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Window Cleaning: Guideline for the Design, Installation and Use of Fall Arrest Anchor Points, Tie-Back Anchor Points and Primary Support for Suspended Equipment Systems

Disclaimer: This resource has been prepared to help the workplace parties understand some of their obligations under the Occupational Health and Safety Act (OHSA) and regulations. It is not legal advice. It is not intended to replace the OHSA or the regulations. For further information please see full disclaimer.

This guideline has been prepared to help workplace parties understand and comply with some of their obligations under the Regulation for Window Cleaning, R.R.O. 1990, Regulation 859 ("Regulation 859" or "Reg. 859") and the Occupational Health and Safety Act (OHSA) as they apply to window cleaning.

Its purpose is to assist design engineers, building owners, employers, supervisors and workers by setting out some of the requirements of Regulation 859 as it applies to:

  • roof anchor points for existing and new buildings
  • the design and installation of anchor points
  • appropriate use, and
  • maintenance considerations.

This guideline references the following sources:

  • The OHSA
  • Regulation 859
  • CAN/CSA Standard Z91-02 "Health and Safety Code for Suspended Equipment Operations"
  • CAN/CSA Standard Z271-10 "Safety Code for Suspended Platforms"
  • CAN/CSA Standard Z259 -10 "Full Body Harness", and
  • CAN/CSA Standard 3-Z11-M81 "Ladders".

The OHSA, in conjunction with Regulation 859, outlines the legislative and regulatory requirements for engineers, building owners, employers, supervisors and workers in the window cleaning industry. Each owner, employer, supervisor and worker is required to be familiar with and comply with the legislation and its regulations. All of these workplace parties have responsibilities under the OHSA and its regulations. It is important to note that the term "employer" under the OHSA includes a contractor or subcontractor who performs work or supplies services and a contractor or subcontractor who undertakes with an owner, constructor, contractor, subcontractor to perform work or supply services.

In the context of window cleaning workplaces, inspectors with the Ministry of Labour will apply and enforce the requirements of the OHSA and its regulations based on the facts as they may find them in the workplace. This Guideline does not affect their enforcement discretion in any way. However, an inspector may refer to the Guideline in determining whether an employer has taken every precaution reasonable in the circumstances for the protection of a worker as required under the OHSA.

Regulatory requirements and best practices

Notification requirements

Before any worker begins window cleaning at a building for which a suspended scaffold, boatswain's chair or similar single-point suspension equipment is used, every employer, contractor and sub-contractor who proposes to carry out window cleaning at the building shall give notice of the proposed window cleaning by telephone to an inspector in the office of the Ministry of Labour that is nearest to the building [Reg. 859, section 7(1)].

An electronic Notice of Window Cleaning Work form is available from the Ministry of Labour website.

Fall protection

Fall arrest system

The fall arrest system shall:

  • arrest any fall by the worker without applying a peak force to the worker greater than 8 kN [Reg. 859, section 10(3)(a)]
  • permit the worker to remain suspended safely in it for a period of at least thirty minutes [Reg. 859, section 10(3)].

All fall arrest components should be compatible and Canadian Standards Association (CSA) certified.

When workers are required to access a roof or similar elevated area and to travel within 2 m of an edge or opening that poses a fall hazard, fall protection should be provided by one or more of the following (in descending order of preference):

  • a fixed guardrail or a fixed parapet that offers protection equivalent to a guardrail
  • a fall-arrest system or travel restraint system for each worker whenever the worker is within 2 m of an unprotected edge, and
  • a temporary guardrail [clause 9.3.1 CAN/CSA Z271-10].

Fixed support

If a worker who is not working from a ladder is exposed to the hazard of falling more than 3 m, the worker shall use a fall arrest system that is adequately secured to a fixed support and arranged so that the worker cannot fall freely for a vertical distance of more than 1.5 m [Reg. 859, section 10(2)].

