ANSI / IWCA I-14.1 was developed through a volunteer organization to create a consensus standard that will improve the safety of window washing. The standard fills an important gap in the OSHA regulations, which do not provide useful guidance to window washers except when they use building-owned powered platforms (29 CFR 1910.66).

We believe the new ANSI / IWCA standard is a good and important document, and we endorse its widespread use. Reasonably prudent owners, contractors, and designers should be familiar with the standard, and should heed its guidance and use the practicable parts. However, voluntary consensus standards are not mandatory like federal OSHA regulations.

We have heard comments to the effect that the standard will quickly become the standard of care for the property management industry. Certainly, it can be anticipated that it will be cited as a reference standard in any litigation regarding window washing. Nevertheless, we believe that it is not prudent to adopt the standard universally. Property managers should guard against blanket adoption of the standard for the following reasons:

1. Lack of Development Record. The development of a voluntary consensus standard does not involve the rigorous “due process” that all government regulations require. Dissenting opinions are not published, nor is there a readily-available record of the standard development process. For comparison, consider the lengthy commentary that accompanies the publication of a new OSHA regulation so that users can study what is included in the final rule, what was deleted or modified during revisions, and the history of the decisions that culminated in the final rule. Not to criticize ANSI, but its standards do not receive nearly the scrutiny of a proposed new federal regulation; although we and BOMA participated in the development of this standard, the level of industry involvement was far less than if it had been a proposed federal regulation.

2. Lack of Variance Process. There is no variance process for industry standards, as there are for government regulations. Therefore, standards leave us with published absolutes that are not practical for every building. For example, ANSI / IWCA I-14.1 prohibits davit arms in excess of 8 feet 6 inches in length. We just designed a new system with longer davit arms than that; did we “violate” the standard? If this restriction were published in an OSHA regulation (and it is not), then we would simply apply for a variance, stating the engineering reasons for the longer davit arms. With no such established variance process for industry standards, every deviation from the published standard could be mistakenly interpreted as a violation. Beware: most buildings will not comply with at least some provisions of the standard, and yet those buildings may have perfectly safe systems.

3. Lack of Published Interpretations. There is no process for publishing official interpretations of industry standards. By contrast, clarifications, corrections, and interpretations of OSHA regulations are a matter of public record and are readily available. ANSI and IWCA cannot disseminate “official” interpretations, so users are left to interpret the standard for themselves—and this standard does require interpretations!

4. Infrequent Revisions. Even if the standard development committee members become aware of needed revisions, the public only becomes aware of those revisions when a new edition is published. Although ANSI is a non-profit organization, it must still recover the cost of printing and distributing its standards; therefore, revised editions are published only when it is economically viable to so. It can be many years between published revisions, during which time only the few committee members know of the pending changes.

5. Limited Applicability. The standard is only for window washing. The standard is not directly applicable to other routine exterior building maintenance, such as replacing sealant joints. Therefore, a building will need a more comprehensive plan for exterior access than simply relying on this new standard.

6. Not Automatically Incorporated. Unlike federal regulations, industry standards do not automatically apply to every building. Generally, they have to be incorporated by a contract requirement. No matter how good and useful the standard may be, it does not benefit you unless you require your vendors to comply with it.

7. Limited Circulation. Because there is a hefty charge to buy the standard and ANSI strictly prohibits making unauthorized copies, not everyone that needs a copy will have one. Of course, OSHA regulations can be downloaded free from their web site, and copied as necessary.

In addition, there are a few specific items in the standard that we strongly disagree with and that we would not recommend for any building (this is the nature of all consensus standards, and is not a criticism of ANSI or IWCA). Discussing those items is beyond the scope of this brief article.