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Site Assessments and Work Plans

by Stefan Bright

There has been a lot of chatter regarding the new OSHA regulations as they seem to be very specific to the window cleaning industry. The new Walking and Working Surfaces Subpart D Regulations pertain to fall hazards, portable ladders (and fixed) falling object hazards and training. Every professional window cleaner in the USA is exposed to some type of all 4 of these topics on a daily basis.

While these regulations were just finally revised and published in January of 2016, there is reference within them to a universally more important regulation which was published in 1994 an goes unnoticed until an accident, injury or OSHA investigation occurs.

The newly revised WWS Subpart D often refers to the “plan” of service and actually references the I-14 Standard (IWCA-2001 version), when it comes to window cleaning. However, OSHA has been enforcing the importance of having a work plan for nearly 23 years. Those regulations are found in the same Code of Federal Regulations (CFR) Section 1910 but further back in 1910.132. Following is an excerpt from the beginning of that section.


1910.132(d) Hazard assessment and equipment selection.
1910.132(d)(1)

The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). If such hazards are present, or likely to be present, the employer shall:


1910.132(d)(1)(i)

Select, and have each affected employee use, the types of PPE that will protect the affected employee from the hazards identified in the hazard assessment;


1910.132(d)(1)(ii)

Communicate selection decisions to each affected employee; and,


1910.132(d)(1)(iii)

Select PPE that properly fits each affected employee.


1910.132(d)(2)

The employer shall verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the date(s) of the hazard assessment; and, which identifies the document as a certification of hazard assessment.

Remember that PPE (Personal Protective Equipment) is not limited to gloves, glasses, respirators and boots. Because of the newly revised regulations, any reference to PPE includes safety nets, guardrails, fall restraint and fall arrest systems; which also include anchors, ropes, cables, lanyards and harnesses.

Workplace hazard assessments are accomplished by visiting each location where you or your crews will work to identify what hazards they may encounter and how to avoid them. If you can, use your slow season to your advantage, and visit all of your contracted worksites. The number of hazards that a professional window cleaner encounters at a typical site is less than a dozen, but each has a level of concern that must be properly addressed. Once identified, these hazards need to be written into a work plan which includes what methods your workers will employ to avoid exposure to the hazard. That would include specifying any PPE which may be needed.

The following list includes most of the hazards any professional window cleaner may encounter at any site, no matter what type of work they are performing:

  • Falling
  • Environment (weather)
  • Equipment condition
  • Ground obstacles
  • Overhead obstacles
  • Suspension rigging and anchor points
  • Electric supply lines
  • General public.

Performing a site assessment and developing a written work plan to address any hazards is a requirement of OSHA and also known as a Job Hazard Assessment (or JHA for short). The written work plan is a great offense and can help provide a means of site supervision during the busy season when you can’t be at every job, and of course, it’s an obvious example of Prevention through Design which is the new direction safety and health plans are taking.

Coming up with a plan for equipment maintenance, training, and conducting site assessments has a proven track record for the industry. During the last two decades, contractors have performed better and more thorough site assessments and it has made a difference. Fatalities and accidents in the window cleaning industry have been reduces by over 30 percent.

One of the most important safety issues to be addressed during a window cleaning operation is the use of tools and equipment on or around areas where people not involved in the operation may congregate. The safety and well-being of the window cleaner is important and equally so, is the safety and well-being of those who may come near the window cleaning operation. In addition, the use of access equipment must also consider the protection of private and public property.

Current OSHA Regulations now repeats the mandate that a work plan be provided by the window cleaning contractor when windows to be cleaned are located in areas where workers may utilize suspended equipment which may have falling object concerns when the public may be exposed to overhead equipment operations or where workers are exposed to falls and other known hazards. The newly revised OSHA regulations address procedures for “falling object protection” which includes warnings such as barricades and danger signs.


After review and understanding by the employer and their crew, this plan should be provided to the building owner or manager as a reference. It is up to the employer and the crew to see that the work plan is enforced.

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