Suspended scaffolds

All suspended scaffolds that are designed for the purpose of gaining access to exterior and interior surfaces of buildings and other structures shall be designed in accordance with applicable regulations and should be designed in accordance with applicable standards.

Every primary suspension line used in connection with a suspended scaffold shall be rigged so that each line hangs vertically from the roof or access level to the ground or level of egress of a worker using the line [Reg. 859, section 27].

Stabilization of suspended scaffolds under 45 metres (150 feet)

Restraint of a suspended platform to the exterior face of a building or structure at suspension heights from 15 m to 45 m shall be provided by angulated roping or by a purpose built stabilization system [CAN/CSA Z271-10 clauses 9.5.2, 9.5.1.2, 9.5.1.3].

Stabilization of suspended scaffolds over 45 metres

The exterior face of a building or structure shall have a positive means of restraining the suspended scaffold to the building or structure when the suspension height exceeds 45 m [CAN/CSA Z271 clause 9.5.1.1].

Boatswain's chair

A boatswain's chair shall not be used where the descent exceeds 90 m [Reg. 859, section 28].

Mid-air transfers from one boatswain's chair to another are prohibited.

Access and egress

In the case of an existing vertical ladder used at an industrial establishment, as defined by the OHSA, the requirements of section 18(1)(d) of the Industrial Establishments Regulation [R.R.O. 1990, Reg. 851] would apply.

A ladder, used to access a roof through a hatch way, shall be capable of extending at least 1 m beyond the roof hatch in order for a worker to maintain three-point-contact while he or she attempts to access the roof surface.

Adequate means for safe access of workers shall be provided where the height of a parapet exceeds 1.07 m and an adequate fall protection system shall be used where the height of a parapet exceeds 3 m [clause 9.3.2 CAN/CSA Z271.10].

Every worker who is on, or is in the process of getting on or off a suspended scaffold or a boatswain's chair or similar single-point suspension equipment shall be protected by a fall arrest system [Reg. 859, section 31].

Anchor points

Every owner of a building where a suspended scaffold, boatswain's chair or similar single-point suspension equipment is to be used for window cleaning or where sill work is done shall, among other things:

  • ensure that any faulty anchor point is repaired
  • ensure that any anchor point is suitable for use for window cleaning and sill work before being used
  • keep a record of the inspections of any anchor points, (including davit bases, monorail systems, stabilizer systems, rope stops) and permanently-installed suspended scaffold in a log book
  • maintain and retain the log book as long as the anchor points and suspended scaffold equipment are used
  • ensure that the name and signature of the person making the inspection is recorded, and
  • record any modifications or repairs made to an anchor point or a suspended scaffold, including the date they are made and the name and signature of the person making the modifications or repairs [Reg. 859, section 41].

Strength requirements for anchor points

The support capability of an anchor point shall exceed the total breaking strength of all support lines attached to it [Reg. 859, section 29(2)].

Anchor points for vertical lifelines, equipment tieback and direct attachment of primary lines for suspended equipment shall:

  • be designed to resist the application of a force of 22.2 kN (5000 lbf) in any direction without fracture of any component or pullout, or both from the anchorage [clause 9.4.3(a) CAN/CSA Z271-10], and
  • resist a test loading of 11.1 kN without permanent deformation of any component when subjected to test loading in the direction(s) that generate the most critical effect on the anchorage system with respect to stability and strength [clause 9.4.3 (b) CAN/CSA Z271-10].

Note: the above tests shall be witnessed and certified by a professional engineer.

Adhesive anchor points

Adhesive anchor installations shall:

  • incorporate a minimum of three adhesive inserts per anchor
  • be designed by a professional engineer
  • only use inserts that are made of stainless material, and
  • be installed under the direction of a professional engineer.

Systems incorporating adhesive expansion fasteners shall also have 100% of the anchor points load tested at intervals not exceeding five years [CAN/CSA Z271-10 clause 9.4.3 (b)].

