Do you need more information on how this standard affects you as a building owner/property manager?
The International Window Cleaning Association is the resource for the most up-to-date safety standards and other regulations.
The ANSI/IWCA I-14 is an American National Standard published in 2001. The intent of the I-14 Standard is to improve the level of safety in the window cleaning industry. The 1-14 Standard provides safety guidelines that benefit building owners, managers and contractors. Safety in the workplace is a shared responsibility; by following the voluntary I-14 Standard, both lives and assets are protected.
The Occupational Safety and Health Administration references the I-14 Standard in violations by window cleaning contractors of the OSHA Section 5(a) 1- General Duty Clause. In these citations, OSHA states that the violations could have been remedied if the contractor were following the requirements of the I-14 Standard.
The nature of the citations range from contractors needing to upgrade their equipment, improve their safety training and providing a written work plan to working with the building owner or manager with re-assessing the safety of the facility.
In a more significant case study, the I-14 Standard helped to eliminate the liability of a property manager after an accident occurred.
During the summer of 2005 in Massachusetts, a window cleaning company had scheduled the cleaning of a six story building’s windows a few weeks after they had submitted their work plan to the property management company. Part of that work plan included the documentation provided by the property management company which assured the window cleaner that the building had a certified roof anchor system and the system was recently inspected. The work plan also showed a diagram of the system and included documents verifying the window cleaners that would be on site were trained in the use of the equipment.
The crew arrived at the site and the supervisor went over the system one more time using the roof anchor layout posted on the roof door. The supervisor then left. The window cleaners then made the decision to not follow the plan by having one worker suspend from the portable rigging device and the other was going to push the device back and forth on the roof. The workers did not tie the device back nor did they use the anchors for safety line attachment. There was no parapet wall and as a result, the rig was pushed off the roof. One worker was killed and the other sustained permanent injuries.
In the federally filed lawsuit that followed, the attorneys for the workers claimed the building owner was negligent because they did not do enough to protect the workers from having the accident. The judge reviewed the case and dismissed the building owner because it was proven they did all they could and in accordance with the American National Standard for Window Cleaning Safety.
After reviewing the new I-14.1 Window Cleaning Safety Standard, the Building Owners and Managers Association (BOMA) International applauded the International Window Cleaning Association (IWCA) for its commitment to finalizing a project that was five years in the making and ultimately won the approval of the American National Standards Institute (ANSI).
“We joined the IWCA I-14.1 Committee in November 1999 to support and develop a consistent and comprehensive national safety standard for window cleaning operations,” said BOMA President Sherwood Johnston, III. “As a member of the committee, BOMA sought to address safety in a manner that was fair, reasonable, achievable and cost effective, and in which safety regulations were based on reliable data and not marketing forces. I believe we’ve accomplished that through the approval of this window cleaning safety standard.”
BOMA and IWCA realize that each respective organization represents one of the two parties which are most affected by the I-14.1 Standard. This fact helped to define shared responsibilities for window cleaning safety by contractors and property managers.
Why you should hire an IWCA Safety Certified Window Cleaner
The International Window Cleaning Association (IWCA) Safety Certification program provides education to help window cleaners work safer by training them in accordance with the safe work practices identified in the IWCA/ANSI I-14 Safety Standard.
As part of the IWCA Safety Certification program, window cleaners study all facets of window cleaning safe practices and equipment. They then must pass three preparatory exams, followed by a final in-person proctored exam. Upon passing the final exam, they will be recognized as being IWCA Safety Certified for five years before being required to renew their certification.
When you are contracting professional window cleaning services, choose one with the training needed to apply best practices and safe use of equipment at your building to protect you, your tenants, and the public.
More information can be found at http://www.iwca.org/
Contractor’s Compliance and Documentation
There are hundreds of rules and regulations that contractors must follow to safely perform their work. In order to protect themselves to the fullest extent, building owners must carefully document all contractor activities. The I-14 requires that building owners receive a “Plan of Service” from their contractors that should include all their activities. Below are some of the documentation that should change hands between property management and window cleaning contractors.
What Contractors Need from Building Owners
* Letter of Assurance of Inspection: A letter informing the contractor that the roof has been inspected and certified
* Copy of Anchorage Certification
* Copy of Manufacturer’s Instructions and Specifications (if necessary): Only needed if there are working parts within the anchorage system.
