7.1 The Basics
It’s good advice to still be safe and compliant in every circumstance, even your own family home, as people’s safety can genuinely be at risk. Whether that’s a trip over a vacuum cleaner cable, or mistakenly swallowing detergent, there can be horrible consequences.
However a direct liability tends to occur when you’re in a business context, such as when an external firm of cleaners are instructed, or a business’ employees carry out the tasks. This also includes less obvious business interests like voluntary groups, who still fall within definitions such as ‘employers’ under legislation. This can be by direct law and obligations for their activity, or more general legislation like the Health & Safety at Work etc. Act 1974.
There is a specific requirement for correct Personal Protective Equipment (PPE) in a work criteria under The Personal protective Equipment at Work Regulations 1992, with full details in a later section.
7.2 COSHH Policy
This is a specific legal obligation under the Control of Substances Hazardous to Health Regulations (2002) which relates to cleaning activities, with the phrase ‘COSHH’ being an abbreviation of this (pronounced as ‘cosh’). Under this you need to asses the risks of hazardous substances with full Risk Assessment, plan for emergencies, plan to prevent or handle risks, train people, and actual time spent with such substances.
From this stems a ‘COSHH Policy’, which is a practical description of how a cleaner intends to carry out activities in line with these obligations. Whilst you can find generic templates to work with, you must demonstrate that this has been applied to your real-life situation.
One aspect of this is having clear procedures and an emergency spill kit to deal with any spillages and exposure on site. This can include plenty of absorbent mats, disposable bags, container for the bags, and materials to soak up spills.
7.3 RIDDOR Procedure
There is an obligation under Reporting of Injuries, Diseases, and Dangerous Occurrences Regulations (RIDDOR) to report any serious accidents and even deaths to an external authority, in addition to usual procedures of alerting emergency services, carrying out First Aid, and reporting any incidents in an Accident Book.
This does not necessarily need to be straight away as the focus will be on genuine and quick medical attention, but as soon as practically possible afterwards this needs formal reporting via telephone call or written means, details available at - www.hse.gov.uk/riddor/report.htm
A clear procedure of the individuals responsible for this and how they are implemented then needs to be agreed.
7.4 Risk Assessments
On the same lines as any other risk assessments, these needs to address the potential risks with any cleaning activity, who is potentially vulnerable to harm from them, the severity and likelihood of these happening, and then practical action points to help ideally avoid them or at least reduce the potential effect from them.
This will need to include the above COSHH policies, and clear application of the issues involved in each situation and instruction.
These should be completed by people actually involved in the cleaning, and then be regularly reviewed and updated in the future as necessary.
7.5 Data Sheets
These are basically a summary of specific cleaning products that are used as an easy quick reference point. As well as technical information often available from the manufacturer or supplier, whether through their own Data Sheets or updates, they also need to have practical instructions on how to correctly use in an emergency, for example how to treat an accident or burns, and how it can or can’t be mixed with other substances.
You then need to ensure only these products are used, rather than cleaners bringing their own items. Even a genuine attempt to locate a cheaper product with the same brand, can trigger a whole new set of requirements.
7.6 Notices & Signs
These range from standard warning signs on places like cupboards and equipment, to more temporary signs warning of actual cleaning in process, whether a poster on the wall or floor flip signs.
Sometimes you also see a working rota of areas being regularly checked and cleaned in public places like motorway service stations and restaurants.
As well as focusing on the essential needs from risk assessments and policies, they always need to make sense and be understood by both cleaners and general users. This includes removing them when not applicable, so people don’t take for granted and actually become immune to them.
7.7 Instructions and Guides
Really simple, but make sure it’s clear what to do and how to do it. Not only will this help newbie cleaners begin correctly, but be a reference for ongoing ones and any emergency call-in cleaners.
It will also probably need to be even easier and simpler than what you may at first think, particularly if you’re heavily involved in the cleaning process anyway. The best way to determine this is to ask someone independent to try and understand what they would need to do by simply looking at your guides and instruction.
There needs to be a basic log of what cleaning is carried out, ideally a simple form but still including all the important information.
As well as general employment information such as hours and areas completed in order to validate charges and service, it forms an important Health & Safety record of how things were completed including reporting of any issues and accidents, and procedures under COSHH and the Risk Assessment.
Whilst this is instinctive and often naturally takes place with people showing new cleaners what to do, it’s important to firstly include all the right elements, and secondly record this in writing. This is for both induction training to begin with, but also regular reviews and refreshers.
All people need to be involved as well, right down from managers in larger organisations to individual cleaners and helpers.
7.10 Buildings & Fire
Make sure individuals know the important facts about a building and how they should safely use it, for example through a formal Building Guide or part of the initial induction.
Examples include knowing what areas to access, where to store stock and equipment, whether to notify anyone, toilet facilities, where to park a car, and safe use of facilities such as stairs and lifts.
Probably one of the most important issues is Fire Safety, so knowing what the procedures are for evacuating the building in an event of an emergency and where to congregate and who to notify. Also, safe operation of Fire Extinguishers, and making sure fire escape routes are always clear and there are no combustible materials.
In some circumstances the cleaner can also assist in other related duties such as carrying out weekly fire alarm bell tests and being able to check any error messages on the fire alarm panel.
7.11 Lone Worker
As part of the main Health & Safety Risk Assessment you need to address issues linked with cleaners working alone, and have a separate Lone Worker Policy to help clarify how this operates. Although the focus is on the individual cleaner and their personal safety whilst carrying out their cleaning duties, this inevitably involves others, for example other co-workers, line managers, and individuals such as the elderly and young that are around.
The range of issues to consider are ways to reduce times when they are alone, regular phone calls and contact when they are alone, and ways to alert others by alarms and calls if there are issues. Also, procedures to reduce the risk for individual tasks, for example not taking rubbish bags along an alley way in darker winter hours.
There are a range of different types of policies to consider, the main ones listed below. It’s essential to make sure there is no cleaning without insurance and to cover the information supplied, and have procedures for processing any claim and supplying certificates of cover when requested.
· Public Liability
· Employers Liability
7.13 Health & Safety Policy
This is a general policy that encompasses general procedures for how an organisation implements good health & safety practice. This is to benefit all internal employees and helpers, as well as clients and customers, and becomes more involved and needing written evidence for larger groups with over 5 employees.
It also applies to both the organisation carrying out the cleaning activity, and also the organisation benefiting from it. So a business called ABC may instruct a cleaning company called XYZ, therefore both require a Health & Safety policy that the other organisation can also see and adhere to.
7.14 Security & Access
Make sure there are clear procedures for how cleaners should access areas, as often this is taken for granted and not correctly thought through. If they have autonomy to complete themselves, then make sure all access codes, and fobs/swipe cards, keys, and alarm codes are issued to them, including any emergency and cupboard areas they may need to access.
If they have less autonomy, then have a clear record of who they need to meet, or how they collect and then drop off, say, any keys and codes. Also, document that these are correctly managed under Data Protection and general Health & Safety duties.
7.15 Food Hygiene
For areas of food and drink preparation, there are additional hygiene requirements to consider. Whilst this is more on the catering side, with aspects like Food Hygiene courses, this does of course include more specific cleaning requirements that either direct kitchen-users and food preparers or other cleaners need to adhere to.
Examples of the issues to consider are:
· Correct storage of food, for example by date.
· Keeping preparation areas like worktops, and utensils like knives, particularly clean.
· Additional cleaning and sterilisation where needed, for example coffee machines.
· Ensuring people keep a high standard of hygiene, for example regularly washing hands, and not carrying infections like colds.