Industrial sites involve hazardous chemicals used by both the site and its cleaning contractor, with each having responsibilities for managing the risks associated with those chemicals. When a cleaning contractor brings degreasers or disinfectants into an industrial site, it must manage the risks associated with those chemicals. At the same time, the contractor must follow the site’s chemical safety rules, including requirements for chemical storage, handling, emergency procedures, and access to Safety Data Sheets (SDS).
Poor coordination can create additional chemical risks. A cleaning chemical used or stored without considering chemicals or substances already present on-site may create an incompatibility or exposure risk. Neither business should assume that the other has managed the risks arising from its own activities. Under the WHS framework, PCBUs with duties relating to the same matter may need to consult, cooperate and coordinate their activities.
Facility and property managers overseeing manufacturing, warehousing or heavy processing sites across Greater Sydney need an industrial cleaning service that understands both sides of this responsibility, not just its own. This blog explains what an SDS provides, what the current WHS Regulation 2025 requires for hazardous chemicals, how responsibilities are shared between a site operator and its cleaning contractor, and what a facility manager should check before engaging one.
What Is an SDS?
A Safety Data Sheet (SDS) is a document prepared by a chemical’s manufacturer or importer that provides information about its hazards, safe handling, storage and emergency measures. On an industrial site, an SDS provides important information that helps workers understand how a specific chemical should be handled and what to do if an incident occurs.
What Information Does an SDS Provide?
An SDS provides information about a chemical’s identity and classification under the Globally Harmonized System (GHS), its physical and health hazards, safe handling and storage requirements, and first aid and emergency measures. This information helps cleaning contractors understand the hazards and required precautions for a specific chemical rather than relying on assumptions based on similar products.
Who Needs Access to the SDS?
Relevant SDSs must be readily accessible to workers and other people who may be exposed to the hazardous chemical. Emergency responders may also need access to this information when dealing with a chemical incident.
On an industrial site, a cleaning contractor should ensure that the SDSs for the chemicals its workers use are readily accessible while they are working on-site. The contractor should not rely only on SDSs stored at its own office or base of operations. The site may also have its own SDS and chemical register requirements, which the contractor needs to understand and follow as part of its site-specific procedures.
What Does the WHS Regulation 2025 Say About Hazardous Chemicals?
The Work Health and Safety Regulation 2025 sets out NSW requirements for working safely with hazardous chemicals across sections 328 to 391. These provisions cover matters including the application of the hazardous chemical requirements, safety data sheets, hazardous chemical registers, risk management, storage, handling and emergency arrangements.
The WHS Regulation 2025 replaced the previous WHS Regulation 2017 and largely continues its hazardous chemical framework, with some amendments and updated terminology.
Regulation 328: Application of Part 7.1
Regulation 328 establishes when Part 7.1 of the WHS Regulation applies. It covers the use, handling and storage of hazardous chemicals at a workplace, the generation of hazardous substances at a workplace, and pipelines used to convey hazardous chemicals. The section also sets out circumstances where Part 7.1 does not apply.
SDS Requirements
The Regulation places duties on manufacturers and importers to prepare and provide safety data sheets for hazardous chemicals. Suppliers also have obligations to provide current SDSs when required. At the workplace, a PCBU must obtain the current SDS for a hazardous chemical and make it readily accessible to workers involved in using, handling or storing it.
For a cleaning contractor, this means the SDS for hazardous cleaning chemicals used on an industrial site needs to be current and readily accessible to the workers who use those chemicals.
Hazardous Chemical Register
Regulation 346 requires a PCBU to ensure that a register of hazardous chemicals used, handled or stored at the workplace is prepared, kept at the workplace and maintained so the information remains up to date. The register must include the listed hazardous chemicals and the current SDS for each one. It must also be readily accessible to workers involved in using, handling or storing the chemicals and anyone else likely to be affected by them.
The register and SDS serve different purposes. The register helps identify which hazardous chemicals are present at the workplace, while the SDS provides detailed information about the hazards, handling, storage and emergency measures for each chemical.
Managing Risks Associated With Hazardous Chemicals
Regulation 351 requires a PCBU to manage risks to health and safety associated with using, handling, generating or storing hazardous chemicals at a workplace. When managing these risks, the PCBU must consider factors including the chemical’s hazardous properties, the nature of the work and any potentially hazardous chemical or physical reaction with another substance or mixture.
The approved Code of Practice: Managing Risks of Hazardous Chemicals in the Workplace provides practical guidance on how PCBUs can meet these duties. An approved code of practice can also be considered as evidence in court proceedings when determining whether a relevant WHS duty has been complied with.
Who Is Responsible for Hazardous Chemicals When a Cleaning Contractor Enters an Industrial Site?