Anchor attachment on parapet walls

Generally, pre-cast concrete and cast-in-place concrete parapet walls designed as part of an original wall design are acceptable for installation of anchors for window cleaning purposes and/or the support of parapet wall clamps, provided the parapet wall is approved by a professional engineer who is aware of loads to be placed on the wall.

Location of anchors

A tie-back anchor elevation for a portable outrigger shall not be more than 1 m above the point of suspension [CAN/CSA Z91-02].

Lifeline and tieback anchors should be located in line with the point of suspension whenever practical, but shall not be offset more than 3 m (10 ft) measured horizontally from a line running at a right angle to the building face at the point of suspension. The angle created by the offset distance shall not exceed 25 degrees [5.4.4 of CAN/CSA Z91-02].

Continuous rail anchor

A continuous rail may generally be substituted for a series of separate anchors if it has been designed by a professional engineer for the intended purpose. It is also generally acceptable to tie both equipment tieback and lifelines to the rail or beam provided that each line is attached to a separate trolley and the system is designed by a professional engineer for all loads likely to be applied as if it were an extension of the roof structure, and installed in accordance with the design.

Certification of the building support structure

The structural adequacy of the building to support built-in-place anchor points used to support lifelines and suspension equipment in new construction must be verified in writing by the professional engineer in charge during the construction of the building.

The structural adequacy of a structure to support retrofitted anchor points, used to support lifelines and suspension equipment, must be verified in writing by a professional engineer.

Inspection reports

Every owner of a building where a suspended scaffold, boatswain's chair or similar single-point suspension equipment is to be used for window cleaning or where sill work is done shall cause all anchor points and permanently-installed suspended scaffolds to be inspected by a competent person before being used for the first time and thereafter as often as necessary but not less frequently than recommended by the manufacturer of the anchor points or the suspended scaffolds, as the case may be, and in any case, at least once a year; and when informed under section 43 of a defect or inadequacy [Reg. 859, section 41(1)].

Clause 11.3.3 of CAN/CSA Standard Z271-10 provides guidance for new or altered anchor points.

The inspection shall include, but not be limited to:

  • a review of the design drawings to ensure compliance with current regulations, standards and engineering standards
  • an assessment of the system to ensure compliance with the engineered drawings
  • an inspection of all exposed, visible and accessible components of the system for signs of distress, and
  • an inspection of all adhesive and expansion fasteners [CAN/CSA Z91-02 clause 7.3.2.2].

A building owner shall obtain a signed and sealed inspection report from a professional engineer concerning the inspection of the anchor system. This report should also be included in the equipment log [CAN/CSA Z91-02].

A building owner shall keep a record of the inspections of any anchor points and any permanently installed suspended scaffold at a building in a log book to be maintained and retained as long as the anchor points and suspended scaffold are used, showing:

  1. (a) the date on which each inspection is made
  2. (b) the name and signature of the person making the inspection, and
  3. (c) any modifications or repairs made to an anchor point or a suspended scaffold, including the date they are made and the name and signature of the person making the modifications or repairs [Reg. 859, section 41(5)].

Static lines

Static or horizontal lines that are rigged between anchor points and to which lifelines or primary support lines are directly attached must be used as a professional engineer directs, and the professional engineer must certify the maximum load to be applied to the static or horizontal line [Reg. 859, section 29].

Davit bases

Generally, a davit base with an attachment point may be used as anchor for a life line or tie back if:

  • it is permanently attached to the structure
  • for new installations a letter sealed and stamped by a professional engineer is provided stating that the main structure, the davit arm base and the method of connection between both are adequate to withstand all the applied loads, or
  • the connection between the davit arm base and the main structure was performed in accordance with the Ontario Building Code and applicable regulations and is permanently attached.

