Window Cleaning Safety Manual

OSHA and Window Cleaning

Federal OSHA does not maintain a single comprehensive standard covering every aspect of professional window cleaning.

Instead, applicable OSHA requirements depend on the work being performed and the access system being used.

Potentially applicable requirements may address:

• Walking-Working Surfaces.
• Fall Protection.
• Rope Descent Systems.
• Scaffolds.
• Powered Platforms.
• Aerial Lifts.
• Ladders.
• Personal Protective Equipment.
• Electrical Safety.
• Hazard Communication.
• Respiratory Protection.
• Emergency Action Plans.

Employers should evaluate each job and access method to determine the requirements that apply.

What Should a Window Cleaning Safety Manual Include?

Depending on operations, a Window Cleaning Safety Manual may address:

• Window cleaning safety responsibilities.
• Pre-job hazard assessments.
• Job Safety Analysis.
• Ground-level window cleaning.
• Water-fed poles.
• Ladder safety.
• Roof access.
• Fall Protection.
• Rope Descent Systems.
• Anchorages.
• Rigging.
• Personal Fall Arrest Systems.
• Suspended scaffolds.
• Powered platforms.
• Aerial lifts.
• Falling-object protection.
• Tool and equipment securing.
• Electrical hazards.
• Working near power lines.
• Cleaning chemicals.
• Personal Protective Equipment.
• Weather conditions.
• Public protection.
• Rescue planning.
• Emergency procedures.

Programs should be selected according to the company’s actual work and equipment.

Window Cleaning Safety Program

An effective Window Cleaning Safety Program establishes responsibilities and procedures for identifying and controlling hazards before employees begin work.

Management should provide:

• Appropriate equipment.
• Employee training.
• Required PPE.
• Fall-protection systems.
• Safe access equipment.
• Inspection procedures.
• Emergency resources.
• Effective supervision.

Managers and supervisors should:

• Evaluate each worksite.
• Select appropriate access methods.
• Verify equipment condition.
• Confirm required anchorage information.
• Establish fall-protection procedures.
• Evaluate weather conditions.
• Control public access.
• Provide employee training.
• Correct unsafe conditions.
• Investigate incidents.

Employees should follow established procedures, inspect assigned equipment, use required PPE, and immediately report unsafe conditions.

Pre-Job Hazard Assessment

Window-cleaning work should be evaluated before employees begin.

The assessment should consider:

• Building height.
• Window locations.
• Roof access.
• Roof edges.
• Anchorages.
• Access equipment.
• Ground conditions.
• Electrical hazards.
• Weather.
• Pedestrians.
• Vehicle traffic.
• Falling objects.
• Cleaning chemicals.

The safest practical access method should be selected for the conditions.

Job Safety Analysis (JSA/JHA)

A JSA/JHA may be used to plan window-cleaning activities.

Potential JSAs/JHAs may address:

• Ground-level window cleaning.
• Water-fed pole cleaning.
• Extension ladder work.
• Aerial lift window cleaning.
• Roof access.
• Rope descent system use.
• Suspended scaffold operation.
• High-rise window cleaning.

The analysis should identify job steps, hazards, controls, PPE, and emergency procedures.

Worksite Survey

Before work begins, the employer should evaluate the building and surrounding work area.

The survey may include:

• Access points.
• Roof configuration.
• Anchorages.
• Parapets.
• Skylights.
• Roof openings.
• Electrical equipment.
• Overhead power lines.
• Pedestrian routes.
• Traffic.
• Landscaping.
• Ground conditions.

Conditions that could affect safe operations should be addressed before work begins.

Selecting an Access Method

The access method should be appropriate for:

• Building height.
• Window configuration.
• Roof design.
• Available anchorages.
• Ground conditions.
• Equipment limitations.
• Weather.
• Duration of work.

Employees should not use an access method simply because it is faster or more convenient.

Ground-Level Window Cleaning

Ground-level work can involve hazards even when employees are not exposed to significant fall heights.

Potential hazards include:

• Slippery surfaces.
• Hoses.
• Chemicals.
• Pedestrians.
• Traffic.
• Electrical equipment.
• Overhead hazards.

Work areas should be maintained and controlled as necessary.

Storefront Window Cleaning

Storefront work frequently occurs near:

• Sidewalks.
• Parking lots.
• Building entrances.
• Customers.
• Vehicle traffic.

Employees should position equipment so it does not create unnecessary trip or struck-by hazards.

Water-Fed Pole Safety

Water-fed poles allow employees to clean elevated windows while remaining on the ground.