Both the site operator and the cleaning contractor have PCBU responsibilities for hazardous chemicals when cleaning work is carried out by a cleaning company on an industrial site. One party’s compliance does not automatically remove the other’s duties. The site operator has duties relating to hazardous chemicals and risks present at the workplace, while the cleaning contractor has duties relating to the chemicals and work activities it controls.
The Industrial Site’s PCBU Responsibilities
The site PCBU may maintain the workplace’s hazardous chemical register, manage risks associated with chemicals used in its operations, and provide relevant information about site hazards and procedures to workers and contractors whose work may be affected.
A cleaning contractor should therefore be given relevant information about hazardous chemicals, site-specific procedures and emergency arrangements that could affect its work. The contractor should not be assumed to be outside these requirements simply because it brings its own cleaning products onto the site.
The Cleaning Contractor’s PCBU Responsibilities
The cleaning contractor has duties to manage the risks associated with hazardous chemicals it uses, handles or stores as part of its work. This includes obtaining and maintaining access to current Safety Data Sheets (SDSs) and ensuring chemicals are appropriately labelled where required.
The contractor also needs to consider how its cleaning activities interact with the wider workplace. Its workers should understand the hazards associated with the chemicals they use, follow the relevant control measures and comply with applicable site-specific procedures.
Why Both PCBUs Need to Coordinate?
Coordination matters because the contractor’s chemicals may interact with existing chemicals, substances or processes at the site, or create other risks depending on how and where they are used. Before starting work, a cleaning contractor should confirm what hazardous chemicals may be relevant to its activities, review site-specific chemical handling procedures and identify areas where its chemicals should not be stored or used.
This coordination helps each PCBU understand the risks created by its own activities and those of the other duty holder, rather than assuming the other party has managed the risk. Where PCBUs share duties for the same matter, they must consult, cooperate and coordinate their activities as required under the WHS framework.
What Hazardous Chemicals are Used in Industrial Cleaning?
Industrial cleaning involves several types of hazardous chemicals. Four common categories include degreasers, disinfectants and sanitising chemicals, strong alkaline or acidic cleaners, and solvents or specialist cleaning products. Each product has its own hazard profile, which is why a single generic handling approach is not suitable for every chemical.
Some of the common hazardous chemicals used in industrial cleaning are:
1. Degreasers
Degreasers are used to remove oil, grease and lubricant residue commonly found on manufacturing equipment, machinery and warehouse surfaces. Depending on the formulation, they may present flammability, skin or eye irritation, or other health hazards. The SDS provides information about the product’s specific hazards and the controls required for its safe use, including ventilation and PPE where applicable.
2. Disinfectants and Sanitising Chemicals
Disinfectants and sanitising chemicals are used to control microbial contamination on surfaces and equipment. Depending on the active ingredients and concentration, they may present corrosive, skin, eye or respiratory hazards, particularly at higher concentrations. Cleaning staff should follow the dilution requirements in the SDS and manufacturer instructions, as incorrect dilution can affect product performance and may increase exposure risks.
3. Strong Alkaline or Acidic Cleaners
Strong alkaline or acidic cleaners are used to remove heavy soil, mineral deposits and specific industrial residues that milder cleaning products may not effectively remove. Depending on the product, they may present corrosive hazards and require specific PPE, handling procedures and compatible containers.
Cleaning chemicals should not be mixed unless the manufacturer specifically states that they are compatible. Incompatible chemicals may react and create additional hazards, which is why appropriate storage and segregation are important parts of chemical risk management.
4. Solvents and Specialist Cleaning Chemicals
Solvents and specialist cleaning chemicals are used for specific industrial contamination, such as adhesive residue, coating removal or specialised equipment cleaning that standard cleaning products cannot effectively address. Depending on the formulation, these products may present flammability, vapour exposure, or inhalation hazards. Appropriate ventilation, safe handling procedures and controls around potential ignition sources may therefore be required.
How Should Hazardous Cleaning Chemicals Be Stored and Handled?
Hazardous cleaning chemicals need appropriate labelling and storage, safe handling practices including PPE, and controls to prevent unauthorised access and spills. These three areas work together. A weakness in one area can reduce the effectiveness of the other controls.
The hazardous cleaning chemicals can be stored and handled in the following ways:
- Labelling, Storage, and Segregation
- Safe Handling and PPE
- Access Control and Spill Prevention
1. Labelling, Storage, and Segregation
Hazardous chemical containers should have the required labelling, with information kept legible and accurate while the chemical is in use. Chemicals should be stored in their original containers where appropriate or in suitable containers that are correctly labelled.
