CHAPTER 3: Green Cleaning Practices
Using environmentally friendly, less-toxic products is just one step in the process of setting up and implementing a successful green cleaning program. How the janitorial staff uses cleaning products and equipment also impacts the program's success.
The following section reviews OSHA guidelines that address worker safety and other federal guidelines that address waste storage and disposal, outlines green cleaning practices and their impacts on worker safety and the environment, and examines issues that arise when janitors practice specific cleaning activities.
How are Cleaning Products Misused and What Injuries Can Result?
Many cleaning products contain chemicals and other ingredients that, when mishandled and misapplied, can adversely affect human health. Data from the State of Washington show that 6 out of every 100 janitors have lost-time injuries every year. Injuries common to janitorial workers break down into the following categories:
According to the Washington data, each reported worker's compensation incident requiring medical attention took the worker off the job for an average of 18 hours. Medical costs averaged $375 per claim, while lost time for the worker and his/her supervisor were estimated at $240 per claim, making the total cost equal to $615 for each workers' compensation claim. In addition, workers' compensation premiums might increase if accidents are frequent.
- 40 percent of janitorial worker injuries involve eye irritation or burns
- 36 percent involve skin irritation or burns
- 12 percent involve breathing chemical fumes
Accidents can happen when workers are not properly taught how to complete their tasks safely or how to use equipment and products properly. Accidents also can happen when workers have been properly trained but are misusing equipment and cleaning products or hurrying to complete a job in the allotted time.
To decrease worker injuries, janitorial managers should identify janitorial products that pose a risk to their workers and learn how to find and test products that are safer alternatives. Janitorial managers also can show staff how to reduce the amount of chemicals they use in cleaning or change the way chemicals are applied-which are some ways of practicing pollution prevention.
Managers also must impress upon their staff the importance of wearing personal protective equipment such as gloves and goggles. Workers should be retrained periodically to re-emphasize the importance of proper procedure and safety practices. According to OSHA, if a worker is injured on the job, even if he/she has received proper training, the company or agency can still be liable for injuries and lost wage compensation.
How to Implement Green Cleaning Practices
One of the biggest roadblocks to setting up a green cleaning program may be human nature-it can be difficult to get people to change their fixed habits. Fortunately, implementing a green cleaning program does not have to mean a big change in how buildings are maintained and cleaned. In many cases, simple changes in products and practices can make a difference.
Keeping dirt out of the building is a low-effort and low-budget way to support green cleaning efforts. Building management can place a durable welcome mat at all entryways so occupants and visitors do not track dirt from outside into the lobby area and throughout the building. Double-door entryways or foyers can serve the same purpose, although it may mean more effort and expense to reconfigure a building entryway. Less soil in the building means less frequent or intense cleaning is necessary, which means janitors use less chemicals. Daily or spot vacuuming also cleans up dirt before it gets ground in and becomes harder to remove.
Janitorial managers should periodically reinforce initial staff training, to remind janitors about green cleaning practices. For example, janitors are taught, either in their training program or through reading the labels on cleaning products, how much cleaning product is needed to remove a particular stain. If training is not reinforced periodically, janitors may start to use more product than is necessary to clean a stain, thus wasting the product, or use products that are more hazardous or aggressive than is really required for the particular cleaning task at hand.
Switching from products with highly toxic ingredients to ones that are less hazardous is a pollution prevention technique that also protects workers. Some cleaning tasks may necessitate the use of hazardous chemical cleaning products because there are no effective substitutes. In these instances, the best pollution prevention strategy is to properly handle and apply the cleaning product, while ensuring the employee is using adequate personal protective equipment.
Special Issues: Specific Cleaning Practices
The following are examples of how to apply green cleaning principles to some everyday cleaning issues.
How to Use Disinfectants
When using disinfectants, janitors must select a product that works on the specific germs they are trying to get rid of, or select a broad-spectrum product that works on all of the germs they may encounter. Because of potential health risks and impacts on the environment, it makes sense to minimize the amount of disinfectant used. There are four ways to do this:
- Select the right product. Use a product that is registered by EPA and contains the specific ingredients needed to kill the germs with the efficiency required for the building r room use (i.e., day care, bathroom, food service). Using the wrong disinfectant wastes time and money and does not remove the germs.
- Plan how often to disinfect. Evaluate building traffic and identify the surfaces that people touch most often or that are most likely to be contaminated. An ultraviolet light can be used to reveal how soon germs reappear after cleaning and can help you schedule disinfection work accordingly. Also check disinfection guidelines published for each situation by EPA, the Centers for Disease Control, and other agencies.
- Control product mixing. Using overly-concentrated product may be reassuring, but this practice is seldom warranted as it just wastes chemicals. In addition, using the full strength product is more dangerous to the user and is prohibited by EPA and OSHA. Therefore, janitors must dilute disinfectants according to the manufacturer's directions.
- Use correct methods. Disinfectants need to be in contact with the germs they are intended to kill. That means the surface must be free of dirt, grease, and oil. Follow the label directions. Many disinfectants must be thoroughly applied and left in place for 10 minutes in order to be effective. Janitors may have to work in a new sequence to give cleaning products longer contact time with the surfaces. For example, the janitor can pre-clean the surfaces and apply the disinfectant throughout a restroom, empty the trash and refill paper dispensers, and then go back and rinse off the cleaner.
Restroom Cleaning Practices
The janitorial staff can keep restrooms clean and sanitary by following a two-level cleaning schedule-a combination of regular daily cleaning and weekly deep cleaning.
