested at 2500 pounds (1134 kg).” Under 29 CFR 1910.27(b)(1)(i), must anchorages be tested at 5,000 pounds, or is it permissible to test them at 2,500 pounds, as described in IWCA/ANSI I-14.1-2001?

Response: 29 CFR 1910.27(b)(1)(i) requires that building owners inform employers, in writing, that the building owner has identified, tested, certified, and maintained each anchorage so that it is capable of supporting at least 5,000 pounds, in any direction, for each worker attached. Certification of each anchorage must be performed by a qualified person. Because the OSHA standard does not specify criteria for testing anchorages, the qualified person may utilize any scientifically-valid testing criteria to determine whether an anchorage is capable of supporting at least 5,000 pounds (2,268 kg) per attached worker. In general, this means using criteria that would be accepted by an industry consensus group, or that are certified by a registered professional engineer. OSHA would consider the testing criteria described in your letter – wherein an anchorage with a 5,000-pound ultimate capacity/strength and a four to one safety factor with a design load of 1,250 pounds is tested at 2,500 pounds – to be acceptable under 29 CFR 1910.27(b)(1)(i).

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA’s requirements are set by statute, standards, and regulations. Our letters of interpretation do not create new or additional requirements but rather explain these requirements and how they apply to particular circumstances. This letter constitutes OSHA’s interpretation of the requirements discussed. From time to time, letters are affected when the Agency updates a standard, a legal decision impacts a standard, or changes in technology affect the interpretation. To assure that you are using the correct information and guidance, please consult OSHA’s website at http://www.osha.gov. If you have further questions, please feel free to contact the Directorate of Enforcement Programs at (202) 693-2100.

Sincerely,

Patrick J. Kapust, Acting Director
Directorate of Enforcement Programs

[Corrected 4/17/2019]

https://www.osha.gov/laws-regs/standardinterpretations/2019-01-25

2019 OSHA National Safety Stand-Down

This week, as part of the 2019 National Safety Stand-Down, OSHA and the IWCA encourage employers and workers to pause in their workday to talk about fall prevention and dedicate themselves yet again to the safety of this nation’s most valuable resource: workers. For more information on the Stand-Down, visit the OSHA Stand-Down page. IWCA is happy to help in this effort with new resources for members each day.

https://www.osha.gov/StopFallsStandDown/

OSHA NATIONAL SAFETY STAND DOWN 2019 – LADDERS
Ladder safety begins with choosing the right ladder. Consider the type of work the ladder will be used for, the weight the ladder must carry, and the condition of the ladder.

Step Ladder Safety

Extension Ladder Safety

Glass Waivers and the IWCA/GANA/NGA Bulletins

Jeff Klass tells us about glass waivers and the resources you get from the IWCA/GANA/NGA Bulletins.

How do you educate your customers about caring for the glass?

Opioids/Cannabis Workplace Drug Testing: What Should Employers Know?

Testing for Opioids and Cannabis in the Workplace PPT

Webinar Link
https://event.on24.com/eventRegistration/console/EventConsoleApollo.jsp?&eventid=1899622&sessionid=1&username=&partnerref=&format=fhaudio&mobile=false&flashsupportedmobiledevice=false&helpcenter=false&key=5FAB9615B9F49DA78A38444E62155831&text_language_id=en&playerwidth=1000&playerheight=650&overwritelobby=y&eventuserid=234254704&contenttype=A&mediametricsessionid=193711803&mediametricid=2674529&usercd=234254704&mode=launch

Article on OSHA and Drug Usage
https://www.fisherphillips.com/resources-newsletters-article-osha-drugs-and-rock-n-roll-a

*Members only have access to a Reasonable Suspicion Checklist inside Campus IWCA.

OSHA’s New Site-Specific Targeting Enforcement Program Webinar

Dr Duffer Explains to NGA Glass Issues – Part 2

Second part of Dr Duffer’s talk about Glass Issues at the NGA Conference.

Dr Duffer Explains to NGA Glass Issues – Part 1

First part of Dr Duffer’s talk about Glass Issues at the NGA Conference.

OSHA Renews Alliance with the IWCA to Protect the Safety of Industry Workers

Trade Release


U.S. Department of Labor
Occupational Safety and Health Administration
Office of Communications
Washington, D.C.
www.osha.gov

For Immediate Release
February 16, 2018
Contact: Office of Communications
Phone: 202-693-1999

OSHA Renews Alliance with the International Window Cleaning Association to Protect the Safety of Industry Workers

WASHINGTON, DC – The Occupational Safety and Health Administration (OSHA) and the International Window Cleaning Association (IWCA) recently renewed an alliance to continue providing training and resources to protect the safety and health of workers in the window cleaning industry.

During the five-year agreement, OSHA and IWCA will work together to address hazards, such as falls from heights, and slips, trips, and falls. Participants will also focus on the safe use of high-reach access equipment, including rope descent systems, ladders, and scaffolding.

