How can you tie-off the ladder without first climbing it?
It doesn't say you have to in the regs; so I guess you climb the ladder and tie it to a flimsy plastic gutter or something!
No trad window cleaner is going to do this; I've only tied a ladder off ONCE in five years; and that was to stop the wind blowing it from the top of a flat roof.
Basically, the rules are there to prevent deaths and injuries; take from them what you will. I know I don't follow them, I just use my own judgement and common-sense.
At the end of the day (IMHO); the only good thing about WAHD 2005 is that it highlights safety in the minds of people who routinely work at height and treat it without the respect it deserves.
Also, I wonder how many lives this document may have saved? I think two window cleaners have already died from falls this year; and I've read a few news articles of some serious life-changing injuries. Although unquantifyable, it would be interesting to know how many window cleaners would've 'knacked' themselves if it wasn't for the 'new regs'?