Davits – used to support a 4-point suspension system

Section 3 of Regulation 859 may be used by an employer or building owner to vary the design or arrangement of any material, object, device or thing required by the Regulation provided the variation affords equal or greater protection to the health and safety of workers. The onus is on the employer/building owner to demonstrate that the varied method of protection meets or exceeds the protection that would otherwise be provided by complying with what is prescribed in the Regulation. An inspector's determination of what may be considered acceptable under section 3 will be made on a case-by-case basis.

Permanent davits – used to support a 4-point suspension system

Where an employer or building owner intends to rely on section 3 to use permanent davits, to demonstrate that the use of permanent davits affords equal or greater protection to the health and safety than would otherwise be provided by complying with what is required by the Regulation, the employer/building owner should be able to show:

  • it is designed according to good engineering practice
  • it can be considered part of the structure, and
  • it is able to withstand all loads that may be applied.

Portable davits – used to support a 4-point suspension system

Where an employer or building owner intends to rely on section 3 to use portable davits, to demonstrate that the use of portable davits affords equal or greater protection to the health and safety than would otherwise be provided by complying with what is required by the Regulation, the employer/building owner should be able to show:

  1. a letter from a professional engineer stating that: the portable davit is capable of withstanding all loads that may be applied
  2. that the connection of the davit arm to the base is sufficient for all possible loading conditions
  3. that the davit is adequately secured in place (i.e. retaining pins through bolts to prevent nuts from working lose)
  4. that if different davit – arms are present then each arm and each base is identified and appropriately marked on the rooftop layout drawing
  5. an annual inspection by a professional engineer is carried out and inspection records are maintained
  6. that the welds on aluminum davits are inspected by non-destructive techniques (NDT) annually (by a certified company in accordance with CAN/CSA W47.1.) to ensure their structural integrity and that they comply with CAN/CSA W59 for welding and fabrication, and finally
  7. a professional engineer's statement that the arrangement used affords equal or greater protection to the health and safety of workers.

Portable davit handling

Suspension equipment should be designed so that the maximum weight of any portable component does not exceed 70 kg. Consideration should be given to the ergonomics of handling and erecting the equipment with not more than two workers [CAN/CSA Z271-10 clause 7.2.1].

Where there is a risk of portable equipment (davits & outriggers) falling over the edge of a roof during setup, it shall be secured by a safety cable or equivalent before installation and it shall remain in place until the work has been completed [clauses 5.5.3 and 5.5.4 CAN/CSA Z91-02 and clause 9.13.1 CAN/CSA Z271-10].

Lifelines

A lifeline used in a fall arrest system, shall:

  • be suspended separately and independently from any suspended scaffold, boatswain's chair or similar single-point suspension equipment [Reg. 859, section 10(6)(c)], and
  • be free from the danger of being chafed or cut [Reg. 859, section 10(6)(b)].

Every lifeline used in connection with a suspended scaffold that is permanently installed on a building or structure; a suspended scaffold that is transported in component form and is assembled for use at a work site; and a boatswain's chair or similar single-point suspension equipment intended for the support of one worker shall, among other things:

  • be rigged in accordance with generally accepted rigging practice
  • be rigged so that each line hangs vertically from the roof or access level to the ground or level of egress of a worker using the line, and
  • have a breaking strength of at least ten times the static load that the line is intended to support [Reg. 859, section 27(1)].

Lifeline rope shall be of a type that is resistant to deterioration by chemical solutions used in operations and by exposure to atmospheric conditions of sunlight and moisture. All non-metal ropes that are not specifically designated as UV rated for exterior use shall not be used [CAN/CSA Z91-02 clause 5.2.6].

The termination of a worker's lifeline shall not be connected to portable equipment such as a parapet wall clamp, davit boom, cornice hook or outrigger beam [clause 5.3.3 CAN/CSA Z91-02].

Lifelines shall not be rigged where they can exert any force on a balcony or terrace rail unless the item or system has been engineered to support all loads to which it may be subjected to [clause 6.5 of CAN/CSA Z91-02].

