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Window Washing Program

Table of Contents

1.0 Introduction  
2.0 Objectives and Metrics
3.0 Scope 
4.0 Roles and Responsibilities
5.0 Procedures  
6.0 Training
7.0 Definitions
8.0 References
9.0 Document History

1.0 Introduction

  • 1.1    The Cornell University Window Washing Program establishes requirements and procedures to protect employees and contractors performing window washing on Cornell public buildings. A company may need to develop a Window Washing Plan for approval by both the Cornell Environment, Health and Safety (EHS) Department as well as the New York State Department of Labor (NYS DOL).

2.0 Objectives and Metrics

3.0 Scope

  • 3.1    This program shall be implemented whenever Cornell employees or contractors are engaged in window washing activities.
  • 3.2    This program has been developed for Cornell University employees, contractors, and incorporates all Cornell facilities operating in the state of New York.
  • 3.3    This program only applies to Cornell University public buildings which meet any of the following criteria:
    • 3.3.1    A multiple-dwelling that is 7 stories or greater; OR
    • 3.3.2    The building is 4 stories or more.

4.0 Roles and Responsibilities

  • 4.1    FCS Contracts Department and DFA Procurement and Payment Services
    • 4.1.1    Incorporate and maintain a contractual requirement for contractors to submit an approved Window Washing Plan prior to work taking place.
    • 4.1.2    Communicate with contractors when applicable, to ensure they have ample time to create and submit their Window Washing Plan.   
  • 4.2    Building Managers
    • 4.2.1    Communicate with the cleaning company (either contractor or Cornell employee) when applicable, to ensure they have ample time to create and submit their Window Washing Plan.
    • 4.2.2    Ensure an approved Window Washing Plan has been obtained by the cleaner prior to work taking place.
  • 4.3    Environment, Health and Safety (EHS) Department
    • 4.3.1    The EHS Department develops, supports and oversees the implementation of the Window Washing Program by:
      1. a.    Reviewing all Window Washing Plans submitted by the window cleaner.
      2. b.    Approving or rejecting Window Washing Plan submittals.
      3. c.    Facilitating NYS DOL plan review for final approval.
      4. d.    EHS will forward the approved plan to building managers and submitter.
      5. e.    Periodically inspect window cleaning activities to ensure compliance with the building-specific Window Washing Plan.
      6. f.    Maintaining a database of approved Window Washing Plans.
  • 4.4   New York State Department of Labor (NYS DOL)
    • 4.4.1    The NYS DOL will be responsible to review and provide the final approval of the Window Washing Plan.

