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
