Do window cleaners use ladders?

The rules for a ladder start where it meets the ground. The Occupational Safety and Health Administration (OSHA) publishes them on a portable ladder QuickCard, and it opens with the reason: falls from portable ladders, step, straight, combination and extension, are one of the leading causes of occupational fatalities and injuries.

The first rule is the angle. OSHA's card says “The proper angle for setting up a ladder is to place its base a quarter of the working length of the ladder from the wall or other vertical surface.” The construction ladder rule, 29 CFR 1926.1053, puts it the same way, and defines the working length as “the distance along the ladder between the foot and the top support.” Against a house wall, the foot goes out one quarter of that distance.

The second is the ground under it. The card reads: “Use a ladder only on a stable and level surface, unless it has been secured (top or bottom) to prevent displacement.” The general industry rule, 29 CFR 1910.23, says the same in its own words, allowing a ladder that is secured or stabilized.

OSHA keeps these rules in two parts of its regulations, Part 1910 for general industry and Part 1926 for construction. Which part a particular window cleaning job falls under is not decided here; on the rules below, both are quoted where they speak.

OSHA's card puts two checks before anyone climbs. The first is overhead: “Look for overhead power lines before handling a ladder. Avoid using a metal ladder near power lines or exposed energized electrical equipment.” The construction rule, 29 CFR 1926.1053(b)(12), goes further and requires nonconductive siderails where the employee or the ladder could contact exposed energized electrical equipment, “except as provided in” 29 CFR 1926.955(b) and (c), the rules for power transmission and distribution work.

The second is the ladder. The card says to inspect it before use and, if it is damaged, to remove it from service and tag it until it is repaired or discarded. On how often, the two parts differ, and each is stated on its own:

• 29 CFR 1910.23(b)(9), general industry: ladders are “inspected before initial use in each work shift, and more frequently as necessary.”
• 29 CFR 1926.1053(b)(15), construction: ladders “shall be inspected by a competent person for visible defects on a periodic basis and after any occurrence that could affect their safe use.”

Once someone is on the ladder, the card's rule is three points of contact while climbing: “two hands and a foot, or two feet and a hand.”

Near the top, the card says not to stand on the three top rungs of a straight, single or extension ladder. And while anyone is up there, the ladder stays where it is: “Do not move or shift a ladder while a person or equipment is on the ladder.” The general industry rule adds extending to the list, saying no ladder is moved, shifted or extended while an employee is on it.

Read against a house wall, those rules mean a ladder is climbed down before it is moved to the next window, and nobody works from its top three rungs.

Some ladders are not for reaching a window at all but for stepping off onto a surface above, such as a balcony or a roof. For that use, OSHA's card says an extension or straight ladder used to access an elevated surface must extend at least 3 feet above the point of support.

The construction rule, 29 CFR 1926.1053(b)(1), says the side rails extend at least 3 feet above the upper landing surface, and allows one alternative only “when such an extension is not possible because of the ladder's length”: the ladder is then secured at its top to a rigid support that will not deflect, with a grasping device such as a grabrail provided. The general industry rule, 29 CFR 1910.23, requires the same 3 feet of side rail above an upper landing.

Stepping from a ladder onto a roof brings in a different set of rules about edges and heights. Those are defined under fall protection, and a related equipment term under personal fall arrest system.

A ladder leaned straight against a wall can put its top rails across the very window being cleaned. An accessory exists for that. A stabilizer holds the ladder a set distance off the wall across a set span, and one maker, Louisville Ladder, describes its LP-2200-00 stabilizer as “designed to give you extra stability when working near windows.” That is a maker describing its product. The accessory itself is defined under ladder standoff.

Another way to reach upper glass skips the ladder. The National Glass Association records a technique using pure water delivered to the glass on a specialized extension pole, with the rinse generally left to evaporate. With no squeegee pass in that description, no one has to be at the pane. How that works is explained under whether second-story windows can be cleaned from the ground, and the water it needs under pure water and the water-fed pole.