By: Alfredo E. Bustamante, PE, CDT and Gary R. Searer, PE, SE with Wiss, Janney, Elstner Associates, Inc.
Building owners often need to access the exterior facade of their buildings, whether for maintenance, window washing, repairs, or construction. The most common means of accessing the facade of tall buildings is the use of powered platforms or scaffolds, which can be either building- or contractor-supplied. The purpose of this article is to present a general overview of inspection and testing requirements to provide certification of building-supplied components and to discuss building owner responsibilities.
Permanent supports for building access typically consist of anchorages and davits. Anchorages are points of attachment that are used to anchor lifelines or tie-backs (pictured left) for certain types of facade access equipment. Davits (pictured right) are devices, typically used singly or in pairs, for suspending powered platforms on a building for the purposes of performing exterior maintenance or construction activities.
The only universally applicable standards for testing and inspection of facade access support systems are provided by OSHA; however, OSHA requirements are often unclear and sometimes conflict with one another. To make matters more complicated, OSHA standards vary depending on the type of work being performed. For example, scaffolds used for building maintenance have different requirements than scaffolds used for construction.
For building maintenance activities, such as window cleaning, re-glazing, and caulking, OSHA 29 CFR 1910.66 and 1910.28 apply. For construction activities the requirements of OSHA 1926 Subpart ‘L’ apply. The meaning of “construction” is not well-defined in the OSHA standards, but the general industry consensus is that anything beyond normal window cleaning, glazing, and caulking would qualify and trigger OSHA 1926 Subpart ‘L’, including painting, installing a sign or stringing holiday lights. Since facade access is achieved by either building-supplied or contractor-supplied equipment, different requirements can apply to the contractor and the owner.
In this context, applicable structural requirements include the provision that davits, davit bases and equipment tie-back anchors be able to support four times the rated load of the attached motor or hoist for maintenance activities and four and one-half times the rated hoist load for construction activities. Regardless of the type of work being performed, fall arrest anchorages must be able to sustain a 5,000 pound static load for each attached lifeline.
Summary of Testing and Inspection Requirements
OSHA requires that facade access installations be both tested and inspected, as summarized below.
Testing requirements for new installations are provided in OSHA 1910.66(g)(1):
Installations and alterations. All completed building maintenance equipment installations shall be inspected and tested in the field before being placed in initial service to determine that all parts of the installation conform to applicable requirements of this standard, and that all safety and operating equipment is functioning as required. A similar inspection and test shall be made following any major alteration to an existing installation.
Nominally, proof load testing to verify that an installation meets the capacity requirements of OSHA is only required for initial certification of the installation or after any major alteration. For new installations, the proof load testing must be performed prior to putting the installation into service. For installations that are not new but that have never been adequately tested, proof load testing is usually the best method of ensuring that the installation meets the minimum capacity requirements.
Once the capacity of the installation has been confirmed, certification can be provided to the building owner. After that, the system is only required to be visually inspected once a year to verify that elements have not been damaged and are being adequately maintained. However, if damage and/or deterioration are suspected (e.g., due to years of exposure and use or due to outward signs of degradation), or if the owner of a building lacks documentation that the building’s equipment has the required capacity (e.g., a building without proper documentation is purchased), load testing is a valuable tool that can be used to verify that the equipment has the minimum capacity required by OSHA.
Annual Inspection: OSHA 1910.66(g)(2)(i) and (ii) require that building supporting structures and all parts of the equipment be inspected by a competent person at intervals not exceeding 12 months.
Maintenance Inspection:OSHA 1910.66(g)(3)(i) requires that maintenance inspections be performed every 30 days or prior to each work cycle if the work cycle is less than 30 days.
Testing is usually the best method of verifying the capacity of an existing installation that is at least partially obscured by roofing such as most davit bases and anchorages. Although the capacities of exposed elements, like davits and attachment devices, often can be determined through analytical methods, even in such instances, verification via load testing is often the best approach. This is especially true for installations with materials whose properties are not documented.
