By now, you’ve probably heard about OSHA’s revised Walking-Working Surfaces regulations. Many of the articles published on this topic explore the deadlines to convert from ladder cages to ladder safety systems (we recently published an e-book that discusses the new ladder regulations). Make no mistake—the revised fixed ladder requirements are significant, but the new OSHA regulations cover additional ground that will impact employers and property owners nationwide. In this post, we’ll look at the new Walking-Working Surfaces regulations as they relate to the use rope descent systems (RDS) and window washing anchors.
Before we dive into our discussion of the new regulations, it makes sense to start with the definition of a rope descent system, which OSHA 1910.27 (b) defines as follows:
“A suspension system that allows a worker to descend in a controlled manner, and as needed, to stop at any time during the descent….the RDS usually consists of a roof anchor, support rope, a descent device, carabiner(s) or shackle(s), and a chair (seatboard).
Prior to the new ruling, OSHA was mostly mum on RDS. You couldn’t find specific language within the older 1910 general industry regulations governing the use of rope descent systems, but OSHA has issued rulings based on a memorandum published back in 1991. The 1991 memorandum specified that a set of basic guidelines for safe RDS use and required that employers:
- Use RDS in accordance with manufacturer instructions
- Implement procedures to ensure employees are properly trained on RDS use and inspection
- Provide a separate anchor for fall arrest and padding for ropes
- Provide a means of prompt rescue
The International Window Cleaning Association’s ANSI/IWCA I-14.1-2001 standard is based on the guidelines set forth in the 1991 memorandum. The provisions of these documents are now incorporated into OSHA 1910.27 (Scaffolds and Rope Descent Systems).
OSHA Anchorage Requirements for RDS
1910.27(b)(1)(i) now requires that before “employers use a rope descent system, the building owner must inform the employer in writing that the building owner has identified, tested, certified, and maintained each anchorage so it is capable of supporting 5,000 pounds in any direction, for each worker attached”. The new regulations also require that the building owner base the information provided to the employer on:
- An annual inspection; and
- A certification of each anchorage, as necessary, and at least every ten years.
In case you are wondering about the certification as necessary language above, OSHA is saying that an accident that damages the anchor, major alterations to the building, or exposure to the elements might require more periodic re-certification.