“What is an Operating Procedures Outline Sheet (OPOS) – and do I legally need one?
That’s a good question. Let’s break it down.
WHAT IS AN OPOS?
An Operating Procedures Outline Sheet (OPOS) is a document/drawing that includes the necessary elements in pictorial and written form to instruct employees about the safe use of roof-supported building maintenance equipment or window cleaning procedures. It shall lay out those methods and procedures in a fashion that is comprehensive, legible and easy for everyone to follow.
The primary intent of the OPOS is to have a document available that clearly outlines the safe methods and procedures to access the building façade that can be easily understood by the appropriate employee. Also, it shall clearly inform the cleaners if there are any dangers on the building that they should be aware of. An OPOS is NOT designed to teach or train window cleaners on how to use or operate any suspension system. The training of employees is the sole responsibility of their employer: the window cleaning contractor.
WHY DO SO MANY BUILDINGS HAVE AN OPOS, EVEN THOUGH THEY DON’T NEED ONE?
In the early 2000s, many of the larger real estate investment trusts (REITs) had major window cleaning accidents on the East Coast. To eliminate or greatly reduce the chance of future window cleaning accidents anywhere in the country, they required a “Service Plan” (AKA OPOS in California) for all their buildings. This meant a lot of buildings in California that did not legally require an OPOS had one created for the building regardless. This also started a mindset for building owners and property managers that all buildings need an OPOS.
I HIGHLY recommend that all buildings have an OPOS regardless if it is required or not. An OPOS increases workers’ knowledge/familiarity of the appropriate methods to access the facade for maintenance work, which in turn can dramatically reduce liability caused by accidents. In my opinion, it is the cheapest form of insurance for the building owner. A onetime cost will last for many years.
DO I NEED AN OPOS?
Not all buildings legally require an OPOS! An OPOS is needed only when your building meets certain conditions outlined by Cal/OSHA. Under Article 5 of General Industry Safety Orders, Section 3282(p)(1)(C): “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 building does not have established window cleaning system or procedures meeting the requirements specified in Articles 5 and 6.” Note: A davit/socket, eyebolt, outrigger system, and/or a Permanently Installed (PI) swing stage system ARE considered “an established window cleaning system” by Cal/OSHA and therefore do not legally require an OPOS if the building has the correlating procedures. Any modifications to the original system or procedures would deem this void. The building shall also have emergency procedures in place for the window cleaners.
- “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.” This requirement was originally written mainly to address older buildings that have now-antiquated window cleaning anchors (see picture). Today, however, this section also applies to any major modifications to the roofs and/or curtain walls that affect the existing window cleaning system. Most older buildings, for example, have replaced their original double-hung windows with fixed windows to provide more efficient air conditioning. Such a modification would require an OPOS.
- “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.” Think of the Disney Concert Hall, the Wilshire Grand Center, or the Wilshire Figueroa Tower. These building require complex riggings that are out of the norm. Depending on the experience of the window cleaning contractor, some of these building may be overwhelming to the inexperienced window cleaning contractor. Unfortunately, many window cleaner contractors take on a larger project like the ones mentioned above either for clout and or ego. Formula for disaster.
TWO OTHER CONDITIONS THAT TRIGGER THE REQUIREMENT OF AN OPOS
- An OPOS is required when the use of counterweighted outrigger beams is needed for your window cleaner to access your building to clean windows. This equipment is commonly used by all types of construction trades, e.g. painters, glaziers, waterproofers, etc., but it is illegal for window cleaners to use them.
- An OPOS is also required if the use of a controlled Descent Apparatus (CDA), otherwise known as a bosun or boatswain chair, is needed for window cleaning.
WHAT SHOULD I DO IF I HAVE AN OPOS?
To ensure and increase the effectiveness of an OPOS, I recommend the following:
- Send a copy of the OPOS to the window cleaning contractor so that they fully understand what it contains. Include with it a Letter of Assurance for them. Make sure you have some type of written confirmation from them that they received both items.
- We also suggest that the window cleaning company provide each laborer a copy of the OPOS.
- The OPOS should be laminated and posted on the roof level next to the roof access door. This placement makes it easy for window cleaners to see the OPOS as they exit to the roof.
- Make sure the window cleaners have some type of communication with a building representative on site (walkie-talkie or cell).
FOR MORE INFORMATION:
Should you like to see the codes for yourself, click on the links below to read the Cal/OSHA window-cleaning regulations that are pertinent to the following types of buildings:
Article 5. Window Cleaning
Article 6. Powered Platforms and Equipment for Building Maintenance
Schedule a Free Safety Seminar by HSG
HSG will conduct a 45-minute educational seminar for your property managers and engineers at your facility free of charge. This will ensure your team is familiar with all the laws that are required for property managers and window cleaning contractors.
To schedule an appointment, call 323-733-8552 or email Hector@hsg-inc.com
Have a Cal/OSHA-related question? Scroll to the bottom of this page and ask Hector!
Or contact him directly. Email Hector Garcia, President of HSG at Hector@hsg-inc.com or call 323-733-8552.