OSHA requires commercial janitorial services to comply with hazard communication, bloodborne pathogens, PPE standards, and general workplace safety regulations. Here is the complete compliance guide for property managers.
Commercial janitorial services are subject to multiple OSHA standards that protect cleaning workers from workplace hazards. Property managers and building owners who contract janitorial services have a shared responsibility with their cleaning contractor to ensure these standards are met. The most important OSHA standards for janitorial operations include the Hazard Communication Standard (29 CFR 1910.1200), the Bloodborne Pathogens Standard (29 CFR 1910.1030), Personal Protective Equipment requirements (29 CFR 1910.132-138), and general industry workplace safety rules. Understanding these requirements helps property managers evaluate cleaning contractors’ safety programs and protect themselves from liability related to workplace injuries on their properties.
OSHA compliance in janitorial services is not optional — violations can result in fines ranging from $15,625 per serious violation to $156,259 per willful or repeat violation. Beyond the direct financial risk, OSHA violations damage a cleaning company’s reputation and can disqualify them from government contracts and large commercial accounts. Property managers should verify that their janitorial contractor has a comprehensive OSHA compliance program, documented training records, and a strong safety record. This guide covers the key OSHA standards that apply to commercial janitorial services and what property managers should look for when evaluating a cleaning contractor’s compliance.
Hazard Communication Standard (HazCom 2012 / GHS)
The Hazard Communication Standard (HazCom) is the most foundational OSHA requirement for janitorial services because cleaning workers are exposed to chemical products every day. Under HazCom, updated in 2012 to align with the Globally Harmonized System (GHS), cleaning companies must maintain a written hazard communication program that documents how they manage chemical hazards in the workplace. This program must include a complete inventory of all cleaning chemicals used on site, with corresponding Safety Data Sheets (SDS) for each product. The SDS must be readily accessible to all cleaning staff during their work shifts — either in a physical binder kept at the job site or through an electronic system accessible from mobile devices.
All chemical containers in the workplace must be properly labeled. Primary containers (the containers chemicals come in from the manufacturer) must have GHS-compliant labels that include the product identifier, signal word (Danger or Warning), hazard statements, precautionary statements, pictograms, and manufacturer information. Secondary containers (spray bottles, buckets, or other containers that cleaning products are transferred into) must also be labeled with the product name and appropriate hazard warnings. Using unlabeled spray bottles is one of the most common OSHA citations in the janitorial industry and creates serious safety risks — a cleaner or building occupant should never have to guess what is in a spray bottle.
Training is the third pillar of HazCom compliance. All cleaning staff must receive initial training on the chemicals they will be using, including how to read SDS documents, how to understand GHS labels and pictograms, the physical and health hazards of each chemical, proper handling and storage procedures, and emergency procedures for spills or exposures. Refresher training is required whenever new chemicals are introduced. Training must be documented with records showing the date, topics covered, trainer name, and employee signatures. Property managers should request to see a contractor’s HazCom training records during the vendor selection process — a cleaning company that cannot produce these records is almost certainly out of compliance.
Bloodborne Pathogens Standard for Janitorial Staff
The Bloodborne Pathogens Standard (29 CFR 1910.1030) applies to any janitorial staff who may reasonably be expected to come into contact with blood or other potentially infectious materials while performing their duties. Since cleaning workers handle restroom trash, clean restroom fixtures, and may encounter discarded needles, bandages, or other medical waste in their daily work, this standard applies to virtually all commercial janitorial operations. OSHA defines “other potentially infectious materials” to include semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva in dental procedures, any body fluid visibly contaminated with blood, and all body fluids in situations where it is difficult or impossible to differentiate between body fluids.
Under this standard, cleaning companies must have a written Exposure Control Plan that identifies job classifications and tasks where occupational exposure occurs, describes the engineering controls and work practices that will minimize exposure, specifies the schedule for cleaning and decontaminating work surfaces, outlines procedures for evaluating exposure incidents, and documents that hepatitis B vaccinations have been offered to at-risk employees. The plan must be reviewed and updated at least annually. Engineering controls for janitorial staff include puncture-resistant sharps containers for needle disposal (provided by the building owner in restrooms), mechanical devices for handling contaminated materials, and proper waste disposal procedures.
