What you need to know now about EBM

Jan 03, 2016

The trouble with exterior building maintenance requirements (EBM) is they’re not widely known. Buildings are not typically reviewed for compliance with state and federal safety codes, and enforcement is by complaint only.

We don’t acknowledge this to alarm real estate builders, owners and investors, but more to draw awareness to an issue that at some point could affect anyone working in the built environment. Knowing what to ask and who can assist you in getting up to code will help mitigate EBM-related risk now and down the line.

Marx|Okubo has been involved in numerous property transactions and construction monitoring projects where the issue of EBM code compliance came to the forefront. In the case of existing construction, knowing the requirements and the cost to meet those requirements has given our clients valuable information regarding potential purchase or sale of the asset. In difficult cases where structural modifications are required, the cost to provide a compliant EBM system for an existing structure can be several hundred thousand dollars.

In new construction, the difference between incorporating the requirements early on and later in the design process can be significant, both from the standpoint of time and cost. EBM systems must tie into the overall design and can impact many other building systems including structural, building envelope, mechanical, electrical, plumbing, etc.

Knowing the codes

By nature, state and federal EBM requirements are complex, with different regulations depending on the type of work being done, height of building, method of work, etc. Additionally, many requirements are not clearly spelled out, and there remain many gray areas and subjective interpretation by state officials. In some states, the code has additional EBM requirements, which adds to the complexity and cost.

In California, for example, California Code of Regulations - Title 8 requires the creation of an OPOS (Operating Procedure Outline Sheet) for most buildings. This document is a graphic and written depiction of the safe window cleaning and exterior maintenance procedures for a building or structure. The OPOS must be posted at the entrance to the work area in question.

As an architectural, construction and engineering consulting firm, our nationwide teams make recommendations based on knowledge of federal and state EBM requirements and pull in EBM experts, such as an experienced surveyor or scaffolding testing and inspection contractor, as needed for specific projects. In general, Marx|Okubo tries to help clients learn about EBM and follow these guidelines:

New construction:

• Bring on system designer early and provide requirements to the entire design team.
• Keep in mind requirements can affect multiple aspects of the design, including structural systems, railing heights, programming of space at occupied roof areas, etc.
• Involve state oversight such as CalOSHA early in the process to provide feedback. There is no charge for this service.

Existing construction:

• Request window-washing system certification (required annually) from the property owner; if not available, hire a qualified professional to prepare certification.
• In many cases, an OPOS is required. Again if not available from the property owner, an OPOS should be prepared by a qualified professional.
• Engage a scaffolding inspection and testing consultant on PCAs when there is any question about safety or code compliance of the existing system.

Being aware of some of the issues that can come up around EBM is just good business. While Marx|Okubo acts as an impartial guide, it’s in our clients’ best interest to know basic EBM rules and ensure buildings are compliant before they are built, bought or sold.