Understanding California’s OPOS Requirements

Cal/OSHA has several key differences from federal OSHA when it comes to fall protection regulation. One of the most unique aspects of California-specific safety code is the requirement for employers to have an Operating Procedures Outline Sheet, or OPOS, in order for work or maintenance to be performed on a building’s rooftop or exterior. This sheet includes all the necessary information that workers or vendors accessing the worksite need to know in order to perform their work safely. Failure to comply with OPOS requirements can lead to hefty fines and legal liabilities for employers and building owners in California.

When is an OPOS Required, and Who is Responsible?

California states in their code of regulations, Title 8, Section 3282, that all buildings over 36 feet require an OPOS if any of the following apply:

• The building does not have an established window cleaning system or window cleaning procedures.
• The building’s procedures have been changed due to building modifications.
• The building has extreme architectural features, requiring the use of complex rigging or equipment.

Oftentimes buildings that require window cleaning or façade maintenance fall under this requirement. The owner of the building is responsible for ensuring that an OPOS exists and is current. If a building owner has any questions about whether or not an OPOS is required, or whether their current OPOS is out of date, California-approved SIT agencies like Diversified Fall Protection can help, and can provide an OPOS if needed.

What information does an OPOS need to contain?

According to Cal/OSHA Title 8, Appendix A of Article 5, an OPOS should contain the following information:

• Isometric or plan view drawing of the building’s roof, including the name of the building, the address, and the date that the OPOS was prepared.
• Identification of drop zones, recommended drop sequences, scaffold configurations, and specific building maintenance procedures, including the equipment to be used, such as davits, outrigger beams, bosun chair, etc.
• Identification of all anchorage points for personal fall arrest systems and building maintenance equipment.
• Identification of personal fall protection requirements and procedures for securing equipment.
• Identification of “Danger Zones” on the drawing.
• Description of the means and methods to be used to transfer equipment from drop location to drop location or between building levels.
• Identification of equipment limitations, load ratings, and special use conditions.
• Provisions for pre-operational, operation, and maintenance inspections.
• Identification of the access and egress to the work locations, and the storage areas for the permanent or transportable building maintenance equipment.
• Indication of the location and method of stabilization provided for the suspended equipment.
• Emergency and rescue procedures and means of communications to be used during such procedures.
• Methods to be used to control employee exposure to falls while they are in the “Danger Zone”

Properly using an OPOS

Once a building owner has an accurate, current OPOS, it needs to be shared with anyone who will be accessing the rooftop, whether it’s an employee or an outside vendor. It should be printed on large enough paper to be easily legible (usually 24” x 36”), then posted at the access/egress point for the roof. Outside vendors can be sent a PDF version of the OPOS to review before coming to perform their work.

It is important to remember that an OPOS is not the only documentation required for the roof to be accessed. The building owner also needs to provide each vendor accessing the roof with their own letter of written assurance, which is provided by an SIT agency like Diversified Fall Protection, assuring that the equipment is in good working order and the vendor has sufficient knowledge on how to safely use the equipment.

Taking The Next Step

If you’re ready to bring your worksite into compliance, the experts at Diversified Fall Protection can help. As the only full-service fall protection company in California with SIT designation, we can help with every aspect of your fall protection program, from OPOS creation to user training, system design, installation, and more. Contact us to get started.