“Falls are among the most common hazards encountered by professional window cleaners,” said Deputy Assistant Secretary of Labor for Occupational Safety and Health Loren Sweatt. “We value IWCA’s expertise, and look forward to our continued alliance to ensure workers receive information and training to keep them safe on the job.”

The alliance was originally signed in 2010, and renewed in 2012. In the past, participants collaborated to develop resources for the window cleaning industry. IWCA also supported OSHA outreach campaigns, such as the National Safety Stand-Down to Prevent Falls in Construction, Safe + Sound Campaign, and the Heat Illness Prevention Campaign. Additionally, the association has provided its members with training on the new requirements for OSHA’s Walking-Working Surfaces and Personal Fall Protection Systems standard.

IWCA is a non-profit trade association representing more than 500 member companies worldwide.

Through its Alliance Program, OSHA fosters collaborative relationships with groups committed to worker safety and health, such as trade and professional organizations, unions, consulates, faith- and community-based organizations, businesses, and educational institutions, to prevent workplace fatalities, injuries, and illnesses. Alliance partners help OSHA reach targeted audiences, such as employers and workers in high-hazard industries, and give them better access to workplace safety and health tools and information.

Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces for their employees.OSHA’s role is to ensure these conditions for America’s working men and women by setting and enforcing standards, and providing training, education and assistance. For more information, visit www.osha.gov.

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OSHA Relief on RDS Enforcement

December 2, 2017

Dear IWCA Members:

As you may recall, on November 17th, we informed you that IWCA sent a letter to OSHA regarding your  challenges with the time constraints contractors and building owners were confronted with in the new regulations for roof anchor inspection, testing and certification.  We know the IWCA was not the only group who had expressed these concerns and the purpose of contacting you now is to inform you that OSHA has replied to our voice. This letter of clarification is a great example of the public and private sector working collaboratively toward our common goal of creating a safe work environment.

OSHA understood the concerns and has issued a memorandum to all Regional Administrators with Enforcement Guidance for the Anchorage Requirements in OSHA CFR 1910.27 (b) (1).

The Memo acknowledges that due to a limited availability of qualified persons to inspect, test and certify anchorages for RDS use, OSHA is providing employers (you) and building owners additional time to comply with 1910.27 (b) (1)…PROVIDED that employers and building owners can demonstrate and document they are exercising due diligence to come into compliance with the requirements of the standard.

Simply put, OSHA will evaluate on a case by case basis, the progress towards compliance with the regulation by examining the documentation and timelines on the inspection, testing and certification of roof anchor systems.

Additionally, employers performing work on buildings may be impacted where building owners experience difficulties with compliance in a timely manner. OSHA will evaluate the extent of a contractors efforts to comply, which includes the use of other measures or to not perform work during the delay in compliance.

A copy of the letter can be found here: OSHA Memo on RDS 11-2017.

Yours truly,

Jason York
President
International Window Cleaning Association

OSHA Walking and Working Surface Regulations Enforcement

November 17, 2017

Dear IWCA Members:

According to revised Federal Regulations, OSHA will start enforcing the Walking and Working Surface Regulations CFR 1910.27 for Rope Descent Systems beginning November 21st.  As a reminder, this means that any anchorage that ropes are attached to for descending in order to access a building, shall have been identified, inspected, tested and certified (in writing) that the anchorage point meets the requirements of these regulations.  The certification of an anchor for use with a rope descending system must also consider location to the vertical areas being serviced to allow for proper rigging and compliant use.  Workers are not to use rope descending equipment when they have not received written verification the anchors have been certified as described.

The IWCA did participate in all the public hearings and information gathering during the OSHA promulgation of Subpart D and I, Walking and Working Surfaces Regulations.  We were greatly pleased to acknowledge its publication in November, 2016 and satisfied that it incorporated many concepts from the I-14 standard such as use conditions, proper rigging and documentation identifying, inspecting, testing and certifying anchorage points prior to use.  We congratulated OSHA’s adoption of these best practices and do believe this new final standard will save lives and make daily operations safer for all industries that utilize Rope Descent Systems for building façade access including window cleaning.  Primarily, it will eliminate the jobsite guesswork we’ve faced for years with identifying proper anchors and their location.

It is the overall sentiment of the industry that the revised regulation has been well-received, and actions are ongoing in many markets with positive momentum.  However, reports and discussions with members and associates have indicated the time it takes to educate clients (building owners/managers) to the new regulations then move toward compliance; has taken longer than members and especially OSHA previously estimated.  The IWCA sent this letter to OSHA outlining our concerns and requesting an extension of the deadline.  In the meantime, we recommend that the positive momentum for change be carried forward.  These long awaited changes in regulations will make our industry better and will save more lives.  As we already know…. good things take time and are usually very worth waiting for.

Yours truly,

Jason York
President
International Window Cleaning Association

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