Building owners require a letter of engagement from a with a qualified person or company. This qualified person must have first hand experienced with the roof anchor RDS certification process.
The engagement letter will allow the qualified person to work on behalf of the building owner in coordination with the employer (window cleaner) to start the certification process under the extra time provision granted by OSHA .
The appointment of the qualified person is needed to document the timeline and process, in order to allow window cleaning on buildings equipped with uncertified anchors or systems that are not in full compliance.
The engagement letter will allow building owners to meet OSHA’s “salt test” of taking all appropriate steps and effort necessary to prove proper due diligence to extended the timeline.
This managed certification program must be made available to the Agency as necessary showing written evidence of the actions and anticipated dates.
OSHA will only consider this program acceptable when building owners can demonstrate and document anticipated dates of inspection, testing, certification.
In addition to the engineering engagement letter, the window cleaning company (employer) must take additional steps to ensure all work is performed safely despite full certification and compliance.
These additional steps will allow the employer to use an approved RDS method for window cleaning under the limited use provision and under the supervision of the qualified person.
“Building owners and Employers must take alternative protective measures when working with RDS and uncertified anchors. OSHA will expect that all reasonable care has been taken to ensure that the health and safety of the workers are protected.”
US Inspections Department