The Meaning of Safety as it Pertains to Building Maintenance

If one reads all the OSHA regulations regarding the location of tiebacks (safety anchors), the strength or holding power, setbacks and spacing rules, it becomes clear that if you are in "construction" vs. "shipyards" vs. "general industry" different interpretations are possible. We like to think of safety as a concept and that it extends to all facets of a building, operations, training, equipment, people, awareness, education, and
the use of known good or "best" practices.

In 2001 an amazing thing happened. The American National Standards Institute (ANSI) adopted another "standard". Sidebar: standards are norms, they are what collections of reasonably knowing individuals agree to be the 'best practice' or the proper distance or the correct manufacturing process or the ideal methodology, etc. etc. etc..

This new standard is the International Window Cleaning Association (IWCA) I-14.1-2001. Even the International Building Owners and Managers Association (BOMA) adopted this standard. It is a collection of guidelines targetted at the window cleaning industry to help save lives. Period.

This set of guidelines is actually a culmination of existing OSHA regulations combined with that set of newer thoughts toward helping mitigate risks associated with working at heights, on roofs, near skylights, unprotected roof edges, descending off roofs using a myriad of types of equipment.

Historically, the window cleaning industry was very unregulated, and it suffered from a very high fatality and high serious injury rate.

The I-14.1 is not to be confused with the American Society of Mechanical Engineers (ASME) A120 standard which is also endorsed by ANSI and in this case "incorporated by reference" into OSHA regulations. The A120 is a set of guidelines specifically targetted at powered platforms. The I-14.1-2001 encompasses that, or defers to it, and it covers other equipment used for window cleaning, as well as what equipment should be installed on buildings to accomodate safe working conditions.

Note that much more is done in building facade maintenance. Window caulking, sealing, painting, pressure washing, repairs, security cameras, practically any kind of maintenance and repair work on a building being performed when suspended from the roof could qualify under this standard.

Some people are confused as to whether the standard applies to them, if they are not under "general industry". Our thinking is that since the laws of physics don't change regardless of your industry, then if the practices and methods are proven, known to reduce fatalities or the risks of death and serious injury, and reduce damage to property, then why not use common sense and go with the flow?

In October of 2006, the I-14.1 became what's known as a "national concensus standard" and is referenced by OSHA. This doesn't mean it is law or a new set of regulations. It does mean that OSHA might refer to it if there is an accident when it does it's investigation and makes suggestions as to how to avoid similar accidents again. There are countless cases of falls from heights found on the OSHA web site.

While you can't necessarily be cited by OSHA for not following the I-14.1 a wise man might assume that in the event of serious injury or death, any aggressive law firm would pursue the issue ... under the general duty clause ... that says basically, "do no harm". Escaping liability or fidiciary responsibility will come at a price no matter what.

We are not legal experts, but the idea that being negligent may relate to not doing the right thing when the right or better thing is available. It's that simple.

We are about safety - and doing the right thing means that providing the best working conditions, particularly when someone's life is literally hanging in the balance, is the way to go.