5.0 Procedures

  • 5.1    Prior to a cleaner (employee or contractor) performing window washing activities on Cornell buildings, they must electronically submit a Window Washing Plan for approval.
    • 5.1.1    The Window Washing Plan will need to be approved by both the Cornell Department of Environment, Health and Safety and the New York State Department of Labor.
  • 5.2   Window Washing Plan (WWP)
    • 5.2.1    The purpose of the Window Washing Plan is to ensure the cleaner is using safe and authorized window cleaning means and method(s) on Cornell University public buildings according to the requirements set forth by the New York State Department of Labor.
    • 5.2.2    A Window Washing Plan will need to be submitted and approved for the initial cleaning of a building’s windows before work can begin.
    • 5.2.3   Following the initial building WWP approval, subsequent WWPs on the same building will be required if any of the following conditions change from what was initially included:
      • a.    Cleaning methods used
      • b.    Sides of the building(s)
      • c.    Equipment used for each cleaning method
    • 5.2.4   The Window Washing Plan can be submitted by completing the Window Washing Questionnaire located in the Cority incident reporting portal.
  • 5.3    Authorized means and methods for cleaning windows
    • 5.3.1    A cleaner will only use authorized and approved means and methods of cleaning windows.
    • 5.3.2    The following means and methods are authorized by NYS for window cleaning.
      • a.    Working from safe surfaces
      • b.    Working from window sills or ledges
      • c.    Working from ladders
      • d.    Working from boatswain’s chairs
      • e.    Working from scaffolds
  • 5.4    Working from safe surfaces or cleaning from the inside
    • 5.4.1    Working position. In using this method for cleaning from the inside, the cleaner shall work from a position on the floor or other interior surface or on an interior sill which is not more than four feet above a floor or stair landing or more than three feet above a stair run.
    • 5.4.2    Working surface. In using this method for cleaning from the outside, the cleaner shall work from a position on the ground level or on a roof, balcony, or other structural part of the building which is capable of sustaining the weight of the cleaner and his equipment. The surface on which the cleaner works shall not be pitched more than 1:12”. It shall either extend four feet or more about the working position or be provided with a firm railing or parapet at least 42 inches high.
    • 5.4.3    Cleaning from the inside. When cleaning from the inside, the cleaner shall not place or extend more of his body than one arm beyond the window sash.
    • 5.4.4    Objects on the working surface. The cleaner shall work from the safe surface and not from any unstable object placed thereon.
    • 5.4.5    Slippery surface. The cleaner shall not work from a surface on which there is snow, ice, or other slippery substance.
  • 5.5    Working from window sills or ledges
    • 5.5.1    Use of Method. A cleaner shall not be suffered or permitted to clean a window from the outside by this method except a window which is so constructed, equipped, and maintained as to be safe for cleaning by the use of fall protection and fall protection harness (herein called a safe window) and certain other windows below described.
    • 5.5.2    A safe window is one which complies with all of the following requirements:
      • a.    It shall not be horizontally pivoted.
      • b.    If it is vertically pivoted or hinged it shall afford an unobstructed passage space to the exterior sill at least 16 inches wide and 40 inches high, and it shall be so constructed that when it is open it does not interfere with the attachment of the fall protection harness, connecting means or anchor.
      • c.    If it is double-hung or counterbalanced, it shall afford an unobstructed passage space to the exterior sill not less than 21 inches wide and 30 inches high from the sill.
      • d.    It shall afford a safe way of approach from an interior floor level to the passage space.
      • e.    It shall have an unobstructed sill or ledge providing a footing at least four inches wide or the full width of the window frame.
      • f.    It shall have its movable parts readily operable and in good condition.
      • g.    It shall be structurally adapted to an authorized installation of anchors.
    • 5.5.3    Special Windows
      • a.    Where three windows with two separating mullions are set in the same wall opening, and the center window is a safe window and the sash openings of the two outer windows are less than 21 inches wide, this method may be used to clean the outer windows from a position on the sill or ledge of the safe window.
      • b.    Where three windows with two separating mullions are set in the same wall opening, and the two outer windows are safe windows, and the center window is not a safe window, this method may be used to clean the center window from a position on the sill of either safe window or astride either mullion.
      • c.    Where a single fixed sash window has adjacent thereto a safe window on either side with separating pilasters 16 inches or less in width and six inches or less in depth from their face to the glass and the fixed sash window has a sill at least three inches deep, this method may be used to clean the fixed sash window from a position on the sill of either safe window or astride either pilaster.
    • 5.5.4    Anchors required. A window cleaned by this method shall be equipped with approved anchors, installed as authorized, and so maintained.
      • a.    Exception: A window having the sill or sills from which the cleaning is done not more than 4 feet above the ground, the floor, or equivalent surface.
    • 5.5.5    Fall protection harness required. The cleaner shall be provided with an approved fall protection harness.
      • a.    Exception: When working from a sill or ledge not more than 4 feet above the ground or an equivalent surface.
    • 5.5.6    Attaching fall protection harness. The cleaner shall attach one harness terminal to an anchor without extending more than one arm beyond the window sash before climbing out, and the other terminal to the opposite anchor before or immediately upon climbing out. When cleaning is done from an interior sill four feet or more high both terminals shall be attached to anchors before work is begun.
    • 5.5.7    Keeping both terminals attached. The cleaner shall keep both harness terminals attached to separate anchors during the cleaning operation.100% fall protection is required at all times
    • 5.5.8    Keeping one terminal attached. The cleaner shall keep one harness terminal attached to an anchor until he has returned inside the window.
    • 5.5.9    Passing. The cleaner shall not pass from one window to another or from one part of a multiple window to another at a level more than four feet above the adjoining floor or ground surface.
    • 5.5.10    Slippery sills. The cleaner shall not work on a sill or ledge on which there is snow, ice, or other slippery substance.
    • 5.5.11    Objects on sills. The cleaner shall not stand or support himself on any object placed on a sill or ledge.
    • 5.5.12    Using defective anchor. The cleaner shall not be suffered or permitted to use an anchor which is inaccessible, loose, damaged, deteriorated, or altered.
    • 5.5.13    Using defective fall protection harness. The cleaner shall not be suffered or permitted to use a fall protection harness which has been used for testing purposes or which is materially damaged, deteriorated, or excessively worn in any part. A terminal slot is excessively worn if any point accommodates a 9/16 inch plug gauge.
