OSHA Fall Protection Basics for Window Cleaners: Ladders, Roof Edges and Rope Descent

Most window cleaning jobs in South Florida happen on a ladder or with a water-fed pole from the ground. When you have employees on those ladders, federal OSHA rules for general industry set specific duties for you as the employer. Here are the basics, with links to each regulation. They are a starting point, not a full safety program.

Ladders: 29 CFR 1910.23

Portable ladders have their own section (1910.23). Among other things, the employer must make sure that:

• Each ladder is inspected before first use in every shift, and a damaged ladder is tagged “Dangerous: Do Not Use” and taken out of service.
• Ladders stand on stable, level surfaces, or are secured so they cannot slip, and are secured on slippery surfaces.
• A ladder in a doorway, passageway or driveway is secured or guarded with a barricade such as cones or caution tape. That matters at storefronts.
• Nobody moves or extends a ladder while someone is on it, and the top step or cap of a stepladder is not used as a step.
• A ladder used to reach a roof or upper landing extends at least 3 feet above it.
• The load, including the worker’s tools and buckets, stays within the ladder’s rating, and ladders are never set on boxes or barrels for extra height.
• Workers face the ladder and keep at least one hand on it while climbing.

Roofs, ledges and the 4-foot rule: 1910.28

If a worker steps off the ladder onto a roof, balcony or ledge, a different rule applies. On a walking-working surface with an unprotected side or edge 4 feet or more above a lower level, the employer must provide guardrails, a safety net or a personal fall protection system (1910.28(b)(1)). Where workers could be hit by falling tools, the same section requires head protection and measures such as toeboards or barricading the area below.

Rope descent systems: 1910.27

Taller buildings are often cleaned from a rope descent system, the seat-and-rope rig some call a bosun’s chair. That is a different operation, with strict rules (1910.27(b)):

• Before anyone uses it, the building owner must tell the employer in writing that each anchorage has been identified, tested, certified and maintained to hold at least 5,000 pounds per worker, and the employer must keep that information for the job.
• Generally no rope descent above 300 feet, a separate independent fall arrest system for each worker, inspection every shift, a plan for prompt rescue, and no work in storms or gusty wind.

Our window cleaning page is written for ladder and pole work on homes, storefronts and low-rise buildings. If you are thinking about rope work, tell your agent first, because it changes how your business is described.

Training: 1910.30

Before an employee is exposed to a fall hazard, the employer must make sure a qualified person trains them on the hazards, the procedures and the equipment they use, and retrains them when the work or equipment changes (1910.30). Keep a simple record of who was trained, when, and on what.

Where insurance fits

A fall is a workers’ comp question for your employee and often a liability question for the property: a ladder that slides into a storefront sign, a bucket that drops near a customer. See our window cleaning insurance page for the coverage side, and our article on helpers and workers’ comp if you work with extra hands.