Most building owners we talk to believe they are in compliance because they have anchors on their roof. Some of them are right. A lot of them are not. The gap between having anchors and being legally compliant under OSHA 1910.27 is wider than most people realize, and the consequences of that gap sit squarely with the building owner.
This guide is written specifically for building owners, facilities directors, property managers, and the risk and compliance professionals who support them. It covers what the law actually requires, what documentation you need to have, and what a real compliance program looks like in practice.
01.
What OSHA 1910.27 Actually Requires of Building Owners
The standard that governs rope descent system anchorage in general industry is 29 CFR 1910.27. It was significantly revised in 2016, took effect in January 2017, and required full compliance by November 20, 2017.
The core obligation on building owners is stated plainly in 1910.27(b)(1)(i): before any rope descent system is used, the building owner must inform the employer in writing that the building owner has identified, tested, certified, and maintained each anchorage so it is capable of supporting at least 5,000 pounds in any direction for each attached employee.
Three things about that sentence are worth pausing on.
First: it is the building owner’s obligation, not the employer’s and not the contractor’s. The employer using RDS on your building has their own obligations, but they cannot discharge yours.
Second: it requires written notice. Not a handshake, not a verbal confirmation from your maintenance team. A written document, kept on file.
Third: that written notice must be grounded in actual inspections and certifications. The standard requires the information be based on an annual inspection by a qualified person and certification of each anchorage, as necessary, and at least every 10 years.
KEY POINT
The employer side of this equation is equally clear: under 1910.27(b)(1)(ii), no employee may use any anchorage before the employer has obtained that written information from you. If your documentation is not current, rope descent work on your building should not be happening at all.
02.
The Three Standards That Work Together
1910.27 does not operate alone. Two other standards intersect with it for most commercial buildings.
1910.27
Rope Descent Systems
Primary standard. Requires building owners to identify all anchors, certify 5,000 lb capacity per worker, inspect annually, and provide written assurance to employers before any RDS use.
1910.66
Powered Platforms
Governs swing stages and suspended scaffolds. Its assurance provisions reinforce building owner documentation obligations and add engineering requirements for roof rigging infrastructure.
1910.140
Personal Fall Protection
Covers harnesses and lanyards used with RDS. Requires anchorages to support 5,000 lbs per employee, or a designed system under a qualified person with a safety factor of at least two.
For most multi-story commercial properties in a dense urban market like Philadelphia, all three standards apply simultaneously. A compliance program that addresses only 1910.27 and ignores 1910.66 is not a complete program.
03.
What Written Assurance Actually Means
Written assurance is not a form you fill out once and file away. It is a living document that must reflect the current state of your anchor systems, grounded in current inspection and certification records.
What the Written Assurance Must Cover
- Each anchorage has been identified
- Each anchorage is capable of supporting at least 5,000 pounds per attached employee in any direction
- Each anchorage has been inspected by a qualified person
- Each anchorage is in safe working condition
- Each anchorage has been certified and maintained as required, and at least every 10 years
What It Must Be Based On
- A current annual inspection by a qualified person
- A current certification, no more than 10 years old, or more recent if conditions require it
When OSHA compliance officers inspect a building following an RDS-related incident, the enforcement guidance memo indicates they review owner records of anchor identification, annual inspection documentation, certification records, and the written notice provided to employers. The absence of any one of these creates citation exposure.
LIABILITY NOTE
When litigation follows an anchor-related incident, these same records are subpoenaed. Buildings without documentation are in the worst possible position, and “we didn’t know” is not a defense under a standard that has been in effect since 2017.
04.
Annual Inspections, Load Testing, and the 10-Year Clock
Compliance is not a one-time event. It is a program with a defined schedule.
Annual Inspections
Annual inspections must be performed by a qualified person, someone with a recognized degree, certificate, or extensive knowledge and experience to identify substrate failure, corrosion, weld integrity issues, and load path concerns. A visual walk-across by your maintenance staff does not meet this standard.
