OPOS Requirement

As mentioned above, an OPOS (or Operating Procedure Outline Sheet) is required for certain buildings in California. This requirement is somewhat confusing, and the following clarifications are offered.

Following is an excerpt from a letter from the Division of Occupational Safety and Health (DOSH, formerly Cal/OSHA), which clarifies the OPOS requirements. For convenience, endnotes have been added that cite the applicable codes.

Effective August 22, 1998, the safety orders were modified to require the development of an Operating Procedure Outline Sheet (OPOS) (see Article 5, Appendix A, Title 8, California Code of Regulations [i]) when one or more of the following conditions exist:

1. 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][ii].

2. 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].

3. 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].

4. When a boatswain's chair or controlled descent apparatus is permitted for window cleaning in accordance with Sections 3286(a)(1)[iii].

5. When the use of counterweighted outrigger beams is permitted for window cleaning in accordance with Section 3291 (d)(2)[iv].

6. 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][v].

The OPOS may only be developed by one of the following; the manufacturer of the equipment or a company possessing a current S.I.T. license issued by the Division.

TOWER offers OPOS development services, that far exceed requirements for such documents. Our color illustrated and "easy to use" documents help to inform workers and protect building owners.

[i] Subchapter 7. General Industry Safety Orders
Group 1. General Physical Conditions and Structures Orders
Article 5. Window Cleaning; Appendix A. Operating Procedures Outline Sheet (OPOS).

An OPOS establishes safe window cleaning and exterior maintenance procedures for buildings and structures. An OPOS shall include all of the necessary elements in pictorial and written form, to instruct employees in the safe use of roof supported building maintenance equipment or window cleaning procedures not covered by these Orders. An OPOS shall contain at least the following elements:

1. Isometric or plan view drawing (pictorial drawing) of the building's roof, including the building's name, address, and the date the OPOS was prepared; and

a. The drawing shall be legible and kept with the building's written assurance; and

2. Identification of drop zones, recommended drop sequences, scaffold configurations, and specific building maintenance procedures including the equipment to be used, e.g. permanent roof rigging platform, ground rigged scaffolding, davits, outrigger beams, boatswain's chair or seat board, etc.; and

3. Identification of all anchorage points for personal fall arrest systems and building maintenance equipment; and

4. Identification of personal fall protection requirements and, if applicable, procedures for securing equipment; and

5. If applicable, identification of all dangerous areas on the roof by highlighting all of the "Danger Zone(s)" on the pictorial drawing(s); and

6. If applicable, description of the means and methods to be used to transfer equipment from drop location to drop location or between building levels; and

7. Identification of equipment limitations, load ratings, and special use conditions; and

8. Provisions for pre-operational, operation and maintenance inspections; and

9. Identification of the access and egress to the work locations and the storage area(s) for the permanent or transportable building maintenance equipment; and

10. If applicable, indication of the location and method of stabilization provided for the suspended equipment; and

11. Emergency and rescue procedures, and means of communications to be used during such procedures; and

12. Method(s) to be used to control employee exposure to falls while they are in the "Danger Zone."

NOTE: Authority cited: Section 142.3, Labor Code. Reference: Section 142.3, Labor Code.

HISTORY

1. Addition of Appendix A of Article 5 filed 7-23-98; effective 8-22-98 (Register 98, No. 9-Z).

[ii] Subchapter 7. General Industry Safety Orders
Group 1. General Physical Conditions and Structures Orders
Article 5. Window Cleaning

§3282. General Requirements for All Window Cleaning Operations

(p)(1)(A) Building owners shall provide the employer written assurance, before use, that all their building's safety devices and equipment meet the provisions of these orders. The written assurance shall consider, but not be limited to: window anchors and fittings; load sustaining capabilities of platforms, building components, hoisting and supporting equipment; stability factors for carriages, platforms and supporting equipment; maximum horizontal force for movement of carriages and davits; design of carriages, hoisting machines, wire rope and stabilization systems; and design criteria for electrical wiring and equipment.

(B) All safety devices and equipment considered in the written assurance shall be inspected at least every 12 months. All safety devices and parts of such equipment, including related building support structures, shall be inspected and where necessary, tested to determine if they are safe to use or operate. All such tests shall be conducted as required in Section 3296(b).

