Chemical Safety for Cleaning Teams

Procedure Steps

1. 1

   Maintain Written HazCom Program Decision

   Your company is required by OSHA (29 CFR 1910.1200(e)) to have a written Hazard Communication Program at each workplace. This must describe: how labeling requirements will be met, how Safety Data Sheets will be obtained and maintained, how employee training will be conducted, and must include a list of all hazardous chemicals present (chemical inventory). It must also address methods for informing employees of hazards during non-routine tasks and hazards associated with chemicals in unlabeled pipes. If you work in client facilities (multi-employer worksites), you must share SDS for chemicals you bring on-site, inform the host employer of precautionary measures needed, and explain your labeling system. The host employer must do the same for you.

2. 2

   Access Safety Data Sheets (SDS)

   Before using any chemical, review its Safety Data Sheet. SDS must be readily accessible to all employees during each work shift at their work location (per 29 CFR 1910.1200(g)(8)) — employees must not have to ask a supervisor to access them. SDS can be maintained as physical binders, electronic files on a tablet/phone, or via a cloud-based SDS management system. For cleaning teams that travel between worksites, SDS may be kept at the primary workplace as long as employees can obtain the information in an emergency at any site. Key SDS sections for daily use: Section 2 (Hazards), Section 4 (First Aid), Section 7 (Handling and Storage), Section 8 (PPE Requirements).

3. 3

   Select Required PPE

   Review SDS Section 8 for each specific chemical you will use — required PPE varies by product. Common PPE includes: chemical-resistant gloves (material type specified on SDS), safety glasses or splash goggles, apron or coveralls. Important: if the SDS or your hazard assessment requires respiratory protection (e.g., for concentrated chemicals in enclosed spaces), your company must have a written Respiratory Protection Program per OSHA 29 CFR 1910.134, including medical evaluations and fit testing. Never handle chemicals without the PPE specified on the SDS.

4. 4

   Verify Container Labels

   All original manufacturer containers must have GHS-compliant labels with: product identifier, hazard pictograms, signal word, hazard statements, precautionary statements, and supplier name, address, and phone number. For secondary (workplace) containers: if the chemical will be used by someone other than the person who transferred it, or beyond the current work shift, the container needs at minimum a product identifier and general hazard information. If you transferred the chemical and will use it all within your current shift, no label is required (immediate-use exception per 1910.1200(f)(8)). Never use a container where you cannot identify the chemical.

5. 5

   Safe Dilution & Mixing

   Follow the manufacturer's dilution instructions on the product label or SDS Section 7 exactly — the label is the legal standard. General safety rule: when diluting any concentrate, add the product to the water, not water to the product, unless the product label specifies otherwise. This prevents dangerous exothermic splash reactions, especially with acid-based concentrates. Use calibrated measuring tools for dilution. Label all diluted solutions with the product name and dilution ratio. Critical: NEVER mix different chemical products. Common dangerous combinations in cleaning include bleach + ammonia-based products (toxic chloramine gas), bleach + acid-based products (chlorine gas), and bleach + rubbing alcohol (chloroform). Sequential application of different chemicals to the same surface also counts as mixing.

6. 6

   Chemical Storage

   Store chemicals in designated, ventilated areas. Keep incompatible chemicals separated — acids away from bases, oxidizers away from flammable liquids. For flammable liquid storage specifically, follow 29 CFR 1910.106 requirements. For all chemicals, follow the specific storage requirements listed in SDS Section 7 for each product. Store chemicals below eye level to reduce splash risk during retrieval. Keep containers sealed when not in use. Maintain organized storage with labels facing outward.

7. 7

   Spill Response Decision

   For minor/incidental spills that trained cleaning staff can safely handle: contain with absorbent materials, clean per SDS instructions, dispose of contaminated materials in proper waste container. For spills involving uncontrolled releases that pose a threat beyond what employees can safely manage — such as large volume releases, unknown chemicals, strong fumes, or any spill causing injury — evacuate the area, ventilate if safe to do so, and contact your supervisor and emergency services. Uncontrolled hazardous substance releases may require trained emergency responders under OSHA's HAZWOPER standard (29 CFR 1910.120); routine cleaning product spills that employees can safely control with proper PPE and absorbents do not require HAZWOPER training. Report all spills to your supervisor per your company's incident reporting procedure. Note: releases of certain substances above EPA reportable quantities may trigger federal reporting obligations under CERCLA or EPCRA.

8. 8

   Training Documentation

   All employees must complete HazCom training at the time of initial assignment, before they work with or are exposed to hazardous chemicals (per 29 CFR 1910.1200(h)). Training must cover: methods to detect the presence or release of hazardous chemicals, how to read SDS and labels, location of SDS at each work site, location of the written hazard communication program and chemical inventory list, physical and health hazards of chemicals at their specific work locations, and protective measures employees can take. Record the training date, topics covered, trainer name, and chemicals reviewed. Have the employee sign an acknowledgment. Best practice: retain training records for at least 3 years. Note: OSHA 1910.1200 does not specify a retention period, but records are your primary evidence of compliance during inspections. Check your state OSHA plan for state-specific requirements.