Although they can reduce the need for ladders or elevated access, they introduce their own hazards.

Potential hazards include:

• Overhead electrical lines.
• Pole instability.
• Muscle strain.
• Falling pole sections.
• Pedestrians.
• Wet walking surfaces.
• Hoses.

Employees should receive appropriate training before using water-fed poles.

Water-Fed Pole Inspection

Before use, employees should inspect:

• Pole sections.
• Connections.
• Clamps.
• Hoses.
• Brush assemblies.
• Other components.

Damaged equipment should not be used.

Water-Fed Pole Handling

Employees should maintain control of the pole at all times.

Pole length should be appropriate for:

• Building height.
• Wind.
• Employee capability.
• Surrounding hazards.

Employees should not overextend equipment beyond manufacturer limitations.

Water-Fed Pole Ergonomics

Long poles can create substantial physical demands.

Potential concerns include:

• Shoulder strain.
• Back strain.
• Neck strain.
• Repetitive motion.
• Awkward posture.

Controls may include appropriate pole length, lightweight equipment, work-rest periods, task rotation, and proper positioning.

Water-Fed Poles and Electrical Hazards

Water-fed poles can present serious electrical hazards when used near overhead power lines or energized electrical equipment.

Employees should identify electrical hazards before raising or extending poles.

Required clearances should be maintained.

Hose Management

Water hoses should be positioned to minimize:

• Trip hazards.
• Vehicle damage.
• Pedestrian interference.
• Kinking.
• Unexpected movement.

Where hoses cross public walkways, appropriate controls should be established.

Wet Walking Surfaces

Window cleaning can create wet walking surfaces.

Employees should control water where practical and use appropriate:

• Signs.
• Barricades.
• Work-area controls.
• Footwear.

Public walkways should not be unnecessarily left wet or obstructed.

Ladder Safety

Ladders may be used for lower-level window-cleaning work when appropriate.

Employees should use ladders that are:

• Appropriate for the task.
• Properly rated.
• Inspected.
• Correctly positioned.
• Maintained in good condition.

Damaged ladders should be removed from service.

Ladder Inspection

Before use, employees should inspect ladders for:

• Damaged rails.
• Missing or damaged rungs.
• Defective feet.
• Loose hardware.
• Contamination.
• Other defects.

Unsafe ladders should be tagged or otherwise removed from service.

Ladder Setup

Ladders should be positioned on stable surfaces.

Employees should consider:

• Slope.
• Wet surfaces.
• Doors.
• Pedestrians.
• Traffic.
• Overhead electrical hazards.

Ladders should not be placed where they can be struck or displaced unless the hazard is controlled.

Extension Ladders

Extension ladders should be:

• Properly angled.
• Secured where required.
• Extended only within manufacturer limits.
• Used according to applicable requirements.

Employees should not stand above permitted working levels.

Ladder Climbing

Employees should maintain appropriate control while climbing.

Tools and cleaning equipment should be carried or raised in a manner that does not interfere with safe climbing.

Employees should face the ladder when climbing.

Working from Ladders

Employees should avoid excessive reaching.

The ladder should be repositioned when necessary rather than allowing the employee’s center of balance to move beyond safe limits.

Roof Access

High-rise and commercial window cleaning may require employees to access roofs before beginning work.

Roof access should be evaluated for:

• Ladders.
• Stairs.
• Hatches.
• Roof openings.
• Skylights.
• Roof edges.
• Trip hazards.
• Electrical equipment.

Employees should use designated safe access routes.

Roof Edge Hazards

Employees exposed to unprotected roof edges should use required fall-protection systems.

The applicable protection depends on:

• Distance from the edge.
• Work activity.
• Roof configuration.
• Applicable OSHA requirements.

Employees should not approach unprotected edges without required protection.

Skylights and Roof Openings

Skylights and roof openings can present fall hazards.

Employees should not assume skylights can support their weight.

Required guarding, covers, or personal fall protection should be used.

Fall Protection

Falls are among the most serious hazards in professional window cleaning.

Fall-protection procedures should address the access method and work environment.

Potential systems include:

• Guardrails.
• Travel restraint.
• Personal Fall Arrest Systems.
• Scaffold fall protection.
• Rope Descent System fall protection.

Employees should be trained in the systems they use.

Personal Fall Arrest Systems

Personal Fall Arrest Systems may include:

• Full-body harness.
• Anchorage.
• Connector.
• Lifeline.
• Lanyard.
• Self-retracting lifeline.
• Rope grab.

