Do Cleaning Contractors Have to Provide SDS Sheets?

What section 5194 requires of a cleaning contractor

The standard treats a cleaning company like any employer whose employees use hazardous chemicals. It needs a written hazard communication program, a list of the hazardous chemicals it uses, an SDS for each one, labels on containers and training for its employees at initial assignment and whenever a new chemical hazard enters their work area.

Access is the test that matters on site. Section 5194(g)(8) requires the sheets to be readily accessible during each work shift to employees in their work areas. Electronic access is allowed as long as it creates no barrier to immediate access, so a QR code that only works with cell coverage is a poor substitute for a binder in a basement janitor's closet.

What shared buildings add under subsection (e)(2)

Your building becomes a multi-employer workplace whenever a contractor's crew works in it. Section 5194(e)(2) requires the written program of an employer whose chemicals could expose other employers' workers to spell out three methods. The duty runs both ways: if your own staff store lab reagents, pool chemicals or maintenance solvents in rooms the crew cleans, your program owes the contractor the same information.

• How it gives the other employers access to the SDS for each hazardous chemical, or makes the sheets available at a central location
• How it informs them of precautions needed in normal operations and foreseeable emergencies
• How it informs them of the labeling system used in the workplace

Which cleaning products need cleaning contractor SDS sheets?

Most professional janitorial products do. The main exception covers consumer products packaged for the general public, and only when employee exposure is not significantly greater than a consumer's. A cleaner using a retail glass cleaner all night, every night, is not a typical consumer.

Reading the parts of an SDS that matter on site

Every SDS follows the same 16-section format, so once you know where to look, comparing products takes minutes. Facility managers usually need five of those sections.

• Section 2, hazard identification: signal word, hazard statements and pictograms
• Section 4, first aid: what to do after a splash or inhalation
• Section 6, accidental release: how to contain a spill
• Section 8, exposure controls: gloves, eye protection and ventilation
• Section 10, stability and reactivity: incompatible materials, such as bleach with ammonia or acids

Spray bottles, dilution and secondary containers

Labeling failures are more common than missing sheets. Section 5194(f) generally requires workplace containers to be labeled, and the portable container exception in subsection (f)(8) covers only containers intended for the immediate use of the employee who filled them. A spray bottle filled on Monday and left on a cart for the next shift needs a label with the product name and its hazards.

California also gives buyers an ingredient tool. The Cleaning Product Right to Know Act of 2017 (SB 258) requires manufacturers of covered cleaning products sold in the state to disclose intentionally added ingredients online and on labels, which helps when an occupant asks what a product contains.

What to require in the cleaning contract

Put the expectations in writing so a product change never surprises a tenant or your own safety lead.

• A product list for your building, updated whenever products change
• Current SDSs for every listed product, kept where your staff can reach them
• Labels on every secondary container that leaves the hands of the person who filled it
• Notice before a new product is introduced, especially in clinical or occupied areas
• Training records showing the crew was trained on the products it uses
• A contact who can answer an occupant's question about a product

How EBS handles products on site

The products EBS uses at a building, including the EPA-approved disinfectants applied to high-touch surfaces, can be listed in the scope agreed at the walkthrough. Green, non-toxic and biodegradable alternatives are available on request where occupants are sensitive to fragrance or chemicals. Team members are trained before a site assignment, and supervisors stay in contact with the client, so a question about a product reaches someone who can answer it.