Facilities Engineering


Have you ever walked down the street, looked up, and wondered if the window washer was crazy? If conducted safely and within the guidelines of OSHA, suspended work is actually a relatively safe working environment. There are a variety of rules governing the safe access of a building façade for window washing (or other façade maintenance work), which fall under the jurisdiction of OSHA.

On November 18, 2016, OSHA adopted their Final Rule for Walking-Working Surface and Personal Protective Equipment Fall Protection Systems, effective January 17, 2017. This Final Rule (part of 29 CFR part 1910 subpart D and subpart I) was long anticipated and has been the subject of great debate ever since the initial memorandum was issued in 1991.

The OSHA Final Rule puts the burden for providing a safe working environment for people accessing the façade of a building directly on the shoulders of the OWNER OF THE BUILDING.

In summary, the Final Rule requires that Owners provide written certification of an identified, permanent, tested, certified and maintained system for accessing the façade. Identification has typically come in the form of a Contractor Use Plan, which is simply a drawing of the roof showing the acceptable anchorage locations to be used for accessing different areas of the façade. Load testing is generally provided by a testing or engineering firm, under the direction of a Professional Engineer, to show the anchors capacity is capable of supporting a minimum 5,000 lb ultimate rated load. The Final Rule stated the above requirements must be implemented by November 20, 2017.

As a building owner, it is critical that you protect yourself and the people working on your building, by following these guidelines and rules. Seek out the assistance of a professional who has experience with these issues in order to provide you with an economical compliant design. Be careful, some readily available anchors may not be arranged efficiently and without proper certification may end up being expensive decorations for your roof!

We hope this “Lessons Learned” on fall protection and the OSHA Final Rule for Walking-Working Surfaces gives you a basis to understand this complicated life safety issue. Should you have any questions or comments regarding this topic, or with any other issued related to vertical access, please feel free to contact us.


ECS Group of Companies