Components should be compatible and used according to manufacturer requirements.

Fall Protection Equipment Inspection

Fall-protection equipment should be inspected before use as required.

Employees should inspect for:

• Cuts.
• Abrasion.
• Chemical damage.
• Heat damage.
• Broken stitching.
• Deformed hardware.
• Corrosion.
• Other defects.

Defective equipment should be removed from service.

Independent Fall Protection

Where required, the fall-arrest system should be independent of the primary suspension or access system.

The failure of one system should not automatically cause failure of the other.

Rope Descent Systems

Rope Descent Systems are commonly used for exterior building cleaning, including window cleaning.

A Rope Descent System allows an employee to descend in a controlled manner and stop as needed to perform work.

A typical system may include:

• Roof anchorage.
• Support rope.
• Descent device.
• Carabiners or shackles.
• Seatboard or chair.

Rope Descent Systems should be used only by appropriately trained employees.

Rope Descent System Height

A Rope Descent System generally may not be used at heights greater than 300 feet above grade unless the employer demonstrates that another access method is not feasible or would create a greater hazard.

Work planning should therefore consider building height before selecting an RDS.

Rope Descent System Anchorages

Before employees use a Rope Descent System, the employer should obtain the required written information from the building owner concerning the applicable anchorages.

Each RDS anchorage must be capable of supporting at least 5,000 pounds in any direction for each employee attached.

Employees should not use unverified anchorages.

Building Owner Anchorage Information

Building owners have responsibilities concerning Rope Descent System anchorages.

Before RDS work begins, the window-cleaning employer should obtain written confirmation that applicable anchorages have been:

• Identified.
• Inspected.
• Tested or certified as required.
• Maintained.

The employer should retain the required information for the duration of the job.

Anchorage Inspection and Certification

RDS anchorages are subject to required inspection and certification provisions.

Building-owner documentation should be reviewed before employees rely on the anchorage.

Window cleaners should never improvise an anchorage because a certified anchorage is unavailable.

RDS Equipment Inspection

Rope Descent Systems should be inspected at the start of each work shift in which they will be used.

Damaged or defective equipment should be immediately removed from service.

Inspection should include applicable:

• Ropes.
• Descent devices.
• Connectors.
• Seatboards.
• Harnesses.
• Lifelines.
• Rope grabs.
• Rigging components.

RDS Rigging

Rope Descent Systems should be properly rigged.

Rigging should address:

• Anchorages.
• Tiebacks.
• Counterweights.
• Cornice hooks.
• Non-permanent anchorages.
• Rope paths.
• Edge protection.

Employees should not begin descent until rigging has been checked.

Tiebacks

Where required, tiebacks should be properly installed.

Tiebacks should not be attached to:

• Unverified structures.
• Plumbing.
• Vent piping.
• Electrical conduit.
• Other unsuitable building components.

Rigging should be performed according to applicable requirements and manufacturer instructions.

Rope Protection

Ropes should be protected wherever they contact:

• Building edges.
• Parapets.
• Anchorages.
• Abrasive surfaces.
• Obstructions.

Appropriate padding or other protection should prevent ropes from being cut, abraded, or weakened.

Rope Condition

Employees should inspect ropes for:

• Cuts.
• Abrasion.
• Chemical damage.
• Heat damage.
• Contamination.
• Excessive wear.
• Other deterioration.

Damaged ropes should be removed from service.

Separate Personal Fall Arrest System

Each employee using an RDS should use the required separate, independent Personal Fall Arrest System.

The suspension rope should not be treated as the employee’s only fall protection.

RDS Stabilization

When descents exceed applicable heights, stabilization should be provided at the specific work location as required.

For Rope Descent Systems, OSHA requires stabilization when descents exceed 130 feet.

RDS Weather Restrictions

Employees should not use Rope Descent Systems during hazardous weather conditions.

Potential hazards include:

• Storms.
• Gusty winds.
• Excessive winds.
• Lightning.
• Ice.
• Conditions affecting rope or equipment performance.

Employees should have authority to stop work when weather becomes unsafe.

RDS Falling-Object Prevention

Tools, squeegees, buckets, and other equipment used during Rope Descent System work should be secured by:

• Tool lanyards.
• Tethers.
• Other suitable methods.

Employees should not rely solely on maintaining a hand grip on equipment.

Protecting Ropes from Destructive Conditions

RDS ropes should be protected from:

• Open flames.
• Hot Work.
• Corrosive chemicals.
• Sharp edges.
• Other destructive conditions.

