Every Houston building that has a cleaning crew also has hazardous chemicals on site, and that puts it under OSHA's Hazard Communication standard (29 CFR 1910.1200). The cleaning company must keep a written program, label every container, keep safety data sheets available on every shift and train its staff. Because two employers share your building, the standard also expects the contractor and the building's own employer to tell each other what chemicals are in use.
Texas has no OSHA state plan for private employers, so offices, plants, clinics and warehouses in Greater Houston answer to federal OSHA directly. Below is what the rule asks for, what the 2024 revision changed, and the clauses worth putting in a cleaning contract so compliance is not left to chance.
Why janitorial products fall under the rule
People tend to think of HazCom as a refinery or lab issue. It covers any workplace where employees can be exposed to a hazardous chemical, and a janitor's closet usually holds several: quaternary disinfectants, acid restroom cleaners, degreasers, floor strippers, bleach and glass cleaners with solvents.
There is a consumer product exemption, but it is narrow. It applies only when a product is used the way a household would use it, for about the same amount of time and as often. A crew that dilutes concentrate from a five-gallon pail and mops 40,000 square feet a night is well past that, so assume the standard applies to commercial cleaning work.
What the cleaning contractor has to do
The contractor is the employer of the cleaning staff, so the core duties sit with them:
- A written hazard communication program. It lists the hazardous chemicals the crew uses at your site and explains how labeling, safety data sheets and training are handled.
- Safety data sheets for every product. SDSs must be readily accessible to workers during every shift. A binder in the janitor's closet or a tablet or app the crew can open without delay both work, as long as nobody needs a manager's login to get to them.
- Labels on every container. Original containers keep the manufacturer's label. Spray bottles and buckets filled from concentrate need a workplace label showing the product name and its hazards. The one exception is a portable container meant for immediate use by the same person who filled it.
- Training before exposure. Workers are trained when first assigned and again whenever a new hazardous product is introduced, in a language and vocabulary they understand. In Houston, that often means training in Spanish as well as English.
The multi-employer piece facility managers miss
The standard has a specific section for workplaces where several employers' staff work side by side. The contractor's written program has to explain how it will give the host employer's people access to its safety data sheets and how it will inform them of precautions to take, such as staying off a floor that has just been stripped or ventilating a room after a disinfectant fog.
It works in the other direction too. If your building stores its own hazardous materials (lab chemicals in the Texas Medical Center, process chemicals near the Ship Channel, pool chemicals in a fitness center), the cleaning crew needs to know where they are and what to avoid. Ask for this exchange at the start of the contract and again whenever products change.
What the 2024 update changed
OSHA published a revised HazCom standard in May 2024 to align it with a newer edition of the Globally Harmonized System of classification and labeling. Most of the work falls on chemical manufacturers and distributors, but a few changes reach building users:
- Updated labels and safety data sheets. Manufacturers had until January 2026 to update information for single substances, and they have until July 2027 for mixtures, which covers most cleaning products. Expect revised SDSs and labels to keep arriving through that period.
- Employer deadlines. Employers using these products must update their labels, written program and training to match. The deadline is July 2026 for substances and January 2028 for mixtures.
- Small containers. Very small containers can now carry abbreviated labels, which matters for test kits and sample bottles more than for janitorial pails.
- Shipped containers. Containers already released for shipment do not have to be relabeled when new hazard information comes out, so old and new labels on the same product can sit side by side for a while.
For a building owner, this means a cleaning vendor working in your building through 2027 should be swapping old SDSs for new versions as suppliers send them, and should be able to show you that the binder or app is current.
Clauses to put in a Houston cleaning contract
A contract that names these items gives you something to audit:
- A chemical list for your site, with the SDS for each product, delivered before work starts and updated within a set number of days whenever a product is added or swapped.
- Where the SDSs will live on site and how your own staff can reach them.
- Labeling of all secondary containers, with dilution ratios on bottles filled from concentrate.
- Training records for every worker assigned to the building, in the language they work in.
- Restricted products. If your tenants include clinics, daycares or people with sensitivities, list what you do not want used, such as aerosol sprays or strong solvents, and ask for alternatives.
- Notice before strong chemicals are used, such as floor stripping or deep degreasing, so occupied areas can be closed off and ventilated.
- A contact for chemical questions who can answer within one business day.
None of this adds much cost. A capable commercial cleaning company already keeps these documents, so the contract simply makes them visible.
Questions to ask during a walkthrough
When you compare bids, ask each company to show you its SDS system and a sample of its secondary container labels. Ask how it handles the HazCom revision and whether its suppliers have sent updated sheets. Ask who trains new hires and how fast a new crew member is trained before working alone. Vague answers here usually mean the paperwork lives in an office somewhere rather than in your building.
You can read more about the work that involves the strongest chemicals, such as floor stripping, degreasing and disinfection, on our specialized cleaning page, and see local market details on the Houston commercial cleaning page.
Frequently asked questions
Does OSHA require a cleaning company to leave safety data sheets in a client building?
The standard requires SDSs to be readily accessible to the workers using the chemicals during every shift. For a crew working at your site, that in effect means a binder or electronic access on site. Most facility managers also write it into the contract so their own staff can reach the sheets.
Who is responsible if a cleaning crew uses an unlabeled spray bottle in an office?
The cleaning contractor, as the employer of the crew, is responsible for labeling its containers and training its workers. A host employer can still be pulled into a multi-employer citation if it knew about a hazard and did nothing, so it is worth reporting unlabeled containers to the vendor in writing.
Are green or "non-toxic" cleaning products exempt from HazCom?
Not automatically. A product is covered if it meets any of the standard's hazard criteria, regardless of how it is marketed. Many third-party certified products have milder hazard profiles, but they still come with safety data sheets and need to appear on the site chemical list.
Does Texas have its own workplace chemical rules on top of OSHA?
Texas does not run an OSHA state plan for private employers, so private sector buildings in Houston follow the federal standard. Local fire code rules on storing flammable and corrosive materials can still apply to janitorial closets, so check them with your building's fire safety plan.
Get quotes from cleaning teams that document their chemicals
Tell us about your facility and we'll connect you with a commercial cleaning team that serves Houston and can provide its chemical list and SDSs with the proposal. Request a quote here.