Fall_Protection_Assessment_0116304-CVG_Centre.pdf

TIE OFF INSPECTIONS AND EVALUATION:

CVG CENTRE ROOF ANCHORAGES

CVG AIRPORT

PO Box 75200 Cincinnati, OH 45275-2000

October 2019

PREPARED FOR:

LJB Inc.

2500 Newmark Drive Miamisburg, OH 45342

(937) 259-5000

Tracey Riepenhoff, P.E., C.S.P., P.M.P Project Manager TRiepenhoff@LJBinc.com

PREPARED BY:

TIE OFF INSPECTIONS AND EVALUATION: CVG CENTRE ● CVG AIRPORT

TABLE OF CONTENTS

TABLE OF CONTENTS

EVALUATION SUMMARY

EVALUATION DETAILS

APPENDIX

EVALUATION SUMMARY 2

EVALUATION SUMMARY

SYSTEM AND ANCHORAGE DESCRIPTION

The roof anchorage system is used for suspension (main line) and fall protection (safety line) while performing window cleaning maintenance. The system consists of multiple individual anchorages spaced along the lower roof in a T-shape. The individual anchorages are used in conjunction with vertical lifelines and a bosun chair for this work.

QUALIFIED PERSON EVALUATION RESULTS

Based on LJB’s Qualified Person inspection and evaluation, this system cannot be certified for the following reasons:

> The current system does not address all fall hazards

> Inadequate strength of the structural support

> Undetermined anchorage connection strength

> There is missing documentation for the system

RECOMMENDATIONS

Based on LJB’s Qualified Person inspection and evaluation, we have the following recommendations for this system:

> Remove the current system from service

> Evaluate the best method to improve the structural support so that it can withstand the applied loads. This may be accomplished with additional bracing and or reinforcement.

> Determine connection of the existing anchorages to the support structure have adequate strength. This may be able to be achieved through subsurface exploration of the building structure.

> Design and install additional anchorages to provide full façade access

> Develop and record the missing documentation that is required for proper system certification

> Upon new design and proper installation:

• Provide use and rescue procedures to ensure system is used as designed with correct equipment and a plan for prompt rescue is provided in the event of a fall

• Conduct system-specific training for all personnel that are authorized to use the system and equipment

• Maintain system documentation through annual inspections and re-certification on a 5-year basis

> Address other items of concern noted in this report to improve safety for those accessing the roof of the CVG Centre

EVALUATION DETAILS 3

EVALUATION DETAILS

PROJECT BACKGROUND

CVG Airport asked LJB to inspect and evaluate the fall protection and window washing system used at CVG Centre. The inspection was performed by two OSHA Qualified Persons from LJB and occurred on August 20th and 21st, 2019.

For reference purposes, OSHA 1910.140(b) defines a Qualified Person as:

“A person with a recognized degree, certificate or professional standing, or through extensive knowledge, training and experience has demonstrated the ability to solve problems relating to the subject matter, work or the project.”

An inspection log documenting the condition is included in the appendix of this report for each system component. The inspection of the system included:

> Thorough visual inspection of the anchorages that make up the window cleaning and fall protection system

> Documentation of observations on an inspection log attached to this report

> The fall protection and suspension equipment used to attach to the anchorages was not on-site during LJB’s field work and was not inspected. Compatibility of connectors, attachment to the system and allowable equipment use should be verified to ensure the system is being properly used.

To assist with evaluation, CVG Airport provided LJB with a set of record drawings of the building, which included architectural and structural drawings for the area. These drawings were used by LJB for evaluating the system and structural support. As part of the Qualified Person evaluation, our team performed:

> An overall system assessment to determine if the system addresses all fall hazards related to work tasks

• This includes information obtained through interviewing maintenance workers and the contractors completing window washing

> Evaluation of the overall system design including items such as fall clearance required, specification of proper equipment and compliant means of access to the system

• This includes reviewing critical elements such as design drawings, use and rescue procedures, equipment user manuals and system specific training documents

> Analysis of structural support for the system to determine if the framing member has adequate strength

• To complete the analysis, LJB used methods in accordance with standard engineering practices, ANSI Z359.6 standards, and OSHA 29 CFR 1910 regulations.

EVALUATION DETAILS 4

FIELD OBSERVATIONS

The anchorages on the 5th floor (lower) roof of CVG Centre appeared to be in good condition. The U-bars did not display any signs of deficiencies, but the stanchions appeared to have light rust. The stanchion connections to the structural supports and the support beams were covered in spray-on fireproofing, therefore the steel surfaces could not be visually observed.

Photograph 6: Roof Anchorages on Lower Roof

Photograph 7: Anchorages with Rust on Stanchions Photograph 8: Anchorage Support Beam with Fireproofing

EVALUATION DETAILS 5

QUALIFIED PERSON EVALUATION

The 5th floor (lower) roof is approximately 58’-0” above the ground level and has a series of 15 individual roof anchorages arranged in a T-shape. There are 8 anchorages spaced along the western edge of the roof and 7 spaced down the center. Access to the system is through a roof hatch and fixed ladder on the east end near the center of the roof. While on-site LJB learned that the windows on the west side of the main building are currently cleaned with an articulating boom lift, not using the anchorages.

