An EBM (exterior building maintenance) design is the plan for how workers safely reach the outside of your building, including where every tie-back goes. An OPOS (Operating Procedures Outline Sheet) is the written procedure that Title 8 §3282 requires for many buildings 36 feet or more in height, and window washing companies are required to follow one. You don’t need either one for the building permit. You need both before the first scheduled window wash.
You’ll also see it spelled OPUS, including on some Hardy pages. The code calls it an OPOS.
What is an EBM design?
An EBM design, also called a facade access design, covers everything a maintenance crew needs to work on the outside of the building safely. Through Hardy’s partnership with EBM Focus, a complete EBM design package includes:
- EBM design documents
- Specification documents
- Calculations
- Detail sheets
- The Operating Procedures Outline Sheet (OPOS), as required by current codes
The tie-back layout is the part architects and engineers feel first, because it touches the roof framing. Title 8 §3291(f)(2) puts the tie-backs at approximately 12-foot intervals, on framing members strong enough to carry the applied loads. The EBM design decides where each one lands.
What is an OPOS?
The OPOS is the operating sheet that tells the employer how to do the work on that specific building. §3282(p)(1)(C) says owners of buildings 36 feet or more in height shall have an OPOS where one or more of these conditions apply:
- The building doesn’t have an established window cleaning system or procedures meeting the requirements of Articles 5 and 6.
- The building’s original window cleaning procedures changed because of building modifications.
- The building has extreme architectural features that require complex rigging or equipment, or it uses rigging or equipment the Orders don’t cover.
Hardy’s code FAQ adds two more cases: when a boatswain’s chair or controlled descent apparatus is permitted for window cleaning under §3286(a)(1), and when counterweighted outrigger beams are permitted under §3291(d)(2).
The code also sets the standard for the document itself. It has to be written so employers can readily understand it, and at a minimum it has to contain the elements of Appendix A of Article 5.
Who has to have an OPOS and EBM design?
It depends on one question: are the windows going to be washed?
If yes, that’s scheduled maintenance. Window washing companies are required to follow an OPOS, the OPOS requires an EBM design, and window washing companies can be fined if no OPOS is provided.
The owner carries the paperwork. Under §3282(p)(1)(A), building owners must give the employer written assurance, before use, that the building’s safety devices and equipment meet the Orders. Under §3282(p)(2), employers can’t let their employees use any building safety devices or equipment until they’ve received the written assurance and, if required, the OPOS from the building owner.
If no, you don’t need to plan for scheduled maintenance. Tie-backs are still required at approximately 12 feet on center. Nothing requires a SIT company to lay out the tie-backs in that case, though some project specifications do.
Unscheduled maintenance is the trap. Painting and repair crews will need an OPOS when they show up. You can get that OPOS later, but if the tie-backs went in without an EBM design, the fall protection system may have to be altered to fit it. That could mean significant added cost.
| Situation | EBM design and OPOS | Tie-backs |
|---|---|---|
| Windows will be washed (scheduled maintenance) | Required before the first wash | Required |
| No window washing planned | Not needed now | Still required at about 12 ft o.c. |
| Painting or repairs later (unscheduled) | Painters and repair contractors will need an OPOS | Layout may need changes if done without an EBM design |
Who designs the EBM system and writes the OPOS?
An EBM system plan must be designed by a Scaffold, Inspection and Testing (SIT) company.
The code language: §3282(p)(1)(C)2 says the OPOS shall be developed by a person or persons with knowledge in the design, installation and use of building maintenance equipment, meaning someone possessing Scaffold Inspection Testing certification as specified in §3296.
If the OPOS calls for structural modifications to the building or its existing maintenance equipment, a mechanical, structural or civil engineer registered in California, with experience designing and installing that equipment, has to design those modifications.
That splits the work cleanly on a new building. Your structural engineer designs the framing that carries the tie-backs, and the SIT company designs how crews use them.
When do you need the EBM design, at permit or before maintenance?
An EBM design and OPOS are not required to obtain the building permit. They’re required before scheduled maintenance.
Legally, that gives you until the first window wash. The cheaper move is to do the EBM design while the roof framing is still on paper. On a typical project the order runs like this:
- Design. Tie-backs go on the roof plan. A California-registered civil or mechanical engineer prepares calculations and/or plans for the complete installation (§3291(a)). Start the EBM design here.
- Framing. The framer installs the tie-backs, ideally on the beams or trusses before they’re raised.
- Before initial service. The installation is inspected and load tested in the field (§3296(a)).
- Before the first window wash. The owner hands the employer the written assurance and the OPOS (§3282(p)(1)(A) and (p)(2)).
- Every 12 months. Safety devices and equipment are inspected, and tested where necessary (§3282(p)(1)(B) and §3296(b)(1)).
Compare the two timelines. If the SIT company sees the roof for the first time after it’s finished, every tie-back it wants moved or added is a change on a completed roof. If it sees the framing plan, every change is a revision on a drawing.
OPOS and EBM design checklist for owners
- Is the building 36 feet or more in height? If yes, check the three OPOS conditions in §3282(p)(1)(C).
- Will the windows be washed? If yes, plan for scheduled maintenance.
- Hire a SIT company for the EBM design while the roof framing is still in design.
- Confirm the tie-back layout in the EBM design matches the structural drawings.
- Load test the tie-backs before initial service and keep the certification record.
- Have the written assurance and the OPOS ready to hand to the window washing company before its first visit.
- If you skip the EBM design now, budget for possible changes when a painter or repair contractor needs an OPOS.
How Hardy helps
Hardy provides complete EBM design through its partnership with EBM Focus: design documents, specifications, calculations, detail sheets and the OPOS, built to meet Cal/OSHA and OSHA requirements. Hardy also offers complimentary EBM design assistance for architects, owners and structural engineers, covering anchor design and application, best system analysis and a facade access plan.
Want one contract for the whole system? Hardy’s design build service covers specification, EBM design and installation. Its installation partner, Access Systems & Solutions, has over 40 years of experience and can deliver a turn-key system from design and engineering through fabrication, installation, load test and the OPOS. See installation.
For the tie-backs themselves, the Hardy Saddle Tie Back Anchor installs on a single beam, double truss or joist. Check your building’s requirements with the tie-back calculator, read Cal/OSHA roof tie-back requirements, or contact Hardy with your drawings.