CLICK HERE FOR BUILDING OWNER ASSURANCE SAMPLE
What Building Owners Need from their Contractor
Assurance of Compliance with Applicable Regulations documentation is vital. Taking a contractor’s word for compliance is insufficient and opens up large possibilities for liability.
- Plan of Service – I-14 requires that the contractor give a detailed plan of how the building will be accessed and cleaned. This plan should include anchorage description and locations, hazardous work areas, drop zones, public protections, and safety features.
- Proof of a Formal Training Program – again, documentation is vital.
- List of Approved Equipment
- Emergency Procedures – get this in writing.
- Fall Protection Letter – this is a letter describing what kind of fall-protection the workers have and will use.
- Certification of Insurance – make sure to have an updated copy before work begins. Keep in mind: if the lawsuit award in court is $5 million and your contractor has only $1 million of insurance, who is picking up the rest of the bill?
What Can VIP Do For You?
As a building owner, property manager or building engineer, you must ask yourself how in the world are you going to keep all the laws, regulations, and standards straight? How do you keep on top of it all? Over and over again, you will find that having knowledgeable contractors as your vendors is the way to go. Window cleaning is no exception. VIP has been a strong crusader for industry standards of safety and offers the following questions you will want to ask a potential window-cleaning vendor.
- Can you facilitate and schedule the required inspections?
- Are you enrolled in the International Window Cleaning certification program and do you have any window cleaners that have completed the certification process?
- Are you an active member of the International Window Cleaning Association and do you attend there safety training seminars?
- Do you ensure proper rigging and safety procedures with a full-time compliance manager?
- Do you have an in-house safety training program?
- Do you have your own quality control manager or do you require the property manager to oversee the quality of your work?
- Do you provide an operational plan of service (OPOS)?
- Do you have signed and logo-ed work trucks?
- How will you educate building engineers and management regarding all pertinent standards and regulations?
- Can you provide $6,000,000 worth of liability insurance?
I-14 Safety Compliance
The window cleaning business could also be referred to as the building access business. Anyone can put soap on glass and wipe it off, but few have the expertise to safely and effectively access the outside of high-rise buildings, while complying with all pertinent codes and standards. This issue is central to the window-cleaning specific American National Standard Institute (ANSI) standards. VIP Window Cleaning will continue to help our customers understand and implement changes at their properties as they relate to the new standards.
In the past, window cleaning contractors and employers of those services had to wade through an overwhelming mass of OSHA regulations and conflicting interpretations on how to apply and comply. VIP regularly conducts seminars for members of the building management associations (such as IFMA, IREM, and BOMA) about the contractor and building owner responsibilities for suspending or asking a person to be suspended from the roof of a building. While the old standards included many pertinent requirements, the window cleaning-specific issues were never addressed. For many years, a window cleaning standard was not recognized by the governing agencies and could not be agreed upon by the various industry committees.
What is an ANSI Standard?
On October 25, 2001, the ANSI approved the IWCA I-14 Window Cleaning Safety draft standard for publication as an American National Standard. The IWCA/ ANSI I-14 Committee is comprised of equal numbers of Users (the window cleaners), Manufacturers (those who make the equipment), and General Interest (including engineers representatives of OSHA, labor, and BOMA). This varied group ensures that multiple viewpoints are represented in order to increase safety in our industry.
OSHA is currently citing window cleaners and building owners while using the ANSI Standard as the reference for the standard. The I-14 is the reference of choice in civil litigation and certain to be cited in liability lawsuits.
What Does the Standard Say?
The I-14 governs the proper use of equipment; outlines accepted types of equipment; and gives clear instruction in the proper use of equipment by the contractor. Most importantly, the I-14 gives very clear-cut responsibilities and were pulled directly from OSHA regulations (especially CFR 1910.66).
Many of our customers simply want to know “What does a Property Manager have to do?”
There are 3 main areas of concern we feel integrate the requirements of the new I-14 Standard and the other standards and regulations already in place.
- Have the roof anchorage system inspected and certified.
- Ensure that fall protection is in place.
