This section includes information about possible ways to achieve compliance for the listed situations. It does not represent the exhaustive measures and procedures required by the Occupational Health and Safety Act and its regulations related to window cleaning operations.

This resource does not replace the Occupational Health and Safety Act (OHSA) and its regulations and should not be used as or considered legal advice. Health and safety inspectors apply and enforce these laws based on the facts they find in the workplace.

Program positions discussed relate to the applicability of the regulation for construction projects as well as Regulation 859: Window cleaning when window cleaning is done on a construction project. They also relate to the adequate use of fall protection and inspections of fall protection systems components under the regulatory requirements.

Window cleaning on a construction project


Do the provisions of the regulation for construction projects O. Reg. 213/91 apply to window cleaning operations carried out on a construction project?


The window cleaning regulation is hazard specific. It applies concurrently with sector specific regulations. Hence, when window cleaning operations are conducted on a construction project, the regulation for construction projects (O. Reg. 213/91) also applies. In this circumstance, the regulation which provides the greatest protection to the workers would prevail.

The use of a triple hitch as a fall arrester


Is a triple hitch generally considered an adequate fall arrester?


No, using a triple hitch as a fall arrester is not allowed as it does not provide adequate protection. Every primary suspension line for a boatswain’s chair or similar single-point suspension equipment that is made of organic or polymer fibres shall be used only with a descent control (fall arrester) or similar device (clause 27(2)(d) of Reg. 859). The descent control device must be approved by the manufacturer for window cleaning and used in accordance with the manufacturer’s instructions (clauses 27(3) (a) and 27(3)(b) of Reg. 859).

The use of rope access in window cleaning


Is rope access allowed for window cleaning operations?


Rope access is not prohibited under the window cleaning regulation (Reg. 859). It may be used for window cleaning operations when done in compliance with the applicable sections of Reg. 859 and if the obligations in the Occupational Health and Safety Act have been met.

Rope access uses a two-rope system that:

  • employs a working rope/line and a safety rope/line for back-up fall protection should the main suspension line fail. In rope access, the safety line acts as the “lifeline” required by Regulation 859: Window cleaning
  • works in combination with a full body harness, lanyards, other devices such as anchors, ascenders, belay devices, back up devices and fall arrestors
  • ensures each rope/line is always attached to separate and independent anchor points

Rope access is called a two-rope system because the working line and the safety line are interchangeable so that the working line may become the safety line, and vice versa, based on the rope access maneuver being performed by the rope access technician.

Employers must ensure that under OHSA subsection 25(2)(a) workers using rope access to perform window cleaning activities are provided with information, instruction and supervision to protect the health and safety of the worker. Workers who are certified in and working in compliance with the Industrial Rope Access Trade Association’s (IRATA) Code of Practice, or Society of Professional Rope Access Technicians’ (SPRAT) Safe Work Practices are considered competent to perform rope access and in compliance with the OHSA and applicable sections of Reg. 859.

Training, certification and work practices other than those set out by IRATA or SPRAT may also satisfy the requirements of the OHSA and Reg. 859. In general, an employer relying on another source of training and certification should be able to demonstrate to an inspector that the alternate training, certification and work practices satisfy the requirement outlined in the OHSA to “take every precaution reasonable in the circumstances for the protection of a worker” [OHSA, clause 25(2)(h)].

For more information on rope access used for window cleaning please visit Access and fall protection best practices.

Inspection of building anchors set up for suspended access equipment used in window cleaning


Who can perform building anchor inspections under the window cleaning regulation?


Every owner of a building where a suspended scaffold, boatswain's chair or similar single-point suspension equipment is to be used for window cleaning or where sill work is done must use a competent person to inspect all anchor points and permanently-installed suspended scaffolds in these situations:

  • before being used for the first time
  • as often as necessary but not less frequently than recommended by the manufacturer of the anchor points or the suspended scaffolds, as the case may be
  • in any case, at least once a year
  • when informed of an inadequacy or defect (Reg. 859 subsection 41(1) and section 43)

The competent person who carries out the inspection does not need to be a professional engineer.

A building owner must keep a record of the inspections of any anchor points and any permanently installed suspended scaffold at a building in a logbook. The logbook must be maintained and retained as long as the anchor points and suspended scaffold are used and contain the following information:

  • the date on which each inspection is made
  • the name and signature of the person making the inspection
  • any modifications or repairs made to an anchor point or a suspended scaffold including the date they are made and the name and signature of the person making the modifications or repairs (Reg. 859 subsections 41(4) and 41(5))

Under the OHSA, the onus is on the window cleaning employer to “take every precaution reasonable in the circumstances for the protection of a worker” (OHSA, clause 25(2)(h)). Consequently, as part of their due diligence, the window cleaning employer must ensure that the building owner used the services of a competent person to perform the annual inspections.

Testing of adhesive anchors


Do 100% of the adhesive anchors in use have to be tested every five years?


The window cleaning regulation does not contain specific provisions for such testing.

Article 8.5.1 of CAN/CSA Standard Z91-17 (Health and safety code for suspended equipment operations) recommends that, “Systems incorporating post-installed fasteners shall be tested after initial installation and at intervals not exceeding five years in accordance with CAN/CSA-Z271.”

Also, CAN/CSA Z271-10 (Safety code for suspended platforms) article 11.3.3 requires that, “each post-installed bolt that is new or altered and is part of an anchorage connector installation shall be inspected and tested to verify strength equal to at least 75% of the design load for the application.”