The Window Cleaners Need a Letter From You Before They Go Over the Roof Edge. Under 1910.27, It's One Letter Per Building.

The window-cleaning contractor's crew arrives at one of your buildings at seven in the morning. Before anyone rigs a line, their supervisor asks the facilities coordinator for the anchorage certification. The coordinator has never heard of it. She calls the regional facilities manager, who thinks corporate real estate handles roof anchors. Corporate real estate thinks the contractor brings their own. The crew waits, or worse, it doesn't.

That conversation plays out differently at every building in a portfolio, and it is driven by a short paragraph in OSHA's walking-working surfaces rule that puts an obligation squarely on the building owner rather than on the contractor doing the work. This post is about that paragraph, 29 CFR 1910.27(b)(1), and why an organization that owns or controls many buildings needs to treat it as a per-building record rather than a line in a vendor contract.

A duty OSHA assigned to the owner, not the employer

Most OSHA obligations fall on the employer of the exposed worker. Rope descent systems are an unusual exception. Under 1910.27(b)(1)(i), before any rope descent system is used, the building owner must inform the employer in writing that the building owner has identified, tested, certified and maintained each anchorage so it can support at least 5,000 pounds, in any direction, for each employee attached.

The same paragraph sets the basis for that written statement. It must rest on an annual inspection by a qualified person, and on certification of each anchorage by a qualified person as necessary, and at least every 10 years.

The contractor's side is in 1910.27(b)(1)(ii). The employer must ensure that no employee uses any anchorage before the employer has obtained that written information from the building owner, and must keep it for the duration of the job. A well-run window-cleaning or facade-maintenance contractor will therefore ask for the letter every time. A contractor that doesn't ask is a warning sign in its own right.

Put those two provisions together and the practical effect is clear. The document the crew needs at the roof hatch is one only the owner can produce, and it has to reflect the condition of that specific building's anchorages, inspected within the past year.

Why a portfolio makes this harder than it looks

For an owner of one building, this is a calendar reminder and a folder. For an organization with dozens or hundreds of locations, three things turn it into a visibility problem.

The first is that anchorages are physical and local. Davits, roof anchors, parapet tiebacks and embedded eyebolts were installed by different contractors at different times to different designs. Some buildings came with them. Some were retrofitted after a renovation. Some have anchors nobody at head office knows exist. The standard speaks of "each anchorage," so the unit of compliance is not the building, and certainly not the company, but the individual anchor point.

The second is that the annual inspection clock runs separately for every building. If inspections are bought locally, each site may use a different qualified person, on a different month, producing a different kind of report. Head office can easily believe the portfolio is covered because a master services agreement exists, while several buildings have quietly gone past their annual date.

The third is ownership itself. Portfolios mix owned buildings, leased buildings, and space in multi-tenant properties. The regulation places the duty on the building owner. Where you lease, your landlord may hold the certification and you may simply need a copy; where you own and lease out, you may be the one your tenants' contractors are asking. Which role you occupy at each address is a question the lease and the facilities team can answer, but only if someone asks it building by building.

The rest of the rope descent rule still happens at the site

The anchorage letter is the piece that most often gets lost between corporate and site, but 1910.27(b)(2) sets out conditions for the work itself, and several of them depend on the specific building.

Rope descent systems may not be used above 300 feet above grade unless the employer demonstrates that other means of access are not feasible or pose a greater hazard. Stabilization must be provided at the work location for descents greater than 130 feet. Each employee must use a separate, independent personal fall arrest system, the system must be inspected at the start of each shift it is used, and prompt rescue must be provided in the event of a fall. Ropes must be padded or protected where they can contact building edges, and the work may not proceed in hazardous weather such as storms or gusty or excessive winds.

Most of those duties belong to the contractor's employer. But height, facade geometry, roof edge condition and the practicality of rescue are properties of the building. An organization that knows which of its buildings exceed those height thresholds, and which have permanent powered platforms governed separately by 1910.66, is in a far better position to choose and brief contractors than one that finds out when the crew is already on the roof.

When your own employees are on the ropes

Some organizations don't use outside contractors for facade work at every location. A maintenance team at a campus or a hotel may clean windows, change signage, or inspect facades using its own rope descent equipment. In that case the organization is both the building owner under (b)(1)(i) and the employer under (b)(1)(ii) and (b)(2).

Being both does not remove either obligation. The written certification still has to exist, still has to rest on an annual inspection by a qualified person, and the employer still has to ensure employees do not use anchorages that lack it. Employees using the system must be trained in accordance with 1910.30. Where some sites contract out and others self-perform, the same portfolio can end up running two different compliance models without anyone at the enterprise level being aware of the split.

What visibility looks like here

None of this calls for a new program. It calls for someone accountable for safety across the portfolio to be able to answer a few questions for every building. Does this building have anchorages used for rope descent work, and how many? Who is the building owner for purposes of 1910.27, and if it is not us, do we hold a copy of the owner's certification? When was each anchorage last inspected by a qualified person, and when was it last certified? Who at the site produces the written statement when a contractor asks for it? Does anyone at this location self-perform rope descent work, and if so, are they trained under 1910.30?

Organizations that answer those questions consistently tend to treat anchorage status as a tracked attribute of each building, with the inspection date and the certifying qualified person recorded where head office can see them. That is a very different posture from assuming the facilities contract covers it. It is worth asking how your current systems would respond if a contractor's supervisor at your least-visited building asked for the letter tomorrow morning.

This is general information, not legal advice. Anchorage design and certification are engineering questions for a qualified person, and where a lease leaves the building owner role unclear, it is worth resolving before the next facade job is scheduled. If you would like to see how WorkSafely Enterprise approaches site-level compliance visibility across a portfolio, request a demo or talk to sales.