Preparing for OSHA Rule 1910

January 7, 2018 | By: David Vences
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Edvard Munch painted a figure with an agonized expression set amongst a tumultuous orange sky landscape commonly known as “The Scream.” This painting has a few meanings, but to me, it depicts an overwhelmed person in a panic. It’s eyes and mouth are wide open along with one hand on each side of its face like the classic Macaulay Calkin scene on Home Alone.

With an upswing in the economy where jobs are more plentiful, income is rising, and housing prices are recovering to pre-recession level, I can honestly say that business is good. So, what does that mean? From a Building Engineer stand point it means that we will be extremely busy with capital projects, tenant improvements, and other building operation related jobs. Being so busy, doesn’t allow us to turn a blind eye to the upcoming industry changes like the new OSHA Rule 1910. This rule is slated to take effect on Nov. 18, 2017. This standard focuses on OSHA’s Walking-Working Surface regulations under new fall protection regulations which are intended to increase worker safety and limit the number accidents associated with the use of stairs, ladders and other elevated work surfaces. As a building engineer who maintains class A commercial office buildings, I will have to comply because not only do I not want to end up like the figure in Edvard’s painting but because it is my duty to protect building assets and its people through risk management assessments and maintenance.

Panic can be avoided by simply understanding what exactly this standard is asking for and the actions you and your management team will have to take to be prepared on these key provisions of OSHA Rule 1910.

Every property management teams wants to maintain and show off the outside of their building. However, when it comes to repairing cracks, pressure washing, and cleaning windows, this OSHA rule could affect how you maintain your building; if you are not in compliance. From the building engineer role, what has helped me become successful in my career is not just knowing about standards or guidelines but rather working with my vendors and my network through BOMA and its events. They know and work around these systems and want to protect their most valuable assets too; people.  I asked Jon Tobiaz with Everclear Enterprises about his thoughts on this new regulation.

He said, “These regulations are not exactly new.  They are described in the I-14 standard, a 38-page safety procedures document put together by the members of the International Window Cleaning Association (IWCA)…” Then I clearly remembered Bob Fuhr’s previous article, in Insight Issue 3 of 2017, saying that it was a standard given through ANSI I-14 Window Safety Standard in October of 2001 however, now it would be “the new law of the land.”

From a property management prospective, the I-14  standard left the industry in a bit of a grey area where contractors and building management were essentially “strongly encouraged” to follow these guidelines.

“This past November OSHA decided to take it a step further and passed the new final rule (1910) taking many of the guidelines from the I-14 and official and making it a mandate/law”, says Jon Tobiaz with Everclear.

They, like many window washing companies, will require the anchors/tie offs to be load tested (and passed) within the last 10 years, and the anchors/tie offs have been visually inspected (and passed) within the last 12 months.

So how can building management teams get in compliance?  Talk to your fall protection and solutions vendors. I spoke with Travis Nelson with Peak Fall Protection who has been involved in our new roof replacement project. They provide fall protection solutions and he explained that there are various revisions to the revised 1910 Subpart D standard, but there are three revisions that will likely have greatest impact on commercial properties.

First, 1910.27 outlines guidelines for anchorage systems that support rope descent systems (RDS), more commonly referred to as bosun’s chair access. Anchorage systems are to be tested, certified, and maintained prior to use with documentation of certification provided to the window cleaning (or other RDS contractor) prior to use.  Certification is to be completed by a qualified person and current within 10 years of issue.  Inspections are to be conducted annually by a qualified person.  Anchorages must be located to allow for compliant use and proper rigging which may require installation of supplemental anchorage points.  Anchorage systems are to be certified for use prior to 11/20/17 which is the OSHA specified phased in compliance date.

Next, 1910.28 outlines need for rooftop fall protection based on distance from building edge, height of parapet wall or guardrail, and training requirements.  Buildings with parapet height less than 39” will require a fall protection study to determine access needs and how to most effectively address with a fall protection solution which will vary based on proximity to the edge, maintenance frequency, fall severity, level of user training, and other requirements.  All walking-working surfaces should be inspected regularly and as needed to prevent hazardous conditions and to ensure clean, orderly, and sanitary condition and free of sharp or protruding objects, corrosion, leaks, etc.

Also, 1910.23 provides guidelines for ladders.  Many of the dimensional requirements are unchanged, but many existing ladders although manufactured properly, are not installed with consideration of adjacent obstructions, foot clearance issues, step-off distance, or connection to walls to name a few.  Review of existing fixed ladders should be conducted as part of the overall fall protection study to determine compliance with the revised standard.  Additionally, fixed ladders greater than 24 ft. in height must be equipped with a ladder climbing fall arrest system.  This requirement is effective for any such ladder that is installed on or after 11/19/18, and for any existing ladder on or after 11/18/36.

Many management groups release Building Improvement (BI) funding during different times of the year and one of the questions that gets asked is, “Do you have anything that needs to be done this year and where would you place it in terms of priorities”? At this point, the management/engineering team would get together and weigh out the options/priorities. If the team plans on getting in compliance with this new standard, they would have to provide three or four quotes along with a compensation sheet to determine their best choice. So, it would not be a bad idea to proactively have this prepared. If you run into problems locating a vendor, the BOMA allied member directory and your industry network would be resourceful in helping you and your management team in compliance with OSHA Rule 1910.