- Physical condition of the anchor: corrosion, cracking, deformation, mechanical damage
- Condition of the attachment point and surrounding substrate
- Integrity of through-bolts, welds, or chemical anchor bonds
- Evidence of movement, settling, or loosening
- Compatibility with current use conditions
Load Testing
Load testing provides objective confirmation that an anchor can perform under real forces. OSHA does not prescribe a single test method. A 2019 OSHA interpretation letter confirms that a qualified person may use any scientifically valid test criteria. The qualified person determines the appropriate test, not a generic standard.
The 10-Year Recertification
The 10-year recertification is a formal engineering review, not an inspection. A qualified engineer must evaluate the anchor system and certify it. This is required at least every 10 years, and sooner when:
- A structural modification may have affected the anchor or its substrate
- Roofing work disturbs the attachment point or surrounding material
- An annual inspection reveals conditions requiring engineering assessment
- A known impact, overload, or damage event has occurred
Buildings with anchors installed in 2013 or 2015 that have never been formally recertified are carrying a compliance gap right now.
05.
What a Real Compliance Program Looks Like
A compliance program is not a binder on a shelf. It is a functioning system with a clear schedule, defined records, and someone accountable for keeping it current.
- Anchor inventory and baseline documentation. Every anchor on the building catalogued: location, type, installation date where known, original design basis, and current condition.
- Engineering review. Every anchor system should have an engineer of record. If your anchors were installed without engineering documentation, that documentation needs to be established before written assurance can be issued.
- Annual inspection on a tracked schedule. Inspections calendared, performed on time by a qualified person, documented in a format that can be produced quickly when requested.
- Load testing records. Documentation showing anchor identifier, test date, load applied, duration, equipment used, and result, directly supporting the written assurance letter.
- Written assurance package. A current document referencing current inspection and certification records, accessible to your facilities team when a contractor calls before a job.
- Recertification tracking. Any anchor approaching its 10-year mark, taken out of service for repair, or affected by roofing work flagged before the deadline passes.
At Premier Building Anchors, this is the program John and Anthony have built and maintained for building owners across Philadelphia. Engineering is handled by licensed structural engineers engaged for every project. The field knowledge that informs every assessment comes from two partners who have spent their careers working on and alongside these systems. When a window washing company asks for your written assurance, you have a current document ready.
06.
Common Mistakes We See on Real Buildings
These are not hypothetical. We encounter all of them regularly.
Assuming the contractor is responsible
The window washing contractor is responsible for their workers’ fall protection. The building owner is responsible for the anchorage those workers connect to. Both obligations exist simultaneously.
Anchors with no engineering documentation
If there is no engineering record behind your anchors, you have no foundation for written assurance. A physical anchor on a roof is not a certified anchor.
Skipping annual inspections
Buildings that only check anchors when something looks wrong are outside compliance. Annual inspections are required, and the absence of records is what OSHA looks for first.
Treating installation as a roofing task
An anchor installed in a reroofing scope without an engineering review is not certifiable without that review being completed retroactively.
Letting the 10-year clock expire
Anchors from 2013 or 2015 that have never had a formal engineering recertification are out of compliance right now. This is the most common gap we find.
Using an outdated written assurance
The letter must be based on current inspections. A document dated three years ago does not satisfy the standard today.
Conclusion
Rope descent system anchorage compliance sits at the intersection of three things building owners cannot afford to get wrong: worker safety, legal liability, and operational continuity.
When a window washer arrives at your building and asks for your written assurance, that is not a bureaucratic formality. It is the moment where years of documentation either exist or do not. If they do not, work should not proceed. If it proceeds anyway and something goes wrong, the paper trail runs directly to you.
The good news is that a real compliance program is not complicated to maintain once it is established. The hard part is building it from scratch on a building that has been out of compliance for years without anyone noticing. If you are not confident in your current anchor documentation, the right move is a baseline assessment before the next contractor call.
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Written Assurance Compliance ChecklistA one-page checklist covering everything your written assurance documentation must include under OSHA 1910.27, formatted for property managers and facilities teams.
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Frequently Asked Questions
What does OSHA 1910.27 require of building owners specifically?