- Ensure contractor compliance with proper documentation
Inspections and Certifications There are four types of inspections:
- Initial inspection and certification
- Annual re-inspection
- Pre-work cycle inspection
- Fall protection
1. Initial Inspection:
The initial inspection must be completed by a registered professional engineer. The anchorage system must be certified to withstand a minimum of a 5,000 pound load. The anchorage system may consist of eyebolts, davits and sockets, outriggers, wind-screen posts, columns, structural eye-beams existing on the roof, or just the penthouse.
The initial certification must be completed under the supervision of a registered professional engineer. The fall arrest system anchorage point must be designed and certified to withstand a minimum 5000 lb. load without fracture or detachment. The system may be comprised of roof anchors, davits, outriggers, monorail and horizontal cable systems.
2. Annual Re-Inspection:
Each certification by the engineering firm is good for one year, so the anchorage system must be re-inspected annually. Each re-inspection must be completed by a qualified person defined in the I-14 as “One who has a recognized degree, extensive knowledge, training and experience, or has successfully demonstrated the ability to solve or resolve problems relating to the subject matter and work.” We feel strongly that the registered professional engineer that performed the initial inspection should perform the re-inspection. Remember: Whoever does your inspection could be called upon to testify in a liability lawsuit. You should have the most qualified person performing these important inspections, not the least.
3. Pre-work Cycle Inspection:
The pre-work cycle inspection must be completed by a competent person, defined in the I-14 as “One who, by way of training or expertise, is knowledgeable of applicable standards, is capable of identifying workplace hazardous or dangerous conditions relating to the specific operation, and is designated by the employer and has the authority to take appropriate actions.” This means someone should inspect the site for any hazardous situations before the work begins. We highly recommend that you insist the contractor provide the competent person and sign a document indicating that they have completed this inspection.
4. Fall Protection
I-14.1 states that fall protection, perimeter guarding of at least 42′ high, personal fall arrest systems or a personal fall restraint system as applicable shall be provided for all work areas that expose a workers to a fall hazard when approaching within 6 feet of an unguarded edge or unguarded skylight (with the exception of working on a ladder supported at grade or using a window cleaner’s belt.) The most common problem a property manager will encounter is that many rooftop parapet walls are less than the required 42′ height. Therefore, fall arrest or personal fall restraint must be engaged prior to approaching within 6 feet of the edge. A rooftop safety evaluation can and should be performed by a competent individual.
VIP Building Services’ safety training program meets or exceeds OSHA regulations, and we are long-time, active members of the International Window Cleaning Association (IWCA) and International Window Cleaning Certification Institute (IWCCI). The VIP safety training curriculum educates employees on how to apply OSHA and ANSI standards to live, on-site situations and to utilize the IWCA certification course safety and self-rescue techniques, including:
basics of safety and planning
rope descent systems and suspended scaffold
proper equipment maintenance
safe chemical use
New VIP employees are required to attend and pass our own rigorous and comprehensive training. We train and re-train technicians for the safest and most qualified employees in our market. All window cleaning technicians are expected to complete the IWCCI’s certification process within 24 months of the first day of employment.
VIP Building Services puts considerable effort into keeping up with safety regulation changes and updates; managers and supervisors attend safety training and seminars all over the country. Our customers appreciate the peace of mind that comes from employees who are educated with an emphasis on safety.
The Occupational Safety and Hazard Administration (OSHA) is the federal agency tasked with the enforcement of all workplace safety and health legislation. At VIP Building Services, safety is our number one priority. Keeping in compliance and current with industry regulations are a large part of our commitment to a safe working environment for our employees, as well as safe practices for our clients and contractors.
OSHA provides a convenient enforcement database online in order to quickly verify a company’s safety records. The site includes all the information the vendor may have already given, or failed to mention, about their history… the good, the bad and the ugly. Follow this link to access OSHA’s Establishment Search database.
Use the OSHA resources to help choose your next vendor and verify a company’s use of safe, best practices. Put the name of the company you want to search in the “Establishment” field. Select “Arizona” from the drop-down list. Once the list of matches is shown, you may see the details by clicking on the activity numbe, underlined in blue. Keep in mind, when searching for the establishment (company), try using the first name initially, rather than the entire company name. As an example, to search for “Blue-Sky Window Cleaning” start by entering only “blue.” You may have better results with broad search terms rather than the specific, or full company name.
For current OSHA information, compliance and regulations, visit www.osha.gov.