Operating Procedures Outline Sheet (OPOS)

An OPOS, or Operating Procedures Outline Sheet, is an OSHA document that contains elements in pictorial and written form to inform window cleaners about the safe use of roof-supported building maintenance equipment or window cleaning procedures. It needs to lay out those procedures in a way that’s comprehensive, but easy for everyone to follow.

The principal intent of an OPOS is to put in picture form the layout of a building’s rooftop so the window cleaner(s) can easily see where the swing stage is positioned and where to secure their life-line. Also, it should clearly inform if there are any dangers on the building that workers should be aware of. An OPOS is NOT designed to teach or train window cleaners on how to use or operate any suspension system. That training is the sole responsibility of their employer: the window cleaning contractor.

Do You Need An OPOS?

Not all buildings legally require an OPOS!An OPOS is only required under certain conditions (explained below). In the early 2000s, many of the larger real estate investment trusts (REITs) had major window cleaning accidents on the East coast. To eliminate or greatly reduce the chance of future window cleaning accidents anywhere in the US, they required a “Service Plan” (AKA OPOS in California) for all their buildings. This meant a lot of buildings in California that did not legally require an OPOS had one created for the building regardless. This also started a mind set for building owners and property managers that all buildings need an OPOS. For the record, I HIGHLY recommend that all buildings have an OPOS regardless if it is required or not. It increases the knowledge/familiarity of the building to the window cleaners, which decreases the possibility of accidents. In my opinion it is the cheapest form of insurance for the building owner. A onetime cost will last for at least 15 years.

When Do I Need An OPOS?

As stated in Article 5 of General Industry Safety Orders: “(C) 1. Owners of buildings 36 feet or more in height shall have an Operating Procedures Outline Sheet (OPOS) where one or more of the following conditions apply to such buildings:

"A building does not have established window cleaning system or procedures meeting the requirements specified in Articles 5 and 6." Note: A davit/socket, eyebolt, outrigger system, and/or a Permanently Installed (PI) swing stage system ARE considered “an established window cleaning system” by OSHA and therefore do not legally require an OPOS.
“A building's original window cleaning procedures prepared in accordance with the requirements in Articles 5 and 6 have been changed because of building modifications.” This requirement was originally written mainly to address older buildings that have now-antiquated window cleaning anchors (see picture). Today, however, this section also applies to any major modifications to the roofs and/or curtain walls that affect the existing window cleaning system. Most older buildings, for example, have replaced their original double-hung windows with fixed windows to provide more efficient air conditioning. That kind of modification would require an OPOS.
“A building has extreme architectural features, which require the use of complex rigging or equipment, or a building that uses rigging or equipment not covered by these Orders.” Think of the Disney Concert Hall, the Wilshire Grand Center, or the Wilshire Figueroa Tower. These building require complex riggings that are out of the norm.

Two other conditions that trigger the requirement of an OPOS

If your building’s window cleaners use a counter-weighted (I-beam) system. This equipment is commonly used by all types of construction type of trades e.g. Painters, glaziers, waterproofers. Etc.. but they are illegal to be used by window cleaners.
A Controlled Descent Apparatus (CDA) otherwise know as bosun or boatswain chairs.

What should I do if I have an OPOS?

To insure and increase the effectiveness of an OPOS, I would recommend:

Send a copy of the OPOS to the window cleaning company so they fully understand what it contains.
We also suggest that the window cleaning company provide each laborer a copy.
The OPOS should be posted on the roof level next to the roof access door. This placement makes it easy for a window cleaner to see as they exit to the roof.

To Consider

To increase compliance of In California, the building owner, not the vendors is legally responsible for providing a safe workplace for outside contractors.