The International Window Cleaning Association asked OSHA whether an industrial rope access system (IRAS) used on a building, which allows controlled descent with the ability to stop at any point, counts as a rope descent system (RDS) under 29 CFR 1910.21(b), and whether the anchorage identification and certification requirements in 1910.27(b) apply to building owners or employers when IRAS are used.
OSHA's answer to both questions was no. The regulation defines an RDS as 'a suspension system that allows an employee to descend in a controlled manner,' but the definition expressly states that 'Rope descent systems do not include industrial rope access systems.' Because IRAS are carved out of the definition, 29 CFR 1910.27(b) does not cover them, and its anchorage identification and certification requirements do not apply to IRAS work.
That does not mean rope access work is unregulated. OSHA pointed to the other standards that do apply: 29 CFR 1910.28 (duty to have fall protection), 1910.29 (fall protection systems criteria), 1910.30 (training), and 1910.140 (personal fall protection systems). IRAS anchorage requirements specifically fall under 29 CFR 1910.140(c)(12) and 1910.140(c)(13) through (c)(13)(ii).