Under 29 CFR 1910.27(b)(1)(i), building owners must provide written confirmation to employers before any rope descent system is used, stating that each anchorage has been identified, tested, certified, and maintained to support at least 5,000 pounds per attached employee. This must be based on a current annual inspection and certification by a qualified person.
How often do roof anchors need to be inspected under OSHA?
OSHA 1910.27 requires annual inspections by a qualified person. Inspections must also be triggered by any event that could have affected the anchor, including significant roofing work, storm damage, structural modifications, or known impact. Annual inspection records are the foundation of written assurance.
What is the OSHA 10-year anchor recertification requirement?
29 CFR 1910.27(b)(1)(i) requires certification of each anchorage by a qualified person, as necessary, and at least every 10 years. This is a formal engineering review, not a visual inspection. It is also required sooner if structural changes, reroofing work, or damage events have affected the anchor.
Can a roofing contractor install compliant RDS anchors?
A roofing contractor can physically install anchors, but compliance requires engineering review, documented design basis, load testing, and certification by a qualified person. Anchors installed during a reroofing scope without this documentation are not certifiably compliant and cannot support a written assurance letter without a retroactive engineering review.
What happens if a building owner cannot produce written assurance documentation?
Under 1910.27(b)(1)(ii), employers are not permitted to allow employees to use RDS anchorages before obtaining written confirmation from the building owner. If that documentation does not exist, work should not proceed. In the event of an incident, the absence of documentation creates direct compliance and liability exposure for the building owner.
Not sure where your building stands?
Premier Building Anchors provides engineering, load testing, annual inspections, and 10-year recertifications for commercial building owners across Philadelphia. We respond within 24 hours and provide clear documentation at every step.
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References and Regulatory Compliance
- 29 CFR 1910.27 — Rope Descent Systems. Final rule published November 18, 2016 (81 FR 82494). Effective January 17, 2017. Full compliance required by November 20, 2017. https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.27
- 29 CFR 1910.27(b)(1)(i) — Building owner obligation to provide written assurance prior to any rope descent system use, confirming each anchorage has been identified, tested, certified, and maintained to support at least 5,000 pounds per attached employee.
- 29 CFR 1910.27(b)(1)(ii) — Employer obligation to obtain written confirmation from building owner before permitting employees to use rope descent system anchorages.
- 29 CFR 1910.66 — Powered Platforms for Building Maintenance. https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.66
- 29 CFR 1910.140(c)(13) — Personal Fall Protection Systems. Anchorage strength requirements: 5,000 pounds per employee, or a designed system meeting a safety factor of at least two, certified by a qualified person. https://www.ecfr.gov/current/title-29/subtitle-B/chapter-XVII/part-1910/subpart-I/section-1910.140
- OSHA Standard Interpretation, January 25, 2019 — Load testing criteria for rope descent system anchorages under 1910.27. Confirms that a qualified person may apply any scientifically valid test criteria. https://www.osha.gov/laws-regs/standardinterpretations/2019-01-25
- OSHA Compliance Directive CPL 03-00-022 — Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems) Standards for General Industry. Issued November 20, 2017. Governs enforcement of 1910.27 including owner documentation requirements. https://www.osha.gov/enforcement/directives/cpl-03-00-022
- “Qualified person” as defined in 29 CFR 1910.140(b): a person who, by possession of a recognized degree, certificate, or professional standing, or by extensive knowledge, training, and experience, has successfully demonstrated the ability to solve or resolve problems relating to the subject matter, the work, or the project.
Related guides
- Anchor Load Testing Methods Explained
- Annual Roof Anchor Inspections vs Load Testing: A Decision Guide for Building Owners
- The 10-Year Recertification Clock: How to Build an Anchor Asset Register
Need help meeting OSHA 1910.27 in Philadelphia?
Premier Building Anchors installs, inspects, load-tests, and recertifies fall-protection anchors across Philadelphia. Call (267) 214-4606 or OSHA 1910.27 compliance in Philadelphia for immediate quoting.