Training under the Bloodborne Pathogens Standard must include an accessible copy of the regulatory text, a general explanation of the epidemiology and symptoms of bloodborne diseases, an explanation of the modes of transmission, an explanation of the employer’s exposure control plan, procedures for recognizing tasks that may involve exposure, information on the types, proper use, location, removal, handling, decontamination, and disposal of PPE, information on the hepatitis B vaccine, procedures for post-exposure evaluation and follow-up, and an opportunity for questions with the trainer. This training must be provided at the time of initial assignment and annually thereafter. Documentation must be maintained for each employee for the duration of employment plus 30 years.
Personal Protective Equipment (PPE) Requirements
OSHA’s PPE standards (29 CFR 1910.132-138) require cleaning companies to provide appropriate personal protective equipment to all employees at no cost. For janitorial staff, typical PPE includes chemical-resistant gloves for handling cleaning chemicals, rubber gloves with cotton liners for wet work in cold conditions, safety glasses or goggles when mixing chemicals or cleaning with splash potential, slip-resistant footwear for work on wet floors, back support belts for lifting heavy trash bags and equipment, and knee pads for floor-level work. The employer must conduct a PPE hazard assessment to determine what equipment is needed for each task, document that assessment in writing, provide the required PPE, train employees on proper use and maintenance, and enforce PPE usage on the job.
One of the most important PPE considerations for janitorial staff is hand protection. Cleaning workers’ hands are exposed to chemicals, water, and biological contaminants throughout their shift. Gloves must be selected based on the specific chemicals being used — latex or nitrile gloves provide protection against mild detergents, while heavier neoprene or butyl rubber gloves are needed for stronger chemical strippers, degreasers, and disinfectants. Gloves must be inspected before each use for tears, punctures, or degradation. Disposable gloves should be changed between tasks, particularly when moving from restroom cleaning to office area cleaning, to prevent cross-contamination. Reusable gloves must be washed and dried after each use and replaced when they show signs of wear.
Property managers can verify PPE compliance by observing cleaning staff during their work — are they wearing appropriate gloves, slip-resistant shoes, and any other required PPE? Are gloves in good condition? Are chemical safety glasses available and used during mixing tasks? A cleaning contractor that prioritizes OSHA compliance will have staff who wear their PPE consistently and correctly. The absence of proper PPE is a red flag that the contractor may be cutting corners on safety in other areas as well.
Slip, Trip, and Fall Prevention for Cleaning Operations
Slip, trip, and fall hazards are the most common cause of injury in the janitorial industry, accounting for approximately 30% of all cleaning-related workplace injuries according to Bureau of Labor Statistics data. The primary hazard is wet floors — cleaning activities create wet surfaces that building occupants and cleaning staff themselves can slip on. OSHA’s general duty clause requires employers to provide a workplace free from recognized hazards. For janitorial operations, this means implementing a comprehensive wet floor safety program that includes proper signage — OSHA-compliant “Wet Floor” signs in high-visibility yellow must be placed at all entry points to wet areas before cleaning begins and remain in place until floors are completely dry. Cones or barricades may be needed for larger areas.
Additional slip prevention measures include using appropriate mopping techniques that minimize water usage, employing microfiber mopping systems that leave floors drier than traditional string mops, scheduling floor work during low-traffic periods to reduce exposure to building occupants, and ensuring proper drainage in mop sinks and storage areas. Cleaning staff should be trained to identify and address other slip, trip, and fall hazards during their work: loose rugs or mats, electrical cords across walkways, uneven floor transitions, poor lighting in stairwells, and debris on stairs. These hazards should be reported and corrected immediately rather than waiting for the next maintenance cycle.
Footwear is a critical prevention measure. Cleaning companies should require slip-resistant footwear for all staff and provide clear footwear policies. Many shoe manufacturers offer slip-resistant footwear specifically designed for the cleaning industry with specialized tread patterns that channel water away from the sole. Property managers should make sure their insurance requirements include that cleaning contractors maintain a written slip prevention program and document their training on wet floor safety procedures.
