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|MCL Nov/Dec 2013 - MNOSHA Statute Update|
MNOSHA Statute Update
Suspended Work Anchorage Requirements
by Matt Doughty, Encompass Inc.
The Minnesota Occupational Safety and Health Administration (MNOSHA), under the jurisdiction of the Minnesota Department of Labor and Industry, has strengthened safety standards related to fall protection for suspended work such as exterior wall repair, exterior wall maintenance, and window cleaning.
The new standards, issued on March 1, 2012, provide a higher level of safety for personnel performing building maintenance, repair, and window cleaning services from suspended platforms or rope descent systems. Buildings are now required to have certified and identified anchorage locations for attachment of suspended equipment and secondary lifelines, as outlined within Minnesota Administrative Rules section 5205.0730, titled "WINDOW CLEANING; BUILDING MAINTENANCE”. This standard and additional information regarding the standard can be referenced on the Minnesota Department of Labor and Industry website at https://www.revisor.leg.state.mn.us/rules/?id=5205.0730 and http://www.dli.mn.gov/OSHA/Pdf/76_0712sl_windowwashingfaqs.pdf.
The required certified and identified anchorages can take many forms but often consist of structural attachment points, attached to roof framing and/or structural elements on the roof that can withstand the prescribed MNOSHA loads. Building elements can be verified as compliant for certification per evaluation, analysis, or testing. The anchorage locations are required to be certified by a qualified individual, as defined in the 5205.0730 statute.
As a result of the recent implementation of the statute, many buildings are not compliant due to either an absence of certified anchorages or in-place anchorages that are in need of certification to allow for suspended work.
Commonly posed questions from associations include: "Does our building need to be compliant?”, "Is our building compliant?”, and "How do we make our building compliant?” One way to proceed in response to these questions is as follows:
Assess the overall building and roof configuration. Many existing three or four-story structures are readily and cost-effectively accessible from the ground using a high lift or ladders and thus do not need suspended workers or related roof anchorages. Taller buildings that are not easily accessible via ground equipment often require anchorages.
If anchorages are needed, the next step is to assess what the building currently has. An association should review its maintenance files for records regarding existing anchors and/or review the roof for the existence of roof anchorages. Note that if existing anchors are present without compliant certification letters and inspection reports, additional certification and/or inspection activities are required prior to use.
In the absence of certified anchorages, an engineer or other qualified personnel can be engaged to review the roof configuration, analyze existing roof features for potential usage as certifiable anchorage points, as well as provide a design for new anchor installations.
If new anchors are being installed or existing anchors are in place but uncertified, load testing of anchors is usually required by the entity providing the certification.
Upon completion of the anchorage certification process (anchor design, review, and/or testing), the association should receive a certification letter and usage log book by the entity responsible for the certification. Certifications are typically valid for a 10 year duration, yet visual inspections by a competent individual are also required yearly and prior to each use, in addition to the certification.
The steps outlined above are one way to navigate through the certification process, yet may vary as each building is unique.
If it is determined that certified anchorages are needed on a specific building to facilitate suspended wall maintenance/repairs or window washing activities, the association can begin moving toward compliance with MNOSHA standards via engagement of a qualified individual, such as a licensed engineer.Published by Community Associations Institute — Minnesota Chapter, copyright 2013. All articles and paid advertising represent the opinions of authors and advertisers and not necessarily the opinion of either Minnesota Community Living or CAI–Minnesota Chapter. The information contained within should not be construed as a recommendation for any course of action regarding financial, legal, accounting, or other professional services by the CAI–Minnesota Chapter, or by Minnesota Community Living, or its authors. Articles, letters to the editor, and advertising may be sent to Chapter Staff Editor Joanne Penn at firstname.lastname@example.org, or at CAI–Minnesota Chapter, 1000 Westgate Dr., Suite 252, St. Paul, MN 55114.