Work should stop if the rope system becomes exposed to conditions that could compromise its strength.

RDS Rescue

Employers using Rope Descent Systems should provide for prompt rescue in the event of a fall.

Rescue planning should be completed before employees begin work.

Calling emergency services alone may not adequately address every high-rise rescue situation.

Rescue Planning

Rescue planning should consider:

• Building height.
• Employee location.
• Roof access.
• Suspension trauma.
• Equipment.
• Communication.
• Available rescuers.
• Emergency services.

Employees should understand the rescue procedure applicable to the job.

Self-Rescue — When Applicable

Where the rescue plan relies on employee self-rescue, employees should be trained and equipped for the expected procedure.

Self-rescue should not be assumed possible for every incident.

Suspended Scaffolds — When Applicable

Window cleaners may work from suspended scaffolds.

Suspended scaffold operations should address:

• Suspension systems.
• Anchorages.
• Hoists.
• Platforms.
• Fall protection.
• Rigging.
• Counterweights.
• Tiebacks.
• Inspections.

Only trained and authorized employees should use suspended scaffolds.

Suspended Scaffold Inspection

Scaffold components should be inspected according to applicable requirements.

Employees should not use equipment that is:

• Damaged.
• Improperly rigged.
• Missing required components.
• Otherwise unsafe.

Scaffold Rigging

Suspended scaffold rigging should be performed by employees with appropriate knowledge and training.

Rigging should consider:

• Supporting surfaces.
• Outriggers.
• Counterweights.
• Tiebacks.
• Suspension ropes.
• Building edges.

Counterweights

Counterweights should be:

• Designed for the equipment.
• Properly secured.
• Sufficient for the system.
• Installed according to applicable requirements.

Improvised materials should not be used as counterweights.

Suspended Scaffold Fall Protection

Employees working from suspended scaffolds should use required fall protection.

Fall-arrest systems should be appropriately independent from the scaffold suspension system where required.

Powered Platforms — When Applicable

Some buildings are equipped with permanent powered platforms or building-maintenance systems.

Employees should use these systems only when:

• Authorized.
• Appropriately trained.
• Equipment is suitable for use.
• Required inspections and procedures have been completed.

Building-specific operating requirements should be followed.

Aerial Lifts

Aerial lifts may be used for windows accessible from parking lots, streets, courtyards, or other suitable locations.

Employees should evaluate:

• Ground conditions.
• Overhead hazards.
• Traffic.
• Pedestrians.
• Equipment capacity.
• Building clearances.

Only trained and authorized employees should operate aerial lifts.

Aerial Lift Inspection

Required pre-use inspections should be completed before operation.

Potential inspection items include:

• Controls.
• Tires.
• Hydraulic systems.
• Safety devices.
• Guardrails.
• Emergency controls.

Defective equipment should be removed from service.

Aerial Lift Fall Protection

Employees should use fall protection appropriate to the type of aerial lift and applicable requirements.

Employees should not:

• Climb on guardrails.
• Use ladders inside platforms to gain height.
• Stand on makeshift devices.

Aerial Lift Setup

Aerial lifts should be positioned on surfaces capable of supporting the equipment.

Operators should evaluate:

• Slopes.
• Curbs.
• Holes.
• Underground structures.
• Traffic.
• Overhead utilities.

Working Near Power Lines

Window cleaners may encounter electrical hazards from:

• Overhead power lines.
• Building electrical equipment.
• Signs.
• Lighting.
• Service entrances.

Electrical hazards should be identified during the pre-job assessment.

Required clearances should be maintained.

Conductive Equipment

Metal ladders, water-fed poles, extension poles, and other conductive equipment can increase electrical risk.

Equipment should not be allowed to approach energized conductors closer than permitted.

Employees should never assume a line is de-energized based on appearance.

Electrical Equipment Near Water

Window-cleaning operations can introduce water near electrical equipment.

Employees should avoid directing water toward:

• Electrical panels.
• Receptacles.
• Lighting.
• Damaged electrical equipment.

Unsafe electrical conditions should be reported to the building representative.

Falling-Object Protection

Window-cleaning equipment can become a serious falling-object hazard.

Potential falling objects include:

• Squeegees.
• Scrapers.
• Buckets.
• Tools.
• Pole sections.
• Equipment components.

Work should be planned to protect employees and the public below.

Tool Tethering

Tools used at elevation should be secured where required or appropriate.

Tethers should be compatible with:

• Tool weight.
• Work activity.
• Access system.

Tethers should not create entanglement hazards.