The lifeline may be redirected from an anchor point to a davit arm or a certified engineered device providing a letter from a professional engineer states that:

  • the davit arm/device is capable of resisting all arrest forces when a worker falls
  • the davit arm/device is not used to support any suspension lines or other lifelines
  • the davit arm/device must be tied back to an anchor with an adequate steel sling, and
  • arranged so that the worker cannot fall freely for a vertical distance of more than 1.5 m.

Where there is a risk of a lifeline slipping around the edge of a building, engineered rope stops/rope deflectors shall be installed [CAN/CSA Z91-02 clauses 5.4.6 and 5.4.7].

Question

Can suspension lines and life lines follow the profile of the building from the roof/or access level? (See Figure 1).

Figure 1

Figure 1: The drawing shows a lifeline that descends vertically along the wall of a building compared to a lifeline that follows the profile of the building.

Answer

Section 3 of Regulation 859 may be used by an employer or building owner to vary the design or arrangement of any material, object, device or thing required by the Regulation provided the variation affords equal or greater protection to the health and safety of workers. The onus is on the employer/building owner to demonstrate that the varied method of protection meets or exceeds the protection that would otherwise be provided by complying with what is prescribed in the Regulation.

An inspector's determination of what may be considered acceptable under section 3 would be made on a case-by-case basis.

Where an employer or building owner intends to rely on section 3 to arrange the lines in a non-vertical configuration, to demonstrate that this varied arrangement affords equal or greater protection to the health and safety than would otherwise be provided by complying with what is required by the Regulation, the employer must be able to show:

  1. a letter signed and stamped by a professional engineer stating that the arrangement of the lines in a non-vertical configuration affords equal or greater protection to the health and safety of workers
  2. that there is no potential of the worker swinging across the building
  3. that the lines are free from the danger of being cut or shaved at the point of redirection
  4. that the redirecting structure is capable of withstanding loads applied from a falling worker or a suspended scaffold, and
  5. that the added distance of redirection over another structure is taken into account to ensure that both the primary suspension lines and the lifeline are long enough to reach the landing or ground surface.

Lanyards

A lanyard used in a fall arrest system shall have a nominal diameter of at least 16 mm and be made of nylon rope or another durable and adequate material [Reg. 859, section 10(5)]. However, a shock absorber type lanyard (certified by CSA) is recommended as best practice and it should be as short as possible. In addition, it should be compatible with the components used in the fall protection system.

Electrical hazards

Electrical equipment, power lines and insulating materials shall be suitable for its or their use and be installed, maintained, modified and operated so as not to present a hazard to a worker [Reg. 859, section 32].

Raising and lowering lines on buildings over 90 m

Consideration should be given to the ergonomics of lifting electrical and suspension lines on buildings greater than 90 m in height. Mechanical means shall be used to raise or lower lines where the height exceeds 90 m [CAN/CSA Z91-02 clause 5.2.4].

Communications

Every worker on a suspended scaffold, boatswain's chair or similar single-point suspension equipment shall have an effective means of summoning assistance in case of emergency [Reg. 859, section 31].

Note: Generally, an effective means of summoning assistance is based on site specific conditions where the means of summoning assistance can be easily heard and understood by a person from any part of the building. In some cases, a cell phone or other electronic device may be required as a reasonable precaution for the safety of a worker.

Roof sketch

Every owner of a building where a suspended scaffold, boatswain's chair or similar single-point suspension equipment is to be used for window cleaning shall prepare a sketch or sketches showing all anchor points and related structures on the building that are suitable and adequate for the attachment of the suspended scaffold, boatswain's chair or similar single-point suspension equipment and the lifeline [Reg. 859, section 39(1)].

