The term “clean” has different meanings in different industries and to different people. For some business owners and facility managers, “clean” has a new definition. It’s no longer just about the absence of dirt or that fresh smell of cleaner. As more and more regulations regarding safe, clean work environments are put into action, cleaning has moved from a basic janitorial task to a specialized component of risk management. Navigating this new world of clean, especially in certain industries, may now be something you need a partner for, especially if you’re dealing with multiple federal agencies and overlapping policies.
That’s why SourceONE is ready to assist you with ensuring your facilities meet or exceed all regulations. We firmly believe that reactive cleaning, or cleaning when you see something that requires attention, isn’t the right way to avoid an audit. Instead, we’ve built our specific cleaning protocols around preventative measures and audit compliance. We won’t just ensure your employees and clients are safe, it will protect your business from the legal and often financial risks that can come from being non-compliant.
The Two Pillars: Understanding OSHA vs. CDC
In order to be fully compliant with all the regulations your industry needs to follow, you first have to understand those regulations and the two organizations responsible for them: The Occupational Safety and Health Administration (OSHA) and the Centers for Disease Control and Prevention (CDC). While these two organizations may often work together, their rules are often very different. In fact, in some cases they can seem almost contradictory.
OSHA Standards: The Legal Mandate
OSHA is the regulatory agency in charge of workplace safety, and they have the authority to issues fines and citations to back up their rules. If they see a potential threat to the health and safety of your employees, they will not hesitate to issue these citations. Under General Duty Clause Section 5(a)(1), employers are required to provide their workers with an area that is free from hazards that could cause physical injury or death.
When it comes to cleaning and disinfecting, the most critical regulation is OSHA’s Bloodborne Pathogens Standard or, in technical terms, 29 CFR 1910.1030. This requires all employers to create and implement an Exposure Control Plan that ensures all surfaces are cleaned with EPA-registered cleaners that have been proven effective against Hepatitis B, HIV, and other specific pathogens.
CDC Guidelines: The Scientific Roadmap
The CDC, unlike OSHA, doesn’t actually have the power to regulate companies, nor does it create regulations. However, their guidelines are the standard on which many legal regulations are based. The CDC publishes guidelines on how to deal with infections. During a public health crisis or outbreak, OSHA will typically directly adopt the CDC recommendations as the standard for a safe workplace.
The Hierarchy of Regulatory Cleaning
There is no one-size-fits-all solution to meeting OSHA and CDC standards. There is a specific hierarchy to regulatory cleaning that begins with general maintenance and ends with using high-level disinfectants. These solutions include the following:
- Sanitizing – reduces the number of bacteria on a surface. Sanitization is common in food-related industries, such as restaurants and grocery stores.
- Disinfecting – Disinfection involves using chemicals to kill most or all of the bacteria, viruses, and other microorganisms on a surface. This is often required for high-touch areas that hundreds or thousands of people touch every day.
- Sterilizing – Sterilizing a surface means that all microbial life has been completely eliminated. This is often used only in surgical environments, such as operating rooms or highly specialized labs.
For the average facility, we typically focus on a regular, consistent disinfection program. However, one common mistake that many cleaning companies make is that they apply disinfectant to a surface that is still dirty. Both the CDC and OSHA stress that you cannot fully disinfect a surface until it has been cleaned. The reason for this is that organic matter, dust, and other debris can cover pathogens, protecting them from the disinfectant chemicals.
Developing Your Compliance Protocols
A professional cleaning service doesn’t simply show up with a broom and a mop. Instead, they first sit down with you and develop a plan for cleaning your facility that acknowledges and observes all regulations. When you partner with SourceONE, we will work with you to create a series of compliance protocols that are documented, verified, and repeatable. These protocols include the following:
1. The Hazard Communication (HazCom) Standard
OSHA’s HazCom standards require employees to be informed about what chemicals that are using or exposed to. This means that every disinfectant used in your facility needs to have a Safety Data Sheet (SDS) that employees can easily access. If an auditor walks into your facility and asks to see the SDS for the glass cleaner being used and you’re unable to provide it, you’re instantly in violation of OSHA guidelines.
2. Dwell Time Accuracy
One of, if not the most overlooked part of disinfecting is what’s known as dwell time. This is the amount of time a disinfectant needs to remain visibly wet on a surface in order to be effective. If it’s wiped away too early, it won’t kill the targeted pathogens. Many disinfectants need to remain on a surface for three to ten minutes. If these chemicals are sprayed on a surface and then immediately wiped away, they haven’t done anything except spread the germs around.
3. High-Touch Point Identification
As part of the protocol design process, you will need to identify your infection vectors. In a standard office building, these will be things that are often touched such as door handles, elevator buttons, and breakroom appliances. The CDC recommends cleaning these areas more frequently to maintain a safe environment and prevent the spread of germs.
The High Cost of Non-Compliance
What happens if you’re not compliant with OSHA regulations? There are financial implications that come with failing an audit, including the cost of the disruption to your workflow and the cost of any fines you’re assessed.
How much are these fines? In 2024, the maximum fine OSHA could assess was over $16,000 per “serious” first-time violations. For repeated violations or for violations they considered willful, the fine could be as much as $160,000 per violation. Beyond the fines, there are other costs. Failing to disinfect surfaces correctly can lead to higher absenteeism as more employees get sick. According to the Bureau of Labor Statistics, US employers lost billions of dollars in lost productivity due to illness-related absences. There’s also the morale and reputation hit that comes with being considered an unsafe or unclean workplace.
The SourceONE Advantage: Precision and Verification
At SourceONE, we don’t leave cleaning to guesswork. Instead, we build our cleaning protocols on the foundation of ISO certifications, OSHA regulations, and CDC guidelines. All of our methods are designed to meet the strictest requirements and audits. We make use of EPA-registered disinfectants on List N, the list of products that have been approved for use against viral pathogens and ensure that all of our team members are trained in the OSHA regulations relevant to your industry. We’ll provide you with all of the documentation necessary to meet these regulations and pass an audit, too.
Compliance isn’t a destination; it’s a process. As guidelines and regulations change, your cleaning protocols must remain flexible enough to change with them. Partnering with SourceONE is the first step to ensuring you are fully compliant with all regulations. Reach out today to discuss your disinfection needs.