Drop Zones

Controlled areas should be established below elevated window-cleaning operations where falling objects could strike people.

Controls may include:

• Barricades.
• Cones.
• Signs.
• Attendants.
• Alternate pedestrian routes.

The size of the controlled area should reflect the work and potential falling-object hazard.

Working Above Building Entrances

Window cleaning above active entrances requires careful planning.

Potential controls include:

• Temporary entrance closure.
• Alternate entrances.
• Canopies.
• Barricades.
• Scheduling during low-traffic periods.

Employees should not rely on pedestrians to notice overhead work.

Working Around the Public

Commercial window cleaning frequently occurs in occupied areas.

Potentially exposed persons include:

• Customers.
• Hotel guests.
• Office employees.
• Residents.
• Students.
• Patients.
• Pedestrians.

Work areas should be controlled so members of the public are not exposed to avoidable hazards.

Sidewalk Safety

Equipment should be positioned to minimize interference with pedestrian travel.

Potential hazards include:

• Ladders.
• Hoses.
• Buckets.
• Cords.
• Water.
• Barricades.

Pedestrians should be directed around hazardous areas.

Traffic Safety

Window cleaning may occur adjacent to:

• Streets.
• Parking lots.
• Driveways.
• Loading areas.

Employees should remain aware of moving vehicles.

High-visibility apparel, cones, barriers, or other controls may be appropriate.

Parking Lot Work

Aerial lifts, ladders, and water-fed poles may be used in active parking areas.

Work planning should consider:

• Moving vehicles.
• Backing vehicles.
• Delivery trucks.
• Pedestrians.
• Equipment positioning.

Parking spaces may need to be temporarily restricted.

Cleaning Chemicals

Window-cleaning products may include:

• Detergents.
• Glass cleaners.
• Degreasers.
• Spot-removal products.
• Mineral-deposit removers.
• Other chemicals.

Employees should understand the hazards of products they use.

Hazard Communication

Where hazardous chemicals are used, the employer should maintain an appropriate Hazard Communication Program.

The program should address:

• Chemical inventory.
• Labels.
• Safety Data Sheets.
• Employee information.
• Training.

Employees should have access to SDSs during their work shifts.

Chemical Labels

Chemical containers should remain properly labeled.

Employees should not place cleaning chemicals in:

• Beverage containers.
• Food containers.
• Unmarked containers.

Secondary containers should be labeled as required.

Chemical Mixing

Employees should not mix cleaning products unless specifically instructed and trained to do so.

Certain cleaning chemicals can produce hazardous reactions when combined.

Manufacturer instructions and SDS information should be followed.

Chemical Storage

Cleaning chemicals should be stored:

• In appropriate containers.
• Away from incompatible materials.
• Protected from damage.
• According to manufacturer instructions.

Containers should remain closed when not in use.

Personal Protective Equipment

PPE should be selected through an appropriate hazard assessment.

Depending on the task, PPE may include:

• Safety glasses.
• Chemical goggles.
• Gloves.
• Protective footwear.
• High-visibility apparel.
• Head protection.
• Fall-protection equipment.
• Weather-appropriate clothing.

PPE should be appropriate for the hazard and work environment.

Head Protection

Head protection may be required where employees are exposed to falling-object or overhead hazards.

Employees working beneath elevated window-cleaning operations should be appropriately protected.

Foot Protection

Footwear should provide appropriate traction for:

• Wet surfaces.
• Roofs.
• Ladders.
• Outdoor conditions.

Additional protective footwear may be necessary for particular jobs.

Eye Protection

Eye protection may be necessary when employees are exposed to:

• Cleaning chemicals.
• Windblown debris.
• Scraping operations.
• Other eye hazards.

Appropriate protection should be selected for the task.

Hand Protection

Gloves should be selected for hazards involving:

• Chemicals.
• Sharp glass.
• Abrasive surfaces.
• Cold weather.
• Rope handling.

Employees should inspect gloves and replace damaged gloves as appropriate.

Broken Glass

Employees should use caution when cleaning:

• Cracked windows.
• Damaged glazing.
• Broken glass.

Employees should not apply pressure to glass that appears structurally unsafe.

Broken glass should be handled using appropriate tools and PPE.

Scrapers and Blades

Window scrapers and razor-type tools can cause lacerations.

Employees should:

• Cut away from the body.
• Use appropriate handles.
• Store blades safely.
• Dispose of damaged blades appropriately.

Unprotected blades should not be carried in pockets.