System Assessment To complete window washing for exterior windows, the contractor indicated that two anchorages are used for each drop. One anchorage is used to attach the safety line rope for the fall protection system (vertical lifeline) and the other for the main line rope for the bosun chair. The ropes are tied to carabiners with figure-8 knots then connected to the anchorages. If a drop needs to occur at an area outside of the thirty-degree cone of an anchorage, the main and safety lines are tied together with a butterfly knot and placed directly between two anchorages. This allows the two lines to drop straight over the edge. The findings from the system assessment are:

> The current system DOES NOT provide safe access

• The anchorages along the western edge are located less than 15’ from the roof edge

> The current system DOES NOT address all fall hazards associated with the task

• Although the current system is appropriate for the task, there are not enough anchorages to properly complete the task. This is evidenced by the fact that the contractor is tying the lines together to drop in between anchorages

• Tying two lines together in order to try to maintain the thirty-degree cone of an anchorage is not an acceptable practice

> The anchorages along the west edge of the lower roof can be removed and taken out of service if the aerial lift is going to continue to be used and they are no longer needed for window washing

System Design The architectural drawings state in the notes that roof anchorages should be provided and either welded or mechanically fastened to the roof structure. The architectural drawings also indicate the number and location of anchorages shown on the roof plan. The structural drawings indicate that the roof beams along the center of the lower roof with anchorages attached to them are W18x40s.

Fall Protection and Window Washing System Design drawings indicating system type, design criteria, performance and use do not exist. This means some design considerations may not have been accounted for, such as: fall clearance required, number of users, specification of equipment and compliant means of access to the system. LJB’s evaluation is based on existing building architectural and structural drawings and data collected on-site. The findings of the system design are:

> Sufficient fall clearance is available for one user and a vertical lifeline as low as the 2nd floor windows

• Fall clearance required is 14’-6” and the available clearance is 14’-8”

> Analysis of the W18x40 beams down the center of the lower roof indicates that they are INADEQUATE and cannot support the design loads for fall protection and window washing in combination with the code prescribed loading

EVALUATION DETAILS 6

• Analysis of the roof beams along the western edge of the roof was not completed since these anchorages are no longer needed to complete the task

> The connection strength between to stanchions and support beams was UNABLE to be determined

• Subsurface exploration of the building must be completed to obtain additional details in order to complete analysis.

Missing Documentation LJB determined that the following critical aspects of fall protection system certification are missing and are gaps preventing certification:

> Fall Protection and Window Washing System Design drawings

> As-built drawings for the fall protection and window washing system

> Use procedures

> Rescue plan

> System-specific training

EVALUATION DETAILS 7

RECOMMENDATIONS

Based on LJB’s Qualified Person inspection and evaluation, this system cannot be certified. We have the following recommendations for this system:

> Remove current system from service

• Tag the system “DO NOT USE”

> Evaluate the best method to improve the structural support so that it can withstand the applied loads. This may be accomplished with additional bracing and or reinforcement.

> Determine connection of the existing anchorages to the support structure have adequate strength. This may be able to be achieved through subsurface exploration of the building structure.

> Design and install additional anchorages to provide full access to all windows

• Incorporate consideration for existing anchorages once it is verified they are acceptable

• Include proper specification of equipment and system parameters

> Develop and record the missing documentation that is required for proper system certification

> Upon new design and proper installation:

• Provide use and rescue procedures to ensure system is used as designed with correct equipment and a plan for prompt rescue is provided in the event of a fall

• Conduct system-specific training for all personnel that are authorized to use the system and equipment

• Maintain system documentation through annual inspections and re-certification on a 5-year basis

ITEMS OF CONCERN

During LJB’s on-site visit, several items of concern were identified in this area. These items are fall hazards or concerns that were easily identified while completing field work for the current project.

Consideration should be given to addressing these hazards in conjunction with redesign of the system to address this area.

> Ladder and hatch access to the lower roof

• Non-compliant ladder at access. It has insufficient toe clearance, climbing side clearance and does not have grab bars at hatch

• Non-compliant opening when hatch is left open on roof. There is no guardrail installed around the hatch (this hazard exists at all hatch access locations on all roof levels)

> Exposure to an unprotected edge while completing maintenance tasks for vents, exhaust fans and drains near the roof edge

Developing and implementing the items listed above will facilitate proper use of the equipment to abate a worker’s fall while working at CVG Airport, as well as allow for the system to be certified.

APPENDIX 8

APPENDIX

The following documents are provided in the appendix to support the information in the report.

> Beam Inspection Log

> Anchorage Inspection Log