OSHA's Hazard Communication Standard (HCS 2012, aligned with GHS Rev. 3) requires that every employer who uses hazardous chemicals — including common cleaning products — maintain a comprehensive chemical safety program. For commercial cleaning operations, this isn't optional. Violations of the Hazard Communication Standard consistently rank among OSHA's top 10 most cited standards. This guide covers what facility managers and cleaning companies must do to comply.
Understanding GHS Labels on Cleaning Products
The Globally Harmonized System (GHS) requires standardized labels on all hazardous chemical containers, including cleaning products. Every GHS-compliant label must include a product identifier (chemical name or product name), signal word (either 'Danger' for severe hazards or 'Warning' for less severe), hazard pictograms (standardized diamond-shaped symbols indicating hazard types), hazard statements describing the nature of the hazard, precautionary statements for safe handling and emergency response, and supplier information. Cleaning staff must be able to read and understand these labels before using any product. If your cleaning company uses products in secondary containers (spray bottles), those containers must also be labeled with at minimum the product identity and hazard information.
Safety Data Sheet (SDS) Requirements
Every cleaning chemical used in a facility must have a corresponding 16-section Safety Data Sheet readily accessible to employees. SDS documents must be available in the workplace during every shift — not locked in a manager's office. Key sections for cleaning operations include Section 2 (hazard identification), Section 4 (first aid measures), Section 7 (handling and storage), Section 8 (exposure controls and PPE requirements), and Section 11 (toxicological information). Digital SDS management systems are acceptable as long as employees can access them immediately and backup procedures exist for electronic failures.
Employee Training Requirements
OSHA requires that all employees who may be exposed to hazardous chemicals receive training before initial assignment and whenever a new chemical hazard is introduced. Training must cover the location and availability of the written hazard communication program, physical and health hazards of chemicals in the work area, protective measures (PPE, ventilation, procedures), how to read GHS labels and SDS documents, and emergency procedures including spill response. Training must be documented with employee signatures, dates, and topics covered. Annual refresher training is considered best practice, though OSHA technically only requires training when new hazards are introduced.
Chemical Storage Requirements
Proper chemical storage is both a safety and compliance requirement. Cleaning chemicals must be stored in designated areas away from food, occupied spaces, and incompatible chemicals. Acids and bases must be separated. Oxidizers must be stored away from flammable materials. In childcare and educational facilities, all chemicals must be in locked storage inaccessible to children. Storage areas require adequate ventilation, spill containment provisions, appropriate signage, and eye wash stations if corrosive chemicals are present. Secondary containment (drip trays or bermed areas) is required for bulk chemical storage.
The Written Hazard Communication Program
OSHA requires every employer using hazardous chemicals to maintain a written Hazard Communication Program. This document must include a chemical inventory listing all hazardous products in the workplace, the location and method of accessing SDS documents, labeling procedures for secondary containers, employee training procedures and schedules, and procedures for non-routine tasks involving chemical exposure. For facilities using contract cleaning services, the written program must address how information about chemical hazards is communicated between the facility and the cleaning contractor.
GreenPoint maintains a comprehensive Hazard Communication Program with current SDS documentation for every product we use, documented employee training records, and GHS-compliant labeling on all containers. We provide SDS binders specific to your facility and ensure our chemical protocols meet both OSHA requirements and your facility's specific policies.