Storage arrangements should also consider chemical compatibility. Incompatible substances should be appropriately segregated to reduce the risk of a hazardous reaction. For example, acidic and alkaline products should be stored according to their specific compatibility and storage requirements. Flammable cleaning solvents may also require controls to keep them away from ignition sources.
2. Safe Handling and PPE
Safe handling involves following the precautions identified in the product’s SDS and the site’s risk controls. PPE may include gloves, eye protection or respiratory protection, depending on the chemical, concentration, task and level of exposure risk.
Where a concentrated product requires dilution before use, cleaning staff should follow the dilution ratio specified by the manufacturer and SDS. Diluting or mixing chemicals without following the required instructions can reduce cleaning effectiveness and create avoidable exposure risks.
Access Control and Spill Prevention
Hazardous chemicals should be stored in locations that restrict access by people who are not authorised or appropriately trained to handle them. This is particularly important on shared industrial sites where other workers may pass through or work near areas used by the cleaning contractor.
Spill prevention starts with secure container closure and stable storage that reduces the risk of containers being knocked over or damaged. Appropriate spill response materials should also be available where required by the chemical’s hazards, the quantity stored and the site’s emergency procedures.
How Should Cleaning Contractors Manage Chemical Spills on Industrial Sites?
Chemical spill response should prioritise protecting people, controlling immediate exposure, following the site’s emergency procedures and the chemical’s SDS, and reporting or escalating the incident as required. The exact response depends on the chemical, the quantity involved, the level of exposure risk and the site’s emergency arrangements.
Cleaning contractors should manage chemical spills on industrial sites in the following ways:
- Immediate Response
- Following Procedure
- Reporting and Escalation
1. Immediate Response
The priority is to stop the task and assess the situation without putting anyone at further risk. Where it is safe to do so, identify the substance and assess the extent of the spill and whether anyone has been exposed or could be exposed.
People should be kept away from the affected area and further exposure prevented. If the spill can be safely contained using the controls and equipment available to trained workers, steps can be taken to prevent it from spreading. Workers should not attempt to clean up a spill when the substance is unknown, the exposure risk is significant, or the response is beyond their training and available controls.
2. Following Procedure
Once immediate exposure risks have been addressed, the response should follow the information provided in the spilled chemical’s SDS and the site’s emergency procedures. The SDS provides product-specific information about hazards, precautions and spill response.
The site’s emergency procedure may also set out requirements for alarms, evacuation, isolation of affected areas, notification and emergency contacts. Cleaning contractors need to understand these arrangements before starting work so they know how to respond if a chemical spill occurs.
3. Reporting and Escalation
The incident should be reported to the cleaning contractor’s management and the site’s designated contact in accordance with the applicable incident-reporting and emergency procedures. This allows the relevant duty holders to understand what occurred and determine whether further action is required.
Specialist assistance may be required when the spill involves a large or uncontrolled release, an unknown substance, significant exposure, a fire or reactivity risk, or a situation beyond the training, equipment and controls available to cleaning staff. Workers should not continue attempting to clean up a spill when doing so could increase the risk of exposure or injury.
How Does Chemical Handling Differ Across Industrial Sites?
The core principles of hazardous chemical management remain the same across industrial workplaces, but the risks and site-specific controls can differ. Manufacturing, warehousing and heavy industrial environments may have different chemical inventories, operational activities, site layouts and cleaning access requirements. A cleaning contractor therefore needs to consider the conditions of each workplace rather than applying the same site procedures everywhere.
Manufacturing and Processing Plants
Manufacturing and processing plants may have a wide range of process chemicals, depending on the production activities carried out on site. This makes coordination with the site’s chemical register, site procedures and existing risk controls particularly important before a cleaning contractor selects or uses its own products.
Production areas may also restrict when and where cleaning can occur. A contractor therefore needs to consider site operations when determining where chemicals can be stored and where cleaning products can be safely used during a shift.
Warehouses and Distribution Centres
Warehouses and distribution centres may not use hazardous chemicals as part of a manufacturing process, but they can store hazardous goods as inventory. A cleaning contractor should understand what hazardous chemicals or goods may be stored in areas where cleaning activities will take place and consider these risks when selecting storage and cleaning locations.
Large open floor areas can also affect spill response planning. Where a spill occurs, the site layout may provide a longer potential path for the substance to spread, making appropriate containment and emergency procedures important.
Heavy Industrial and Workshop Environments
Heavy industrial and workshop environments may involve oil, fuel, lubricants, dust and other residues from mechanical or industrial processes. These conditions can increase the use of degreasers and other cleaning products designed to remove industrial contamination.
These sites may also have designated areas for storing hazardous chemicals or other controlled materials. A cleaning contractor should identify these areas and understand the site’s storage, access and emergency procedures rather than assuming that cleaning chemicals can be stored wherever convenient.
