December 2, 2017
Dear IWCA Members:
As you may recall, on November 17th, we informed you that IWCA sent a letter to OSHA regarding your challenges with the time constraints contractors and building owners were confronted with in the new regulations for roof anchor inspection, testing and certification. We know the IWCA was not the only group who had expressed these concerns and the purpose of contacting you now is to inform you that OSHA has replied to our voice. This letter of clarification is a great example of the public and private sector working collaboratively toward our common goal of creating a safe work environment.
OSHA understood the concerns and has issued a memorandum to all Regional Administrators with Enforcement Guidance for the Anchorage Requirements in OSHA CFR 1910.27 (b) (1).
The Memo acknowledges that due to a limited availability of qualified persons to inspect, test and certify anchorages for RDS use, OSHA is providing employers (you) and building owners additional time to comply with 1910.27 (b) (1)…PROVIDED that employers and building owners can demonstrate and document they are exercising due diligence to come into compliance with the requirements of the standard.
Simply put, OSHA will evaluate on a case by case basis, the progress towards compliance with the regulation by examining the documentation and timelines on the inspection, testing and certification of roof anchor systems.
Additionally, employers performing work on buildings may be impacted where building owners experience difficulties with compliance in a timely manner. OSHA will evaluate the extent of a contractors efforts to comply, which includes the use of other measures or to not perform work during the delay in compliance.
A copy of the letter can be found here: OSHA Memo on RDS 11-2017.
Yours truly,
Jason York
President
International Window Cleaning Association