Manual Material Handling

Employees may handle:

• Ladders.
• Water-fed poles.
• Hoses.
• Buckets.
• Rope systems.
• Scaffold components.

Team lifting or mechanical assistance should be used where appropriate.

Ladder Handling

Long extension ladders can be difficult to maneuver.

Employees should consider:

• Ladder length.
• Weight.
• Wind.
• Overhead power lines.
• Pedestrians.

Two-person handling may be appropriate for long or heavy ladders.

Ergonomics

Window cleaning can involve repetitive:

• Reaching.
• Scrubbing.
• Squeegee use.
• Pole handling.
• Overhead work.

Work practices should reduce unnecessary strain where practical.

Weather Conditions

Weather should be evaluated before and during exterior window cleaning.

Potential hazardous conditions include:

• High winds.
• Lightning.
• Rain.
• Ice.
• Extreme heat.
• Extreme cold.

Employees should have authority to stop work when conditions become unsafe.

Wind

Wind can affect:

• Rope Descent Systems.
• Suspended scaffolds.
• Aerial lifts.
• Ladders.
• Water-fed poles.

High-rise work should be suspended when wind conditions exceed safe equipment or operating limitations.

Lightning

Exterior elevated work should be suspended when lightning creates a hazard.

Employees should move to an appropriate safe location.

Rain

Rain can increase hazards involving:

• Roofs.
• Ladders.
• Walking surfaces.
• Electrical equipment.

Work should be reassessed when surfaces become slippery.

Ice and Snow

Ice can make:

• Roofs.
• Ladders.
• Platforms.
• Sidewalks.
• Building edges

unsafe for work.

Employees should not proceed when adequate footing or equipment stability cannot be maintained.

Heat Stress

Window cleaners may perform strenuous outdoor work in direct sunlight.

Heat-illness prevention should consider:

• Acclimatization.
• Water.
• Rest.
• Shade.
• Workload.
• Weather conditions.

Employees should understand symptoms of heat illness.

Cold Stress

Employees may work outdoors in cold and windy conditions.

Procedures should address:

• Protective clothing.
• Wet clothing.
• Warming opportunities.
• Wind chill.
• Employee monitoring.

High-Rise Building Conditions

High-rise window-cleaning work requires careful planning before employees access the exterior of a building.

Planning should consider:

• Building-specific access systems.
• Anchorages.
• Roof configuration.
• Rigging.
• Rescue.
• Weather.
• Public areas below.

Employees should not begin descent until required conditions have been verified.

Building Owner Coordination

The window-cleaning employer should coordinate with the building owner or property representative concerning:

• Roof access.
• Anchorage documentation.
• Building-maintenance systems.
• Electrical hazards.
• Restricted areas.
• Public access.
• Emergency procedures.

Required information should be obtained before work begins.

Building Access

Employees should use authorized routes to access:

• Roofs.
• Mechanical areas.
• Anchorages.
• Platforms.

Restricted building areas should not be entered without authorization.

Communication

Employees performing elevated or suspended work should have an effective means of communication.

Communication may be necessary between:

• Workers aloft.
• Ground personnel.
• Supervisors.
• Building representatives.
• Rescue personnel.

Communication methods should remain effective at the work location.

Working Alone

High-risk window-cleaning operations should be evaluated to determine whether employees can safely work alone.

Activities involving:

• Rope Descent Systems.
• Suspended scaffolds.
• Significant fall exposure.
• Rescue-dependent operations

may require additional personnel.

Emergency response should not depend on an injured employee being able to summon assistance.

Rescue and Emergency Response

Emergency procedures should address foreseeable window-cleaning incidents.

Potential emergencies include:

• Falls.
• Suspended employees.
• Equipment failure.
• Rope damage.
• Scaffold malfunction.
• Aerial lift failure.
• Electrical contact.
• Severe weather.
• Medical emergencies.

Employees should understand their responsibilities before work begins.

Suspension Trauma

An employee suspended in a fall-arrest harness may require prompt rescue.

Rescue planning should minimize the amount of time an employee remains suspended after a fall.

Employees should understand emergency communication and rescue procedures.

First Aid

First-aid resources should reflect worksite conditions and emergency-response availability.

Potential injuries include:

• Falls.
• Cuts.
• Chemical exposure.
• Heat illness.
• Electrical injury.
• Musculoskeletal injuries.

Employees should know how to summon emergency medical assistance.

Equipment Inspection

Window-cleaning equipment should be inspected according to applicable requirements and manufacturer instructions.

