OPOS (Operating Procedures Outline Sheet)
Under California Title 8 (GISO Section 3282), many buildings are required to maintain an Operating Procedures Outline Sheet (OPOS) for exterior window cleaning and related maintenance operations.
Failure to provide a compliant OPOS may expose building owners to significant liability, regulatory citations, and operational risk.
Highline develops compliant, defensible OPOS documents tailored to each building’s unique configuration and equipment.
What Is an OPOS?
An OPOS is a formal operating document that defines:
- Approved access methods
- Equipment limitations
- Safety protocols
- Hazard zones
- Emergency procedures
- Worker qualification requirements
The OPOS serves as both a regulatory compliance document and a training reference for contractors performing exterior building maintenance (EBM) operations.
Highline provides vendor orientation upon delivery to ensure proper implementation.
When Is an OPOS Required?
An OPOS is required when one or more of the following conditions exist:
- The building does not have an established, compliant window cleaning system
- Original procedures have been altered due to building modifications
- The building contains complex architectural features requiring specialized rigging
- Boatswain’s chairs or controlled descent systems are permitted
- Counterweighted outrigger beams are permitted
- Required training and operational documentation is not available onsite
Additionally, even when an OPOS is not explicitly triggered, Federal OSHA (29 CFR 1910.66) and ANSI/IWCA I-14.1 require a Plan of Service for buildings performing facade access work.
Does the Requirement Apply to Older Buildings?
Yes. The OPOS requirement applies to all buildings that meet triggering conditions – regardless of construction date.
Who Is Qualified to Prepare an OPOS?
Under California regulations, an OPOS must be prepared by a firm knowledgeable in the design, installation, and use of building maintenance equipment and holding a valid Scaffold Inspection Testing (SIT) certification.
Highline’s Principal holds California SIT License #40.
Unlike many states where contractors may prepare similar documents, California requires a qualified SIT firm. Utilizing an independent firm ensures the document is unbiased and aligned with the owner’s long-term interests.
Why Provide an OPOS?
- Establishes defensible compliance documentation
- Reduces owner liability exposure
- Standardizes safe work procedures
- Prevents unsafe improvisation by contractors
- Supports consistent and comparable competitive bidding
- May reduce exposure to citations and fines
In California, the building owner – not the window cleaning contractor – is ultimately responsible for providing a safe workplace for exterior maintenance operations.
A properly developed OPOS demonstrates a proactive commitment to compliance and risk management.
When Must an OPOS Be Updated?
A properly developed OPOS remains valid unless:
- The building is modified
- EBM equipment is altered or replaced
- Required inspection and testing protocols are not maintained
- A citation or stop-work order is issued
- Regulatory requirements change
Can an OPOS Be Issued to a Deficient Building?
No.
If a building cannot obtain certification of safe use due to deficiencies, an OPOS cannot be issued until corrective measures are completed.
In certain circumstances, an interim deviation plan may be developed to allow limited, temporary operations while permanent corrections are implemented.
Independent and Defensible
Highline does not manufacture, maintain, or repair equipment. Our role is strictly independent regulatory documentation and engineering analysis – ensuring objective, defensible compliance.
Contact Us
For assistance with OPOS development or interim deviation planning, please contact Highline Consulting.