August 2015 — Property Management Quarterly —
Page 5
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all protection and façade access
regulations governing safety
for maintenance activities such
as window washing or rooftop
access are becoming more
stringent and are changing every year.
Many buildings – particularly low- and
midrise structures – are not in compli-
ance with current standards. Some
owners might not even be aware of
FPFA regulations. Below I answer the
following questions: What is FPFA?
When/why do I need it? Is it worth it?
What are the costs today and in the
future?
Fall protection is a planned system
used to protect a worker from death
or severe injury in the event of a fall
while working at height. Typical fall
protection systems are classified as
either active or passive. Passive sys-
tems include parapets or guardrails to
prevent a worker from falling. Active
systems “arrest” the worker after they
have fallen. Catching a person in mid-
air has several challenges, therefore a
passive system is the preferred choice
by workers and safety professionals.
Fall protection systems often are
installed in conjunction with façade
access systems. Depending on the
building height or ground access
restrictions, exterior building mainte-
nance can be done from the ground or
while suspended from the roof using
façade access systems. The most com-
mon systems consist of roof anchors/
davits and either a suspended swing-
stage or boatswains chair.
When do you need fall protection?
This is arguably the most debated
topic. It is a misconception that work-
ers only need fall protection if they
are within 6 feet of a roof edge. Occu-
pational Safety and Health Adminis-
tration states in the Code of Federal
Regulations Preamble that “there is
no safe distance from an unprotected
side or edge.”
In fact, it depends on the many cir-
cumstances unique to each condition.
Not only is the safe distance from an
edge debated, but also the vertical fall
distance is inconsistent within the
different codes. Because OSHA is sepa-
rated into General Industry and Con-
struction Industry, there are two differ-
ent triggers for fall protection. General
Industry requires protection at 4 feet,
while the Construction Industry uses a
value of 6 feet. The International Build-
ing Code has its own value of 30 inch-
es. These inconsistencies potentially
expose building owners to liability in
the event of an accident.
As a property manager or building
owner, you may be wondering why
you need to care about this. After all,
you hire private contractors to main-
tain your building exteriors and roofs.
If your building has a façade access
system, then you should have current
records for these systems. “Building
owners of all installations, new and
existing, shall inform the employer in
writing that the installation has been
inspected, tested and maintained in
compliance with …,” according to
OSHA 1910.66.
Further IWCA I-14.1 states, “Building
owners and/or their operating agents
shall provide the window cleaning
contractors with the following written
assurances: … that the installation or
structure has been inspected, tested
and maintained in compliance with
the requirements of this Standard …”
One of the few things the standards
are consistent about is the need for
annual inspections and load testing
every 10 years.
So, back to the question: Is it worth
it? First of all, the law requires build-
ings to have an OSHA-compliant fall
protection system
while performing
maintenance opera-
tions, whether your
building is one story
or 100 stories tall.
Second, if you have
existing systems but
are not performing
maintenance and
inspections, and you
have an accident
involving use of
the systems, OSHA
may issue a willful
negligence citation
for an experienced
owner starting at $70,000. Awards from
civil suits in fall protection cases have
topped $30 million with more com-
mon settlements in the range of $1
million to $5 million. For the last sev-
eral years, the most frequently issued
citation by OSHA was related to fall
protection violations.
If you are considering having your
existing system certified, tested or
inspected, or putting money in the
budget for a new system, you probably
are wondering about the cost. To get
a safety consultant or fall protection
engineer to walk your property, cus-
tomize a fall protection solution, and
develop a schematic plan with a cost
estimate, you should budget $1,000
to $2,000. Existing systems requiring
annual inspections and 10-year load
testing will vary by the number and
type of systems. A rough estimate of
what you should budget for annual
inspections and a 10-year load test is
$1,000 to $2,000 for inspections and
$5,000 to $10,000 for each load test.
Now the million-dollar question,
how much will a new system cost on
an existing building sight unseen?
Well, no surprise, it is much more cost-
effective to have the system installed
during original construction. Design
and installation costs for a retrofit
system will depend on the size and
construction type of your building, as
well as the type of system selected
to meet your maintenance needs.
The cost to retrofit existing buildings
can be 10 times the cost of systems
installed during original construc-
tion and can range from $10,000 to
$100,000 depending on size as well as
when and how the structure was con-
structed.
OK, you’re probably mentally add-
ing up some numbers and wondering
if there is a cheaper way to get your
maintenance and window wash-
ing done without having to install
a permanent FPFA system. Some
owners hire a contractor to do the
maintenance and let them take care
of the fall protection requirements.
The contractor most likely will install
temporary OSHA-required fall protec-
tion, do the work and then remove the
fall protection components.You won’t
have to pay for annual inspections,
but you will pay for every temporary
installation and removal. It adds up. In
the long run, you, as a property owner
or manager, most likely will see sub-
stantial savings with a permanently
installed system that is designed for
your building and your needs.
If you choose to retrofit your building
with fall protection, it pays to do your
homework. Some structures are easier
to retrofit than others. For example,
a concrete or steel structure will be
easier than wood or light-gage steel
structure.Who you hire also makes a
difference. A structural engineer with
fall protection experience can design
a system specific to your building’s
structural system and its limitations
while minimizing costs associated
with reinforcement of the structural
framing. It also may surprise you to
learn that the manufacturers in this
industry typically put a clause in their
new systems contract that it is the
owner’s responsibility to check the
structural framing of your building to
support the new loads. Because these
loads are often 5,000 pounds or higher,
more often than not, the existing
framing cannot adequately support
the loads without some reinforcement
or careful consideration.
It’s a lot to think about, but the bot-
tom line is that fall protection saves
lives, reduces injuries and is required
by law. As a building owner, can you
afford to be without it?
s
Legal
Photos courtesy Martin/Martin
AMartin/Martin structural engineer uses a boatswains chair during a façade investigation.
OSHA-required load testing of an existing davit base for use with a portable davit arm
and swing-stage
Repair contractors rappel down the Colorado Capitol Dome during the final stages of
repair using newly installed permanent tieback anchors.
Andrew
Emmons, PE
Fall protection
engineer, Martin/
Martin Inc.,
Lakewood
