What Are Cal/OSHA's Rules for Commercial Window Cleaning?

What do the Cal/OSHA window cleaning safety orders cover?

Article 5 sits in Group 1 of the General Industry Safety Orders and runs from definitions to the design of rooftop equipment. Section 3282 holds most of the general rules; the sections after it deal with specific equipment.

When are window cleaning anchors required?

Section 3282(g) sets the trigger. Where a cleaner stands on a sill or works from inside an opening large enough to fall through, window cleaning safety anchors or other anchorages approved by the Division must be installed. A window counts as that kind of hazard when its fully opened clear opening is more than 18 inches in its smaller dimension, or when its proportions otherwise present a fall hazard.

Buildings without that condition still need a safe method, and the order lists the options: aerial platforms, rolling scaffolds, suspended scaffolds, boatswain's chairs or ladders, each used as the article specifies. A cleaner moving from sill to sill outside a building must keep one belt terminal attached at all times, and no one may work from a sill that is obstructed or slippery, or from any surface the building's engineer of record or a building official has not rated for the load.

What must the building owner provide before work starts?

Section 3282(p) puts specific duties on owners whose buildings have anchors, davits, platforms or other installed equipment for window cleaning. Before that equipment is used, the owner must give the employer written assurance that it meets the orders, covering items such as anchors, platform load capacity, stability, wire rope and electrical design. The covered devices must be inspected at least every 12 months and tested where necessary.

Buildings 36 feet or taller may also need an Operating Procedures Outline Sheet, prepared by a qualified person, where they have no established procedures, where modifications changed them, or where unusual architecture or rigging calls for one. The employer may not let workers use the building's equipment until it has copies of the written assurance and any required outline sheet, so missing paperwork can stop a job at the roof hatch.

• Inventory every anchor, davit, track and platform on the roof and facade
• Schedule inspections at least every 12 months, with testing where needed
• Keep the written assurance current and ready to hand to each contractor
• Check whether the building needs an Operating Procedures Outline Sheet
• Have structural modifications designed by a California-registered engineer
• Record the live-load rating of any ledge or roof surface crews may stand on

When can windows be cleaned from ladders?

Only when anchors and belts cannot do the job safely and practicably. Section 3287 treats ladders as a last resort and bars them for any window that would need a fully extended extension ladder longer than 40 feet. Ladders with a working length over 18 feet need a second person at the foot, facing the ladder and holding it with both hands.

The rest of the section reads like a field checklist: daily inspection with defective ladders tagged out of service, no standing on the top three rungs without a firm handhold or fall protection, no ladders set on boxes or other unstable bases, none placed in front of doors unless the door is blocked open, locked or guarded, and no hooked ladders hung over parapets.

What to ask a window cleaning contractor

Section 3282 requires employers to train cleaners on their equipment, supervise its use and assign only properly trained employees to scaffolds or boatswain's chairs. Asking these questions at the bid stage shows quickly whether a contractor plans the work or improvises it.

• Which access method will you use on each elevation, and why?
• Have you received our written assurance and any outline sheet the building needs?
• How is the crew trained on the equipment it will use, and who supervises it?
• How are belts, harnesses and ladders inspected, and is the inspection recorded?
• How will pedestrians, entrances and parking below the work be protected?
• Which elevations, if any, go to a suspended-access specialist?

Where EBS fits on window cleaning

EBS cleans interior and exterior glass, frames and sills on a set schedule for storefronts, offices and multi-story buildings, scoped elevation by elevation at the walkthrough. Facades that need suspended access from the building's rigging are a separate specialty, and the walkthrough is where that line is drawn for each one. EBS crews are trained before a site assignment, supervisors inspect completed work, and the company is licensed and insured.