As mandated by the California GISO Title 8, Para 3282, many building are required to have an Operating Procedures Outline Sheet (OPOS) for exterior window cleaning operations. Owners often have many questions about the OPOS requirement and how it may affect their properties, so we have included a brief FAQ below:
What is an OPOS and what does it include?
An OPOS is an official document which instructs workers performing window cleaning and other EBM work in a number of ways; specifies allowable procedures, equipment limitations, safety protocols, working hazards, emergency procedures, etc. GISO Article 5, Appendix A specifies what items are to be included in the OPOS document. The document includes user qualifications and is often used as a training guide for window cleaning contractors. HighLine provides vendor orientation upon delivery of the OPOS.
Does my building require an OPOS?
Although all buildings which perform window cleaning will greatly benefit from having an OPOS (see below), the GISO dictates specific triggers which require building owners to provide this document. An OPOS is required when one or more of the following conditions exist:
- A building does not have an established window cleaning system or procedure meeting the requirements specified in Articles 5 & 6 [3282(p)(1)(C) 1A].
- A building’s original window cleaning procedures prepared in accordance with the requirements in Articles 5 & 6 have been changed because of building modifications [3282(p)(1)(C) 1 B].
- A building has extreme architectural features, which require the use of complex rigging/equipment or a building uses rigging, or equipment not covered by the Title 8 safety orders [3282(p)(1)(C) 1C].
- When a boatswain’s chair or controlled descent apparatus is permitted for window cleaning in accordance with Sections 3286(a)(1).
- When the use of counterweighted outrigger beams is permitted for window cleaning in accordance with Section 3291 (d)(2).
- When the necessary information, such as an operating manual, required to properly train personnel in the safe use of the equipment is not available at the jobsite, it may be necessary to develop an OPOS [3298(a) 3&4].
Even when the building does not meet the above conditions, Federal OSHA Part 1910.66 and ANSI/IWCA I-14.1 require that all buildings provide a Plan of Service which is to include emergency procedures, drop zones, hazard areas, etc. Development of the Plan of Service must be done by a qualified person, but is not limited to SIT companies only.
Does the requirement apply to buildings constructed prior to the adoption of the regulations?
Yes. Although the requirement was adopted August 22, 1998 the requirement applies to all buildings which meet the conditions above.
Who can develop an OPOS?
The GISO dictates that an OPOS shall be developed by a firm with knowledge in the design, installation and use of building maintenance equipment, possessing a current Scaffold Inspection Testing (SIT) certification. This differs from states outside of California where window cleaning contractors are allowed to provide a Plan of Service document. Development of the OPOS by a licensed SIT firm which is independent from any equipment manufacturer will assure that the building owner receives an unbiased document to last for the life of the system.
What are the benefits of providing an OPOS?
The benefits of providing an OPOS are many, but the primary goal is to improve workplace safety thereby reducing liability to the building owner. Relying on the window cleaning contractor to provide and maintain its own safety protocols may not provide the protection that building owners desire. In that vein, window cleaners that may improvise their own procedures “on the fly” expose owners to considerable risk. In California, the building owner (not the window cleaning contractor) is legally responsible for providing a “safe-workplace” for outside contractors with respect to window cleaning or “scheduled maintenance” operations. Also, the reality of enforcement along with heavy fines levied on building owners as well as maintenance contractors for safety infractions is becoming more and more prevalent.
The OPOS not only provides safe procedures for the workers to follow; it also benefits the property by “leveling the playing field” for any competitive bids involving the use of these systems. Utilizing the OPOS, all potential bidders for any exterior building maintenance will propose work with methods prescribed by the OPOS and therefore eliminate any confusion between prices. These procedures can further benefit the building owner when attached by contract to any work involving these systems; and this practice may effectively reduce accident liability exposure.
Does the OPOS document expire? When does it require revision?
A properly developed OPOS will last for the life of the building unless one or more of the following occur:
- The building is modified causing changes to the methods and procedures outlined in the OPOS document.
- The EBM equipment is modified or replaced for any reason.
- Inspection and Testing requirements in accordance with the appropriate regulations are not adhered to.
- A citation or stop work order is issued by DOSH.
- A change in the regulatory requirements of the OPOS document.
Can an OPOS be issued to a building which has been “red-tagged” or is in the process of replacing or overhauling its existing equipment?
The short answer to this question is No. Buildings which are deemed deficient to the point where a certificate of safe use cannot be issued cannot be provided an OPOS. In some cases an interim deviation plan can be developed to clean the windows on a “one-time” basis using temporary equipment and procedures, while the permanent equipment is replaced or overhauled.
Please contact us for further information about our OPOS documents and interim deviation plans.