What Are Common Hazardous Chemical Handling Mistakes in Industrial Cleaning?
The common hazardous chemical handling mistakes in industrial cleaning are:
- Skipping the Site Chemical Register Check
- Storing Incompatible Chemicals Together
- Skipping PPE Specified in the SDS
- Treating a Minor Spill as Routine
1. Skipping the Site Chemical Register Check
Starting a cleaning task without checking the hazardous chemicals relevant to the work can make it harder to identify potential incompatibility or exposure risks before work begins. This can happen under time pressure when a contractor treats every site as equivalent to the last one cleaned rather than confirming the specific chemical environment, site procedures and risks of the current workplace.
2. Storing Incompatible Chemicals Together
Storing incompatible chemicals together, such as certain acidic and alkaline products, or storing a flammable solvent near an ignition source, can increase the risk of a hazardous reaction or fire. Appropriate segregation reduces these risks and should be based on the specific chemical hazards and storage requirements.
Limited on-site storage space can contribute to poor chemical storage practices. This is why a cleaning contractor should confirm that suitable and appropriately segregated storage is available before bringing hazardous cleaning chemicals onto an industrial site.
3. Skipping PPE Specified in the SDS
Using inadequate PPE because a worker is familiar with a chemical can lead to overlooking changes in concentration, application method, exposure route, or working conditions. The SDS provides important information about the PPE and other precautions that may be required for a specific chemical, which should be considered alongside the task and the site’s risk controls.
Familiarity with a product is not the same as confirming that the same PPE and controls are suitable for how the chemical is being used on a particular site.
4. Treating a Minor Spill as Routine
Cleaning up a small spill without first assessing the situation can overlook risks associated with the chemical itself. Spill size is important, but the appropriate response also depends on the substance’s hazardous properties, potential exposure, site conditions and available controls.
A small amount of a highly hazardous chemical may require a more cautious response than a larger amount of a lower-hazard product. Cleaning staff should therefore follow the applicable SDS and site emergency procedures rather than deciding how to respond based on spill volume alone.
What Should a Facility Manager Look for in an Industrial Cleaning Contractor’s Chemical Compliance?
A facility manager should look for a contractor that maintains current SDSs for the hazardous chemicals it uses, understands the site’s chemical register and procedures, confirms site-specific chemical hazards before starting work, and can demonstrate a documented spill response process. A contractor should also be able to explain how it coordinates its chemical management practices with the site’s existing hazards and emergency arrangements.
A facility manager should look for the following standards in an industrial cleaning contractor:
- SDS and Chemical Register Management
- Site Coordination Process
- Staff Training and PPE Compliance
- Spill Response Readiness
SDS and Chemical Register Management
A contractor should maintain current SDSs for the hazardous chemicals it uses, handles or stores as part of its work and ensure they are readily accessible to the workers who need them. A facility manager can also ask how the contractor coordinates with the site’s hazardous chemical register and whether the relevant chemical information can be provided promptly when required.
The purpose is not simply to maintain paperwork. SDSs and chemical records need to be accessible and usable when workers are planning a task, responding to an incident or reviewing the controls required for a particular chemical.
Site Coordination Process
A contractor should have a defined process for confirming the hazardous chemicals, processes and site-specific procedures relevant to its cleaning activities before starting work at a new or unfamiliar industrial site. It should not assume that every industrial workplace presents the same chemical risks.
This coordination should be part of the contractor’s normal site mobilisation process rather than something only addressed when a facility manager specifically requests it.
Staff Training and PPE Compliance
Cleaning staff should understand the hazards associated with the chemicals they use, the required control measures and why particular PPE is appropriate for the task. A facility manager can ask how the contractor trains workers to interpret SDS information, follow chemical handling procedures and use the required PPE.
It is also reasonable to ask whether relevant training and competency records are documented and kept up to date.
Spill Response Readiness
A contractor should be able to clearly explain its chemical spill response process, including how it coordinates with the site’s emergency procedures rather than relying solely on its own internal protocol.
Appropriate spill response equipment and materials should be available based on the chemicals being used, the quantities involved, the work location and the site’s emergency arrangements. The contractor should also be able to explain when workers are expected to manage a spill themselves and when the situation needs to be escalated.
Chemical Compliance That Works With Your Site, Not Around It
Hazardous chemical handling on an industrial site depends on 2 businesses coordinating correctly, not one contractor operating in isolation from what’s already on-site. Cleanin brings its own SDS and chemical register management to every industrial site across Greater Sydney, confirming existing site hazards before work begins rather than after an issue arises.
Request an on-site assessment and quote to see how a coordinated chemical handling approach fits your facility.
