The Rule in Plain Language
OSHA 29 CFR 1910.27(b)(1), the Rope Descent System (RDS) standard, became enforceable in 2017. It places the certification burden directly on the building owner, not the contractor. The owner must provide written certification that each anchor on the building can hold at least 5,000 pounds in any direction, and the certification must be based on:
- Annual inspection by a qualified person
- Recertification at least every 10 years
- Engineering analysis after any structural change, repair, or known impact
The rule applies any time a worker on your building uses suspended access for window cleaning, facade work, inspection, painting, or any other service. If a contractor connects a rope descent line to an anchor on your roof, the certification requirement is in force.
Free download: Roof Anchor Compliance Guide (PDF), covering the federal rule, inspection cadence, and what to ask any contractor working on your roof.
The 10-Year Deadline Is Hitting Now
Buildings with anchor systems installed in 2014, 2015, and 2016 are now reaching the 10-year recertification cutoff. For most owners this is the first time the recert clock has fully expired since the rule took effect, and many compliance programs that were set up during the original install have lapsed in the intervening decade. If you have not had a licensed structural engineer review your anchors since installation, you are past due.
The recertification is not a re-inspection. It is a fresh engineering review that confirms each anchor, its substrate connection, and its load path still meet the 5,000-pound capacity requirement after a decade of weather, building movement, and wear.
What WA L&I Enforcement Looks Like in 2025
Washington Labor and Industries (L&I) issued more than $1.4 million in fall protection fines in the fourth quarter of 2025 alone. Most of the published citations have been written against contractors rather than building owners. Valentine Roofing was fined $148,716 on December 3, 2025. Asset Roofing was fined more than $720,000 earlier in the year.
Owners are not the typical target of these citations, but the exposure flows back to the property in two ways. First, if your own maintenance staff performs work on the roof, you are the employer for the purposes of the fall protection rule and the citation lands directly on you. Second, in the event of an incident, the absence of owner-provided certification becomes a central question in any civil claim, regardless of whether L&I issued a citation.
Scheduling Disruption Is the Operational Risk Most Owners Overlook
Even in a market where most window cleaning contractors will perform the work without asking for owner certification, the situation is shifting. National facade and access contractors are tightening their pre-job paperwork in response to insurance pressure. Once an incident has occurred on a building or a sister property in the same portfolio, contractors get cautious quickly. Larger companies with dedicated safety staff are already requiring written owner certification before they send technicians to the roof.
For a property manager, the cost is not the citation. It is the Tuesday morning when a window cleaning crew arrives, asks for the anchor certification, and leaves when nobody can produce it. The job that was on the schedule for six weeks gets pushed by another four. The tenants who were told the windows would be done complain. The cleaning contract gets renegotiated, or the contractor walks. None of that shows up in an OSHA penalty table, but it is the part that wakes you up.
The simple fix is to have current certification in hand before any contractor is scheduled. That way the conversation is never about whether the work can happen.
Civil and Insurance Liability Beyond the Citation
The OSHA serious-citation penalty is capped at $16,550 per violation. In practice the more consequential exposure for owners is civil. An injury from an anchor failure or unverified anchor produces a claim that dwarfs any citation, and the discovery process will surface the certification record as one of the first documents requested.
Insurance carriers are also moving on this. RDS documentation is now appearing in commercial property renewal questionnaires. Carriers that previously took owners at their word are increasingly asking for the actual certification on file, and absence of documentation is being treated as a coverage condition for fall-related claims.
What a Compliance Review Actually Involves
A full anchor compliance review for a typical commercial building includes:
- Visual and structural inspection of every anchor on the roof, by a qualified person
- Load path verification from anchor through substrate
- Documentation review of the original install records, prior inspections, and any structural changes
- Engineering analysis and signed certification letter from a licensed structural engineer
- Anchor schedule and roof plan deliverable that you keep on file and provide to any contractor on request
The deliverable is the certification packet, which you store with your other building documentation and produce when a contractor asks for it. ADS provides this service across the Pacific Northwest, including Seattle, Bellevue, Tacoma, and the greater King County market.
Next Step
If your building had anchors installed in 2014, 2015, or 2016, request a compliance review now rather than waiting for the next service contractor to ask. The review is faster and cheaper to schedule on your timeline than under contractor pressure.
Contact us for a free evaluation, or call our Seattle office at (206) 338-2584. ADS Contractors, LLC has been certifying roof anchor systems for commercial property owners in the Pacific Northwest since 2008. We work with a licensed structural engineer on every certification.
Is Your Building Due for Recertification?
If your anchors were installed in 2014, 2015, or 2016, the 10-year deadline is here. Get a free compliance review before your next contractor asks for paperwork.
Request a Free Review