  • 5.6    Working from ladders.
    • 5.6.1    Use of method. The use of this method is prohibited for cleaning a window where any of the following conditions exist:
      • a.    The interior surface of the window is to be cleaned and the top of such window is more than 35 feet above the nearest interior floor or equivalent surface on which the base of the ladder is to be placed.
      • b.    The exterior surface of the window is to be cleaned and the top of such window is more than 35 feet above the nearest street or ground surface.
      • c.    The window is so placed or obstructed as to make the method unsafe.
    • 5.6.2    Ladders over 18 feet – holding. At all times when a cleaner is working on a ladder over 18 feet long, a person shall stand at the foot of it, face it and hold it with both hands.
    • 5.6.3    Sidewalk doors. No ladder shall be rested on a sidewalk door.
    • 5.6.4    Protection against slipping. All ladders shall be provided with means to prevent slipping suitable to the bearing surface.
    • 5.6.5    Inspection of ladders. Each ladder shall be inspected before each use by the person using it
    • 5.6.6    Maintenance and replacement. Ladders shall at all times be maintained in a safe condition. Any ladder having a broken member or part, or any insecure joint between members or parts or any flaw or defect of material that may cause failure or any rung or step that is worn down to three quarters or less of its original thickness shall be immediately taken out of service for necessary repairs or replacement
  • 5.7    Working from boatswain’s chairs.
    • 5.7.1    Approval required over 75 feet. A boatswain's chair which is suspended from a point with an elevation of more than 75 feet above the nearest street or ground surface shall be approved for the specific building and location where it is to be used to clean windows. Approval will not be considered unless other authorized means of cleaning the windows have been found impracticable or impossible due to the exterior features of the building.
    • 5.7.2    Suspended point height of 75 feet or less. A manually operated boatswain's chair which is suspended from a point with an elevation of 75 feet or less above the nearest street or ground surface is not required to be approved but shall conform to the following requirements:
      • a.    Fall protection harness and lifeline required. Each person working from a boatswain's chair shall be provided with and shall use an approved fall protection harness and a lifeline consisting of a hanging line and a tail line. The tail line shall be of minimum practical length and shall be attached to the hanging line by an approved special device to allow vertical adjustment of the point of attachment.
      • b.    Protection of all areas below work. Where a boatswain's chair is suspended over an area traversed by pedestrians or vehicular traffic, the ground area directly under the chair work zone shall be effectively blocked by a barricade, or an attendant shall be stationed so as to keep the area clear.
      • c.    Skilled operators. Persons not trained in the use of boatswain’s chairs shall not use such equipment.
      • d.    Chairs. Boatswain’s chairs and all supports shall be designed and constructed to sustain without failure a minimum load of 600 pounds. Each chair shall be suspended from its four corners by means of rope slings, have a seat not less than 24 inches long by 10 inches wide and two inches in thickness if of soft wood or one and one-eighth inches in thickness if of oak or ash, and be reinforced across the full width by cleats securely fastened to each end. The chair seat may be constructed of material other than wood, provided the material is equivalent in strength to two inches of soft wood or one and one-eighth inches of oak or ash. If constructed of material of equivalent strength, cleats across the full width of the seat shall be provided unless structural analysis indicates they are not necessary.
      • e.    Tackle. Tackle shall consist of rope at least equal in strength to five-eighths inch first grade Manila rope and proper sized blocks. Rope attachment to block shall be by a thimble and splice. Hooks shall be provided with means to prevent accidental disengagement.
      • f.    Anchorage. The object to which the tackle is anchored shall be rigid and of ample strength.
      • g.    Tie-ins. Tie-ins shall be provided for boatswain’s chairs and used by the cleaner to prevent sway during the window cleaning operation.
    • 5.7.3    Powered boatswain’s chairs. A powered boatswain’s chair used for window cleaning shall be approved in respect to its hoisting machine and shall be subject to the requirements set forth above in Section 5.7.1 and Parts A-G of Section 5.7.2.
  • 5.8    Working from scaffolds.
    • 5.8.1    Compliance with Part (Rule Number) 23. Every scaffold used for cleaning by this method shall be designed, constructed, installed, operated, and maintained in compliance with all relevant provisions of Part (Rule No.) 23, Protection of Persons Employed in Construction and Demolition Work, as amended, except as the board may otherwise provide in this Part (rule) or in a resolution of approval of a specific scaffold or type thereof' and OSHA 1926 Subpart L-Scaffolds.
    • 5.8.2    Maintenance and inspection requirements.
      • a.    The owner of the scaffold shall establish and maintain a log showing inspection and maintenance work performed on the scaffold. The maintenance schedule and log sheet, recorded on forms furnished by the commissioner, shall be available at the site for use by the commissioner or his authorized representative.
      • b.    Prior to being put into operation on any day, the scaffold shall be subjected to a preliminary inspection and test to assure its safe condition. Results of this inspection shall be noted in the log. This inspection shall be performed by the foreman or other responsible person trained in the use and operation of the scaffold.
      • c.    Upon discovery of any substantial defect or abnormal condition in the scaffold or any part thereof, the scaffold shall be placed out of operation until such time as the abnormality or defect has been corrected and the scaffold restored to its normal condition.
    • 5.8.3    Suspended scaffolds - 75 feet or more. Every suspended scaffold so used to include both manually or power-operated types shall be approved if it is or is intended to be suspended from any point which has an elevation 75 feet or more above the nearest street or ground surface.
    • 5.8.4    Suspended scaffolds not exceeding 75 feet; lifelines.
      • a.    Every scaffold including both manually and power operated types which is suspended or is intended to be suspended from any point not exceeding 75 feet in elevation above the nearest street or ground surface is required to be approved only in respect to any hoisting machine which may be used thereon, provided that all other components comply with Part (Rule No.) 23. A block and tackle is not construed to be a hoisting machine. Any part of such scaffold assembly and suspension which is not named or described in Part (Rule No.) 23 is required to be approved pursuant to section 23.26 of said Part (rule) and OSHA 1926 Subpart L-Scaffolds.
      • b.    Each person working on such a suspended scaffold shall be provided with and shall use an approved fall protection harness. Each harness shall have its own lifeline, which shall consist of a hanging line and a tail line. The tail line shall be of minimum practical length and shall be attached to the hanging line by an approved special device to allow vertical adjustment of the point of attachment. The lifeline shall be securely attached to a sufficient anchorage.