As a minimum, the sketch should include, but not be limited to:

  • a plan view showing essential structural members, including anchors and approach anchors
  • details of the equipment and its installation
  • the safe working loads of the equipment and any use restriction on the equipment
  • all relevant obstruction and structures or other obstacles that impede the safe use or operation, or both, of the equipment
  • the distance between anchors
  • the location of all windows
  • details of anchor system including, capacity, size and material used for every component
  • related codes and standards used in designing the anchor system
  • a self-rescue plan, and
  • drawings that are signed and sealed by a professional engineer – clause 8 of CAN/CSA Z91-02.

The building owner must provide a copy of the sketch(s) to the person supplying the window cleaning services before the work is begun and no employer may permit a worker to engage in window cleaning using a suspended scaffold, boatswain's chair or similar single-point suspension equipment until the employer has received a copy of the sketch or sketches [Reg. 859, section 39(2)].

The building owner shall post a copy of the above noted sketch(s) near the entrance to the roof [Reg. 859, section 39(3)].

Work plan

Every employer who proposes to carry out window cleaning using a suspended scaffold, boatswain's chair or similar single-point suspension equipment or to carry out sill work shall prepare a work plan in writing, signed by the employer, indicating the manner in which any primary support lines and lifelines used are to be attached to the anchor points or related structures shown on any sketch(s) required by Regulation 859 and setting out such other information as may be required for the safety of workers. [Reg. 859, section 42(1)].

A work plan shall be prepared by the employer based on the roof sketch. The work-plan shall describe the intended work methods and necessary rigging procedures in accordance with the roof sketch. The work plan shall include, but not be limited to:

  • the name of the building owner or contact person, including address and telephone number
  • the name of the work site supervisor, including address and telephone number
  • a general description of work
  • the procedure for fall protection
  • showing the tie in locations for the lifelines and the suspension lines for every window cleaning drop on the roof sketch
  • the procedure for equipment rigging and usage of the manufacturer's operating and maintenance manual, included, but not limited to, the permanent and/or portable equipment rigging plans
  • contact name(s) and phone number(s) in case of emergency
  • emergency procedures, including but not limited to: worker injury, equipment damage/failure, and an emergency response plan.

A copy of the work plan is to be provided to each worker who engages in window cleaning or sill work at the building and shall retain a copy for examination by an inspector [Reg. 859, section 42(2)].

No worker shall begin window cleaning that requires the use of a suspended scaffold, boatswain's chair or similar single-point suspension equipment and no worker may begin doing sill work until the worker has received a copy of the work plan [Reg. 859 section 42(3)].

Supervision

Every employer of a worker who engages in window cleaning using a suspended scaffold, boatswain's chair or similar single-point suspension equipment and every contractor and sub-contractor who proposes to carry out window cleaning in that manner shall appoint a supervisor. In addition, the supervisor shall visit the location of the window cleaning operation at least once daily [Reg. 859, section 44].

Glass surfaces

Workers shall not walk on or place any significant loads on any glass surface or frame, or both, in a skylight or atrium or canopy unless the glazing system has been engineered to safely permit this access method [CAN/CSA Z91 clause 6.1.3].

Training

For training requirement refer to section 9(2) and section 45 of Reg. 859 and reference should also be made to clause 3 of CAN/CSA Standard Z91-02.

Public protection

Equipment shall be secured from unauthorized use by mean of a lockout, disabling of the power source, or equivalent means. The public must be restricted from access to the support system area by adequate barriers, warning signs, or equivalent safeguards. The equipment, when not in use should be secured in a stored position [clause 7.1 CAN/CSA Z91-02].

If practicable, signs containing the words "DANGER – WORK OVERHEAD" in legible letters must be posted in prominent locations and in sufficient number to warn pedestrians that window cleaning is being carried out overhead. [Reg. 859, section 12.]

Table 1: Metric symbols and imperial equivalents
Metric Imperial
kN = kilonewtons lbf = pound force
kg = kilograms lb = pounds
m = metres ft = feet
mm = millimetres in = inches

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