Equipment may include:

• Ropes.
• Harnesses.
• Lifelines.
• Descenders.
• Carabiners.
• Seatboards.
• Ladders.
• Water-fed poles.
• Suspended scaffold components.
• Aerial lifts.

Damaged equipment should be removed from service.

Equipment Storage

Equipment should be stored to protect it from:

• Chemicals.
• Sunlight.
• Heat.
• Moisture.
• Sharp objects.
• Vehicle damage.

Fall-protection and rope equipment should be stored according to manufacturer recommendations.

Rope Storage

Ropes should be kept away from:

• Chemicals.
• Oils.
• Sharp objects.
• Excessive heat.
• Contamination.

Wet ropes should be handled and dried according to manufacturer instructions.

Equipment Maintenance

Repairs should be performed only by appropriately qualified or authorized persons.

Employees should not make unauthorized modifications to:

• Fall-protection equipment.
• Rope systems.
• Ladders.
• Scaffolds.
• Aerial lifts.

Vehicle Safety

Window-cleaning contractors may transport employees and equipment between multiple jobs each day.

Vehicle procedures should address:

• Driver authorization.
• Vehicle inspections.
• Load securement.
• Ladder racks.
• Equipment storage.
• Distracted driving.

Ladder Racks

Ladders transported on vehicles should be properly secured.

Employees should inspect racks and tie-down systems before travel.

Loose ladders can create serious roadway hazards.

Equipment Securement

Buckets, poles, tools, chemicals, ropes, and other equipment should be secured during transportation.

Chemical containers should remain upright and protected from damage.

Housekeeping

Work areas should remain orderly.

Employees should control:

• Hoses.
• Buckets.
• Ropes.
• Tools.
• Chemicals.
• Packaging.

Access routes and emergency exits should not be obstructed.

Contractor and Property Coordination

Window-cleaning companies frequently work at customer-controlled properties.

Before work begins, relevant hazards should be coordinated with the property owner, manager, or controlling employer.

Potential issues include:

• Roof access.
• Anchorages.
• Electrical hazards.
• Pedestrian traffic.
• Building operations.
• Other contractors.

Incident Reporting

Employees should promptly report:

• Injuries.
• Falls.
• Near misses.
• Equipment damage.
• Rope damage.
• Anchorage concerns.
• Electrical incidents.
• Unsafe conditions.

Potentially serious fall-protection equipment should be removed from service after an incident as required.

Incident Investigation

Significant incidents should be investigated to identify:

• Immediate causes.
• Contributing factors.
• Root causes.
• Corrective actions.

Investigations may consider:

• Access-method selection.
• Rigging.
• Anchorages.
• Equipment.
• Weather.
• Training.
• Work planning.
• Public protection.
• Supervision.

Root Cause Analysis

Root Cause Analysis may identify underlying issues involving:

• Pre-job planning.
• Equipment selection.
• Training.
• Inspection.
• Building coordination.
• Anchorage verification.
• Procedures.
• Supervision.
• Corrective-action systems.

Corrective actions should address identified causes rather than simply assigning blame.

Window Cleaning Safety Inspections

Periodic safety inspections should evaluate applicable:

• Fall-protection equipment.
• Ropes.
• Rigging equipment.
• Ladders.
• Water-fed poles.
• Aerial lifts.
• Suspended equipment.
• PPE.
• Chemicals.
• Vehicles.

Unsafe equipment should be removed from service.

Window Cleaning Safety Training

Employee training should reflect assigned duties and access methods.

Depending on responsibilities, training may address:

• Fall hazards.
• Rope Descent Systems.
• Fall Protection.
• Rigging.
• Suspended scaffolds.
• Aerial lifts.
• Ladders.
• Water-fed poles.
• Electrical hazards.
• Falling-object prevention.
• Rescue.

Employees should not independently perform specialized elevated work until appropriately trained.

Rope Descent System Training

Employees using Rope Descent Systems should receive training appropriate to applicable OSHA requirements and their assigned work.

Training should address:

• Equipment.
• Inspection.
• Rigging.
• Anchorages.
• Fall protection.
• Rope protection.
• Weather.
• Falling objects.
• Rescue.

Fall Protection Training

Employees exposed to fall hazards should understand:

• Fall hazards.
• Required protection.
• Equipment use.
• Inspection.
• Limitations.
• Anchorage requirements.
• Emergency procedures.

Retraining should be provided when necessary.

Ladder Training

Employees using ladders should understand:

• Inspection.
• Setup.
• Climbing.
• Electrical hazards.
• Prohibited practices.
• Equipment limitations.

