1. Anchor Systems and Safe Access Points
For buildings with an exterior height greater than 36 feet, Cal/OSHA mandates the installation of permanent anchor points that workers can safely tie off to when performing exterior maintenance work. These anchor points must meet the following criteria:
- Anchor Load Capacity: The anchor must be capable of supporting at least 5,000 pounds (or the anticipated load, whichever is greater).
- Spacing of Anchors: Anchors should be spaced appropriately, generally about 12 feet apart, depending on the building layout and intended use.
- Roof Access: Safe, unobstructed access to the roof is essential. Facilities must ensure there is an accessible pathway that does not expose workers to fall hazards.
2. Building Maintenance Units (BMUs) & Suspended Access Systems
For taller buildings or those with complex facades, Building Maintenance Units (BMUs)—permanently mounted mechanical systems for suspended access—may be required. BMUs include equipment like suspended platforms or cradles that provide a stable platform for workers to perform tasks at height.
These systems must:
- Be inspected annually to ensure their integrity.
- Include backup systems for emergency situations, such as power loss or malfunction.
- Be designed to carry both workers and tools/materials necessary for the job.
For buildings where BMUs are not feasible, suspended access systems (such as cradles or scaffolding) are acceptable but must be used according to Cal/OSHA’s guidelines.
3. Personal Fall Protection Equipment
T8 CCR 3212(d)(1) Guardrails as specified in section 3209 shall be required at locations where there is a routine need for any employee to approach within 6 feet of the edge of the roof. When intermittent work is being done safety belts and lanyards, or an approved fall protection system may be provided in lieu of guardrails.
For the purpose of this requirement, routine need means more than four times a year and intermittent work means work not exceeding four times a year.
Therefore in CA, workers accessing high-rise exteriors must be protected by means of a 42″ parapet or Guardrail System.
Guardrails must meet the following specifications:
- A top rail height of 42 inches, plus or minus 3 inches.
- The ability to withstand 200 pounds of force without failure.
4. Fall Protection Plans for Infrequent Work
What is Infrequent Work? When an approach to a fall hazard area is not exceeding four times a year!
Let’s think about this… If I have roof drains within 6′ of my roof’s eaves how many times will a worker walk back and forth from these roof drains? If it is more than 4 times at any one location then the work is classified as routine.
In situations where conventional fall protection systems (like guardrails or scaffolding) are impractical, employers are still required to develop a fall protection plan. This plan must be reviewed and signed off by a qualified safety professional and should include:
- Controlled access zones where fall hazards are clearly marked.
- Safety monitors who are tasked with ensuring workers do not approach fall hazards.
- Emergency rescue procedures to ensure rapid response in case of a fall.
For infrequent work, Workers accessing high-rise exteriors may use an approved fall protection system may be provided in lieu of guardrails if no adequate parapet is present, when working at heights of 6 feet or more. These systems include full-body harnesses, lanyards, shock-absorbing devices, and self-retracting lifelines.
5. Inspection and Certification Requirements
Buildings with permanent facade access systems or BMUs must be inspected annually by a qualified professional. If a system is found to be defective or inadequate, it must be promptly repaired or replaced to meet safety standards. The inspection report must be available for review by Cal/OSHA and other regulatory bodies.
In addition, personal fall protection equipment must be inspected before each use. Any worn or damaged equipment must be immediately removed from service and replaced.
Important Changes for 2025
As of 2025, Cal/OSHA has introduced several updates to the existing guidelines governing exterior building maintenance in General Industry:
- Expanded Fall Protection Coverage
Previously, the trigger height for fall protection was 15 feet for some general industry tasks. In 2025, this has been lowered to 6 feet for all maintenance work performed at height. This means that more maintenance tasks now require fall protection, even for lower buildings. - New Requirements for Suspension Platforms
Cal/OSHA has updated its regulations to clarify the requirements for suspended access platforms (such as cradles and BMUs). These systems now require stricter load capacity and maintenance protocols, including backup power systems and emergency stop functions. - More Specific Safety Monitoring Requirements
The new regulations also specify more detailed protocols for safety monitoring during exterior maintenance. Employers must now provide more thorough training for safety monitors, particularly in situations where controlled access zones are established. - Stricter Certification for Window-Cleaning Systems
Buildings that rely on window-cleaning equipment must provide annual certification of all BMUs and suspended access systems. This certification must confirm that the equipment complies with all safety standards, including load capacity and emergency protocols.
Common Violations to Avoid
Failure to comply with Cal/OSHA’s EBM regulations can result in severe consequences, including fines, citations, and shutdown orders. Common violations include:
- Failure to install anchor systems or properly certify existing ones.
- Inadequate fall protection for workers when working at heights of 6 feet or more.
- Non-compliance with BMU maintenance and inspection protocols.
- Lack of proper training for workers on how to use fall protection systems and inspect their equipment.
Conclusion
Ensuring the safety of employees working on the exterior of buildings in California is critical not only for compliance with Cal/OSHA regulations but also for the well-being of the workforce. In 2025, these requirements have become more stringent, with a greater emphasis on fall protection, anchor systems, and regular equipment inspections.
For employers, this means it’s time to review your existing systems, ensure your building maintenance protocols are up to date, and invest in comprehensive training for your teams. A proactive approach will help mitigate risks, avoid fines, and keep your workforce safe.
By staying ahead of these regulations and working with experts to design safe, compliant systems, you can create a safer environment for those performing essential exterior maintenance tasks.
If you have any questions about how to bring your exterior building maintenance practices up to 2025 standards, feel free to reach out to Tieback Safety, Inc by calling (888) 671-5711 or email Paul directly at pbetts@tiebacksafety.com.