APPLICABLE CODES & STANDARDS

VIP's COMPLIANCE PROGRAM
In many ways, the window cleaning business could be better termed the building access business. While there are many who could put soap on glass and wipe it off, few have the expertise to safely and effectively access the outside of high-rise buildings and have the company infrastructure to comply with all pertinent codes and standards. This issue has assumed center stage as a window cleaning-specific ANSI Standard has been created. To answer the demands of this new Standard, VIP Window Cleaning has expanded its management capabilities to assist our customers in understanding and implementing the changes as they relate to this new standard.

In the Past
In the past, window cleaning contractors and those who employed them had to wade through a overwhelming mass of OSHA regulations and conflicting interpretations on how to apply them when trying to comply with accepted safety standards in our industry. We know, because we have given seminars for building management associations (such as IFMA, IREM, and BOMA) concerning the responsibilities of the contractor and building owners whenever a person is suspended from the roof of a building. While there were many pertinent requirements in the old standards, many window washing specific issues were never mentioned. For many years, a desperately needed window washing standard was unable to be agreed upon by various committees.

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What is an ANSI Standard?
On October 25th, 2001, the American National Standard Institute (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 a quest to increase safety in our industry.
OSHA is currently citing window cleaners & building owners and using the ANSI Standard as the reference for the standard. The I-14 is the reference of choice in civil litigation and sure 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. Perhaps most importantly, the I-14 gives very clear-cut responsibilities which were pulled directly from OSHA regulations (especially CFR 1910.66.)

What Must Be Done?
Many of our customers simply want to know "What does a Property Manager have to do?"
There are 3 main areas of concern that we feel integrate the requirements of the new I-14 Standard and the other standards and regulations that are already in place.
1. Have the roof anchorage system inspected and certified.
2. Ensure that fall protection is in place.
3. Ensure contractor compliance with proper documentation.

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Inspections and Certifications
There are four types of inspections:
* Initial inspection and certification
* Annual re-inspection
* Pre-work cycle inspection
* Fall Protection
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 & sockets, outriggers, wind-screen posts, columns, structural eye-beams existing on the roof, or just the penthouse.
Annual Re-Inspection:
Each certification by the engineering firm is typically only 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!
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." What does this mean? It means that someone should inspect the site for any hazardous situations before the work begins. The question is who wants to be the competent person? We highly recommend that you insist that the contractor provide the competent person and sign a document indicating that they have completed this inspection.

Fall Protection
I-14.1 states that fall protection, perimeter guarding (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.

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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 the activities of their contractors. The I-14 requires that building owners receive from their contractors a "Plan of Service" that should include all of 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
* Assurances 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 The 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 - Again, get it 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 that you have an updated copy before any work is begun. One thing to think about, if the lawsuit award in court is for $5 million and your contractor has $1 million of insurance, who is picking up the rest of the bill?

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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 different.
The cause of increasing safety in our industry has been VIP Window Cleaning's crusade for over a decade. Some of the things that VIP can do for you include:

Now Let's Compare Apples to Apples
The Questions you may want to ask the other vender...
* 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?