What Is a Cal/OSHA IIPP for a Cleaning Contractor?

What must a Cal/OSHA IIPP include?

Section 3203(a) lists eight elements. None of them is a form to fill in; each is a system the employer has to run. Here is how they translate to a janitorial company whose employees spread across dozens of client buildings.

When does a cleaning contractor have to train its crews?

Section 3203(a)(7) ties training to events rather than a calendar. Cleaners must be trained when the program is first set up, when they are hired, when they take on a new assignment they have not been trained for, when new substances, processes, procedures or equipment bring a new hazard, and when the employer learns of a hazard it had not recognized. Supervisors must also be trained on the hazards their crews face.

For a janitorial company, the new-assignment trigger fires constantly. A cleaner moved from an office tower to a warehouse with forklift traffic, or to a clinic with sharps, needs site-specific instruction before the first shift there. Section 3203(b)(2) requires records of each employee's training, with dates, type and trainer, to be kept for at least one year.

Which hazards should a janitorial IIPP address?

A generic IIPP copied from a template will not describe cleaning work well. The hazard list should reflect what crews actually do, and several other Title 8 programs plug into it.

• Slips and falls on wet floors, stairs and loading docks
• Chemical exposure, dilution and mixing errors, tied to the hazard communication program under section 5194
• Strain from lifting trash, repetitive mopping and pushing floor machines
• Ladders and step stools used for high dusting and light fixtures
• Sharps in trash and blood spills where section 5193 applies
• Indoor and outdoor heat under sections 3396 and 3395
• Working alone at night, now part of the workplace violence prevention plan required by Labor Code section 6401.9
• Vehicle and forklift traffic in parking structures, docks and warehouses

How does a contractor's IIPP fit with the host's safety program?

Each employer keeps its own program for its own employees, and the two have to meet in the middle. The host knows the site hazards: restricted rooms, lockout areas, lab chemicals, roof access and traffic patterns. The contractor knows the work. Neither program is complete unless the host shares those hazards and the contractor builds them into its inspections and training.

Cal/OSHA can cite more than one employer for the same hazard under its multi-employer worksite rule, Title 8 section 336.10, so coordination protects the host as much as the crew. A short site safety orientation at the start of service, with a named contact on each side, covers most of it.

What to ask a cleaning contractor to show you

There is no need to audit the whole program. A few documents show whether it is real or only a binder.

• The name of the IIPP's responsible person and how to reach them
• Recent inspection records for your site: who inspected, unsafe conditions found and corrective action taken, which section 3203(b)(1) requires to be kept for at least one year
• Training records for the cleaners assigned to your building
• How a hazard reported by your staff is logged and closed
• The injury investigation procedure, and whether your site contact hears about incidents
• The related written programs: hazard communication, heat illness and workplace violence prevention

How EBS inspections support site safety

EBS's quality system produces the kind of records a safety review looks for. Supervisors inspect each site on a routine schedule, unannounced audits included, and eHub logs what was checked, what needed attention and the corrective action taken. Team members are trained before they are assigned to a site, and supervisors stay in touch with the client, so a hazard noticed by either side has a clear route to the right person. EBS is licensed and insured; ask at the walkthrough for the safety documents your site requires.