Ladder Safety and Working at Heights
Janitorial staff frequently use ladders and step stools to clean windows, change light bulbs, dust high surfaces, and access stored supplies. OSHA’s ladder safety standards (29 CFR 1910.23) apply to all ladder use in commercial janitorial operations. Step ladders used in cleaning must meet OSHA requirements including being in good condition with no broken or missing steps, having slip-resistant feet, being rated for the weight they will carry including the worker and their tools (Type I or Type IA is recommended for janitorial use), and being placed on stable, level surfaces. The use of makeshift climbing devices — chairs, desks, boxes, countertops, or stacked items — is strictly prohibited by OSHA and should never be tolerated on a job site.
Cleaning staff must be trained on proper ladder safety: always maintaining three points of contact (two feet and one hand) when climbing, never standing on the top two steps of a step ladder, keeping your body centered between the side rails, not over-reaching while on the ladder (move the ladder instead), inspecting the ladder before each use, and never using metal ladders near electrical equipment. Cleaning companies should conduct annual ladder inspections and maintain a written ladder inventory with inspection records. Any ladder with defects should be immediately removed from service and tagged as “Do Not Use” until repaired or replaced.
For tasks requiring work above 6 feet, additional fall protection measures may be required. High-reaching work such as cleaning atriums, tall windows, or warehouse racking may require scaffolding, aerial lifts, or other fall protection systems that require additional training and certification. The cleaning contractor should assess each job site for elevated work requirements and provide the appropriate equipment and training before staff begin work. Property managers should discuss any elevated work requirements with their cleaning contractor before the contract begins to make sure the contractor has the capability to perform the work safely.
Recordkeeping and Reporting Requirements
OSHA requires cleaning companies with more than 10 employees to maintain specific records and report certain events. Injury and illness records must be maintained using OSHA Forms 300, 300A, and 301. Form 300 is the Log of Work-Related Injuries and Illnesses used to record each workplace injury or illness. Form 300A is the annual summary that must be posted in a visible location in the workplace from February 1 through April 30 each year. Form 301 is the individual incident report for each injury or illness. These records must be maintained for five years and made available to OSHA upon request.
Certain events require direct reporting to OSHA. Work-related fatalities must be reported within 8 hours. Work-related in-patient hospitalizations, amputations, or losses of an eye must be reported within 24 hours. Reports can be made by calling the nearest OSHA office, calling the OSHA 24-hour hotline at 1-800-321-6742, or reporting online through OSHA’s website. Cleaning companies should have clear procedures for reporting these events and should train their supervisors on the reporting requirements.
Property managers should ask potential cleaning contractors about their OSHA recordkeeping practices and recent injury history. A contractor with a high injury rate or a history of OSHA citations may not have an effective safety program. However, be aware that some contractors under-report injuries to make their safety record look better — this is itself an OSHA violation. A reputable contractor will have a safety director or designated safety officer, documented safety meetings, and a proactive approach to identifying and correcting hazards. The contractor should be willing to share their OSHA 300A summary and discuss their safety record openly. RBM Building Services maintains comprehensive OSHA compliance across all our service locations. See our janitorial services page for more on our safety program or contact us to request our safety documentation.
Ensure your cleaning contractor meets all OSHA requirements. Contact RBM for compliant services.
Final Thoughts
OSHA compliance in commercial janitorial services is not just a legal requirement — it is a fundamental indicator of a cleaning company’s professionalism, training standards, and commitment to worker safety. Property managers who work with OSHA-compliant cleaning contractors reduce their liability risk, ensure better-trained staff are working in their buildings, and contribute to safer working conditions across the industry. When evaluating a janitorial contractor, ask about their written safety programs, training documentation, injury records, and insurance coverage. A contractor that takes OSHA compliance seriously will have comprehensive programs and will be happy to share their safety documentation with prospective clients.
Since 1974, RBM Building Services has maintained comprehensive OSHA compliance across all our commercial janitorial services, building maintenance, industrial cleaning, and specialty services. We serve facilities across Utah, Arizona, Nevada, and Texas. Our safety program includes regular training, documented compliance, and a dedicated safety officer. Call 800.403.3564 or contact us to learn more about our safety standards. For more commercial cleaning and safety insights, visit our company blog and the DoubleTake Carpet Cleaning blog.
