The short answer
Under OSHA 1910.27(b)(1), the building owner is responsible for having each rope descent anchorage identified, tested, certified and maintained, and for confirming it in writing. The contractor must not use an anchorage without that confirmation. The property manager usually runs the program for the owner. A qualified person does the technical work.
Who carries what
| Party | Responsibility | Source |
|---|---|---|
| Building owner | Identify, test, certify and maintain each anchorage; confirm it in writing before rope descent work | OSHA 1910.27(b)(1)(i) |
| Contractor | Obtain the owner's written confirmation before use; keep it for the job; follow the rope descent rules | OSHA 1910.27(b)(1)(ii) and (b)(2) |
| Property manager | Usually schedules inspections, keeps records and hands them to contractors | Management agreement |
| Qualified person | Inspects, tests and certifies the anchorages | OSHA 1910.27(b)(1)(i) |
Delegating the work is not delegating the duty
An owner can hire a manager to run the program and a qualified firm to inspect and certify. The rule still names the owner as the party who confirms it in writing. Make sure the management agreement says who schedules, who pays and who keeps the records.
State law can reach further
Some states add their own rules. New York is one example: its Labor Law section 202 requires the owner, lessee, agent and manager of a public building, and every contractor involved, to provide safe means for cleaning windows and exterior surfaces. Check the rules in each state where you own buildings.
See what building owners are liable for when a contractor falls.
Making the split work
- Put anchor responsibilities in the management agreement
- Keep one anchor register per building, owned by the manager, visible to the owner
- Require contractors to request the written confirmation, and refuse work from any who do not
- Use a qualified firm that provides anchor-by-anchor documentation
Through its long-time anchor partner, S&K installs engineered anchor points and inspects, load tests and certifies existing systems, with records you can hand to ownership, insurers or auditors. See anchor installation and inspection.
Not sure where your building stands? Start with a free roof compliance survey, or read the full Roof Anchor and Fall Protection Compliance guide.