To satisfy the testing requirements of OSHA and verify the actual capacity of facade access support elements, the test load must equal or exceed the minimum capacity required by OSHA. Testing to a lesser load will only verify the ability to carry that lesser load. The proof test load applied to a platform support element (e.g., davit or davit base) should be equivalent to the rated load of the supported hoist multiplied by the appropriate load factor. The proof test load for anchorages should be 5,000 lbs times the number of lines that are allowed to be attached (usually one). Anchorage testing should verify adequate strength in all directions for which use is anticipated.
To the extent possible, we recommend that every permanent component of a building’s facade access support system be proof load tested before providing a written certification to the building owner. If access or other constraints prevent testing of certain elements, we recommend exposing the attachment of those installations to the building and verifying the capacity analytically.
There appears to be some confusion in the industry regarding the appropriate level of testing. Testing of facade access support system components to a maximum of one-half the OSHA required capacity is recommended by California OSHA and the International Window Cleaning Association (IWCA). Unfortunately, such testing does not verify compliance with minimum OSHA standards. Since OSHA (including California OSHA) requires building owners to assure users of their equipment that it meets minimum OSHA safety requirements, half load testing does not give owners the information they need. Testing an installation to half of the required strength only proves that the installation is at least half as it needs to be.
On occasion, we have found that older proprietary roof anchor elements are not designed to remain elastic when subjected to the loads required by OSHA. These elements are problematic because proper in-field load testing would likely cause damage. Since load testing cannot be used to certify such elements, more costly methods such as exposure and analysis must be used to determine capacity.
Building Owner Responsibilities
OSHA 1910.66(c)(3) requires that building owners of all installations, both new and existing, inform the user of the facade access support system in writing that the installation has been inspected, tested, and maintained in compliance with OSHA’s testing, inspection, and maintenance requirements. If a system was installed or was modified since July 23, 1990, OSHA 1910.66(c)(1 and 2) require the owner to inform the user that the system meets all of OSHA’s requirements relating to minimum strength as well as the load test requirements, including verification that the installation has the minimum required capacity by a professional engineer.
Inspection requirements germane to the building owner mandate that the davits, davit bases, fall protection anchorages and related building elements be inspected by a competent person every 12 months.
OSHA requires daily and start-up inspections (maintenance inspections) of the equipment and record results of these inspections in the daily log book. Building owners are required to maintain documentation of the maintenance inspections, as indicated by OSHA 1910.66
The building owner shall keep a certification record of each inspection and test performed under paragraph (g)(3)(i) of this section. The certification record shall include the date of the inspection and test, the signature of the person who performed the inspection and/or test, and an identifier for the platform installation which was inspected. The certification record shall be kept readily available for review by the Assistant Secretary of Labor or the Assistant Secretary's representative and by the employer.
Maintenance inspections performed by a competent person are required at monthly intervals, but OSHA has previously indicated that monthly inspection can be reduced to coincide with the start of each work cycle when the cycle is longer than 30 days. OSHA defines a competent person as a person who, because of training and experience, is capable of identifying hazardous or dangerous conditions in powered platform installations and of training employees to identify such conditions. The competent person can either be a building owner employee, the contractor, or an outside firm. The building owner is obligated to keep a record of such inspections.
OSHA requirements are often unclear; nevertheless, owners are required to comply with the requirements or risk fines and penalties. The authors hope that the brief overview presented above helps explain some of the pertinent requirements with which building owners must comply.
Alfredo E. Bustamante, PE, CDT is a Senior Associate with the Houston office of Wiss, Janney, Elstner Associates, Inc. He has been involved with the evaluation and testing of facade access support systems, non-destructive testing of concrete structures, steel/masonry computer modeling and analysis, exterior wall cladding repair, and investigation of parking structures. Bustamante is a member of the American Institute of Steel Construction (AISC). He can be contacted via e-mail at email@example.com.
Gary R. Searer, PE, SE, is an Associate Principal and Unit Manager of the Los Angeles unit of Wiss, Janney, Elstner Associates, Inc. He has been involved with the assessment, repair, and maintenance of parking structures, civil structures, and office buildings, as well as facade access systems for the past 17 years. Mr. Searer can be contacted via email at firstname.lastname@example.org.