Aerial Lift Training

Only appropriately trained and authorized employees should operate aerial lifts.

Training should reflect the equipment used and applicable requirements.

Water-Fed Pole Training

Employees should receive instruction in safe water-fed pole use.

Training should address:

• Equipment inspection.
• Electrical hazards.
• Pole control.
• Ergonomics.
• Pedestrians.
• Hoses.
• Weather.

New Employee Orientation

New window-cleaning employees should receive safety orientation before independently performing assigned work.

Orientation may address:

• Fall hazards.
• Equipment.
• PPE.
• Electrical hazards.
• Public protection.
• Emergency procedures.
• Stop-work authority.

Refresher Training

Additional training may be appropriate following:

• Unsafe equipment use.
• Falls or near misses.
• New equipment.
• New access methods.
• Procedure changes.
• Identified knowledge gaps.

Safety Meetings

Periodic safety meetings may reinforce topics such as:

• Fall Protection.
• Rope inspection.
• Rigging.
• Ladder safety.
• Water-fed pole safety.
• Weather.
• Electrical hazards.
• Recent incidents.

Recordkeeping

Window-cleaning employers should maintain applicable safety and health records.

Records may include:

• Employee training.
• Equipment inspections.
• Anchorage documentation.
• Aerial lift inspections.
• Incident investigations.
• Corrective actions.
• Injury and illness records.

Records should be retained according to applicable requirements.

Additional Safety Programs

Depending on company operations and employee exposures, additional programs may be necessary for:

• Window Cleaning Safety.
• High-Rise Window Cleaning Safety.
• Fall Protection.
• Rope Descent Systems.
• Anchorage Safety.
• Rigging.
• Personal Fall Arrest Systems.
• Suspended Scaffold Safety.
• Powered Platforms.
• Aerial Lifts.
• Ladder Safety.
• Roof Safety.
• Water-Fed Pole Safety.
• Falling-Object Prevention.
• Dropped-Object Prevention.
• Rescue Planning.
• Electrical Safety.
• Working Near Power Lines.
• Hazard Communication.
• Personal Protective Equipment.
• Walking-Working Surfaces.
• Slips, Trips & Falls.
• Heat Stress Prevention.
• Cold Stress.
• Severe Weather.
• Manual Material Handling.
• Ergonomics.
• Working Around the Public.
• Barriers & Signage.
• Traffic Control.
• Vehicle Safety.
• First Aid.
• Emergency Action Plan.
• Contractor Safety.
• Incident Reporting & Investigation.
• Root Cause Analysis.

Programs should be included when the company’s work and employee exposures make them applicable.

Building a Window Cleaning Safety Manual

A useful Window Cleaning Safety Manual should reflect the company’s actual work methods rather than assuming all window cleaners perform the same work.

A storefront window-cleaning company may primarily require procedures for ladders, water-fed poles, slippery surfaces, chemicals, pedestrians, traffic, ergonomics, and electrical hazards.

A commercial low- and mid-rise window-cleaning contractor may also require procedures for aerial lifts, roof access, Fall Protection, drop zones, public protection, and building-owner coordination.

A high-rise window-cleaning company using Rope Descent Systems requires substantially more extensive procedures for anchorages, rigging, independent Personal Fall Arrest Systems, rope inspection and protection, stabilization, falling-object prevention, rescue, weather, and building-owner documentation.

A contractor using suspended scaffolds or powered building-maintenance platforms requires equipment-specific procedures for those systems in addition to the company’s general Fall Protection Program.

A company using several access methods should include each applicable program in its master safety manual and select the procedures appropriate to each job during pre-job planning.

The safety manual should therefore be based on the access methods, buildings, equipment, and work actually performed.

Customized Window Cleaning Safety Manuals

A Window Cleaning Safety Manual can be developed around the company’s storefront, commercial, high-rise, interior, and exterior window-cleaning operations and the access systems its employees actually use.

The finished manual may incorporate applicable programs for Fall Protection, Rope Descent Systems, Anchorages, Rigging, Personal Fall Arrest Systems, Suspended Scaffolds, Aerial Lifts, Ladders, Water-Fed Poles, Electrical Safety, Dropped-Object Prevention, Public Protection, Weather, Rescue Planning, Emergency Response, Incident Investigation, and other hazards associated with professional window cleaning.

This provides storefront window cleaners, commercial window-cleaning contractors, high-rise window cleaners, building-service contractors, and other professional window-washing companies with a practical safety manual organized around the work their employees actually perform.