6.0 Training

  • 6.1    Training requirements include the following topics, which are to be provided to the employee by their employer before window washing activities can take place:
    • 6.1.1    Fall Protection - 1926 Subpart M, 1910.140 Subpart I
    • 6.1.2    Ladder Training - 1926 Subpart X, 1910.23 Subpart D
    • 6.1.3    Scaffolding - 1926 Subpart L, 1910.27 Subpart D
    • 6.1.4    Boatswains chairs - If being used as a cleaning method only skilled operators can operate this device after training
  • 6.2    If there are questions about the Window Washing Program, contact the EHS Department or askEHS.

7.0    Definitions

  • 7.1    Cleaner – A person doing the actual work of cleaning a window.
  • 7.2    Extension Devices- A cleaner using an extension device above the first floor shall attach it to his person by a wrist loop or otherwise to prevent dropping
    • 7.2.1    Each extension device used above the first floor shall have a locking device to prevent inadvertent detachment of the brush or squeegee
  • 7.3    Multiple-Dwelling – A dwelling which is either rented, leased, let or hired out, to be occupied, or is occupied as the temporary or permanent residence or home of three or more families living independently of each other, including but not limited to the following: a tenement, flat house, maisonette apartment, apartment house, apartment hotel, tourist house, bachelor apartment, studio apartment, duplex apartment, kitchenette apartment, hotel, lodging house, rooming house, boarding house, boarding and nursery school, furnished room house, club, sorority house, fraternity house, college, and school dormitory, convalescent, old age or nursing homes or residences. It shall also include a dwelling, two or more stories in height, and with five or more boarders, roomers, or lodgers residing with any one family.
  • 7.4    Public Building – Shall include a factory building, an office building, a mercantile building, a hotel building, a theatre building, a warehouse building, an apartment building, a State or municipal building, a school, a college or university building, a building containing a place of public assembly maintained or leased for pecuniary gain, or any other building more than one story high except a dwelling house less than three stories high or occupied by less than three families.
  • 7.5    Safe Window – A window which is so constructed, equipped, and maintained as to be safe for cleaning by the use of anchors and fall protection harness; also includes other windows as described in Section 5.5.3.
  • 7.6    Story – A space between the level of one finished floor and the level of the next higher finished floor, or, if the top story, of the space between the level of the highest finished floor and the top of the highest roof beams, or, if the first story, of the space between the level of the finished floor and the finished ceiling immediately above. For the purpose of measuring height by stories of dwellings erected on or after July 1, 1952, one additional story shall be added for each 12 feet or fraction thereof that the first story exceeds 15 feet in height, and for each 12 feet or fraction thereof that any story above the first story exceeds 12 feet in height.
  • 7.7    Window – A window installed in a public building which is subject to the provisions of section 202 of the NYS Labor Law.
  • 7.8    Window Washing Plan – This document explains in detail how a cleaner is proposing to safely wash a building’s windows in a manner with approved means and methods. This document will require approval by both the Cornell Environment, Health and Safety Department and the New York State Department of Labor before window washing activities can begin.

8.0    References

9.0 Document History

 

Documentation
Date Change Made by
01/08/2020 Initial Document Jmk492
10/07/2021 Updated Section 5.2.4 to include information on the new Window Washing Questionnaire located in the Cority incident reporting portal. Npg24