(C) 1. Owners of buildings 36 feet or more in height shall have an Operating Procedures Outline Sheet (OPOS) where one or more of the following conditions apply to such buildings:

A. A building does not have established window cleaning system or procedures meeting the requirements specified in Articles 5 and 6, or

B. A building's original window cleaning procedures prepared in accordance with the requirements in Articles 5 and 6 have been changed because of building modifications, or

C. A building has extreme architectural features, which require the use of complex rigging or equipment, or a building that uses rigging or equipment not covered by these Orders.

2. An OPOS shall be developed by a person(s) with knowledge in the design, installation and use of building maintenance equipment (i.e. possessing Scaffold Inspection Testing certification as specified in Section 3296). The OPOS shall be written in manner that can be readily understood by employers. An OPOS that requires structural modifications to the building or existing building maintenance equipment shall have such modifications designed by a mechanical, structural or civil engineer currently registered in the State of California with experience in the design and installation of such equipment.

3. An OPOS shall be developed which at a minimum shall contain the elements of Appendix A of this Article.

[iii] Subchapter 7. General Industry Safety Orders
Group 1. General Physical Conditions and Structures Orders
Article 5. Window Cleaning

§3286. Manual Boatswain's Chairs and Controlled Descent Apparatus (CDA).

(a) Use and Application.

(1)(A) Boatswain's chairs and CDAs shall be used for window cleaning operations only where the windows cannot be cleaned safely and practicably by other means.

[iv] Subchapter 7. General Industry Safety Orders
Group 1. General Physical Conditions and Structures Orders
Article 5. Window Cleaning

§3291. Special Design Considerations--Permanent Roof Top Installations.

(d) Outrigger Beams.

(1) Outrigger beams shall not be employed on buildings exceeding 130 feet in height unless acceptable to the Division. All outrigger beams shall be designed to support the rated load imparted by the suspended scaffold or boatswain's chair with a safety factor of at least 4. Outrigger beams shall not extend more than 6 feet beyond the face of the building. Only steel or high strength alloy beams shall be used. The inboard end of outrigger beams, measured from the fulcrum point to the anchorage point, shall be not less than 1 1/2 times the outboard end in length. The fulcrum point of the beam shall rest on leg(s) or equivalent supports securely attached to the beam and so arranged as to prevent lateral overturning of the beam. Bearing pads shall be securely affixed to each support and shall be of sufficient area to safely distribute imposed loads to the roof structure. The inboard ends of outrigger beams shall be securely anchored by means of tension members (tie-down) affixed to the structural frame of the roof in such a manner that applied forces are resisted within allowable limits affording a safety factor of at least 4. All tie-down fittings at the inboard end of the beam shall be of a type that vibration effects shall not produce accidental disengagement. Safety hooks for beam tie-down purposes shall not be used. The use of counterweights at the inboard end of mobile and fixed outrigger beams are prohibited.

(2) The use of counterweights on the inboard end of portable or transportable outrigger beams shall be permitted only when the following conditions have been met:

(A) The building on which the counterweight beam is to be used, was constructed prior to July 23, 1990.

(B) The building was not designed for other suspension systems.

[v] Subchapter 7. General Industry Safety Orders
Group 1. General Physical Conditions and Structures Orders
Article 6. Powered Platforms and Equipment for Building Maintenance

§3298. Operations.

(a) Training

(1) Working platforms shall be operated only by qualified persons who are proficient in the operation, safe use and inspection of the particular working platform to be operated.

(2) All employees who operate working platforms shall be trained in the following:

(A) Recognition of, and preventive measures for, the safety hazards associated with their individual work tasks.

(B) General recognition and prevention of safety hazards associated with the use of working platforms, including the provisions in the article relating to the particular working platform to be operated.

(D) Work procedures required in subsection (a)(4) of this section.

(E) Personal fall arrest system inspection care, use and system performance.

(3) Training of employees in the operation and inspection of working platforms shall be done by a qualified person.

(4) Written work procedures for the operation, safe use and inspection of working platforms shall be provided for employee training. Pictorial methods of instruction may be used, in lieu of written work procedures, if employee communication is improved using this method. The operating manuals supplied by manufacturers for platform system components can serve as the basis for these procedures.