Regular Daily Cleaning:
Trash removal, surface cleaning, disinfection, and restocking supplies should occur daily in most commercial or office restrooms. Facilities in airports, restaurants, and other high-traffic sites may need more frequent touch-up cleaning and restocking of soap and paper supplies.
Routine cleaning involves removing trash and replacing can liners; refilling dispensers; dusting high surfaces; cleaning toilets and urinals with a non-acid bowl cleaner; cleaning showers with a non-acid soap remover; cleaning mirrors and other glass surfaces; cleaning walls, ceiling, partitions, doors, and light switches; disinfecting all surfaces and fixtures; and vacuuming and wet mopping with a cleaner/disinfectant.
Some products combine cleaning and disinfecting ingredients into one container. These combined products work well only on surfaces that are already relatively clean. For dirty surfaces, it is important to clean first, then apply a separate disinfectant.
Fairly mild products are available for daily restroom cleaning. Such products are reasonably safe to use and have little environmental impact. Check the supplier's directions, and mix the cleaning product with as much water as possible.
Deep cleaning in public restrooms usually needs to be done weekly. Deep cleaning also may be required when janitors are cleaning a restroom for the first time or when the restroom is particularly dirty. High-traffic restrooms, such as airport or restaurant restrooms, may need deep cleaning once a day, even if routine cleaning is done more frequently.
Some deep cleaning tasks require stronger chemical products to remove stubborn deposits or stains. Examples include removing graffiti, cleaning stained toilet bowls, and removing shower tile deposits. In addition, janitors may need to spend more time removing soil with brushes and scrub pads.
Hard Floor Cleaning Strippers:
Hard floor care involves one of the most dangerous chemical products that janitors use-floor finish stripper. Stripper usually comes in two forms: a liquid concentrate for stripping large floor areas, and a ready-to-use aerosol for removing floor finish from baseboards. Both of these strippers contain chemicals that can seriously harm the user and also might affect building occupants and the environment.
Reducing stripper use is a good idea, for safety and financial reasons. Floor stripping takes a great deal of time, so labor is expensive. Stripping should be performed only when needed, and should be performed correctly so no time or chemicals are wasted. Building occupants can cut back on the stripping the janitorial staff needs to do by keeping abrasive dirt particles from reaching the floor in the first place.
Another way to reduce stripper use is to carefully monitor the floor refinishing work. Strip floor finish only when needed. Keep track of the floors and refinish only those areas where the surface is wearing out. With good records, a building manager will spot patterns in the way floors are wearing.
Additional reduction in floor stripper use comes from training janitorial staff how to refinish floors correctly and how to refresh them with buffing and cleaning between refinish jobs. Following set procedures ensures that the stripper will work properly and reduce the amount of restripping required.
Janitors also should not use the same mop to apply stripper and floor finish. It is a good idea to use some sort of method, perhaps painting the mop handles in two different colors, so that the mops are distinguishable from each other.
Most carpet care products are relatively safe to use and have only a small impact on the environment. However, some products contain toxic chemicals that are harmful both to the janitor who uses them and to people who occupy the building. Janitors should use the mildest products available that work effectively.
Stain prevention techniques, such as prohibiting occupants from eating or drinking in their individual offices, also will lessen the amount of stains resulting from food and beverage spills.
Minimizing Product Use
Using less of a cleaning product in the first place reduces both pollution and waste and is the hallmark of a green cleaning program. Activities such as diluting chemicals and using as little of a chemical cleaner as possible reduce the amount of product used, thereby minimizing emissions, spills, and health and safety hazards. For example, as overviewed in the previous subsection, using less floor stripper-one of the most toxic chemical products janitors use-is a good way to prevent pollution. Janitors can reduce the amount of floor stripper they use by 50 percent by:
Janitors can reduce acid toilet bowl cleaner use by using two toilet bowl cleaners-a mild product for daily cleaning and then an acid cleaner only when necessary. Adopting this strategy could potentially decrease hazardous materials usage by 1.8 pounds per user per year.
- Scheduling floor renewal work according to wear patterns rather than following a strict cleaning calendar.
- Diluting stripper with as much water as possible while still maintaining the effectiveness of the product.
- Carefully and thoroughly applying the diluted stripper, by using a rotating pad scrubber wherever possible.
- Thoroughly rinsing the newly stripped floor to neutralize the surface before applying the new floor finish.
Building management also can help janitors reduce the amount of room deodorizers that they use in areas such as restrooms by making sure that the plumbing system is in good working condition. Improperly sealed toilet fixtures can be the source of malodors, rather than improper cleaning. In addition, as a general rule, the more fresh air that enters a building, the better the state of the air in that building. Fans can circulate air throughout the building and lessen reliance on chemical deodorizers.
Janitors and office occupants also can minimize the use of carpet cleaners by reacting immediately to spills and spots before they have time to become permanent stains. Cleansing should start with blotting cold water on the spot, moving on to the chemical cleaning products only if necessary.
In some cases, for example, when the stain is still "fresh," blotting the stain with plain water may be just as effective in removing the stain as applying a chemical cleaner. The building occupants, rather than janitor staff, might be best poised to clean up stains in this manner, because they are likely the ones who caused the stain and thus can attempt to clean it before it dries. Building management should educate building occupants about their responsibility in this regard.
When performing maintenance cleaning, janitors should use as little of the cleaning product as possible to effectively clean the area. When using deep-cleaning products, janitors should carefully apply a minimal amount of the product and give it time to work rather than adding more product. Teaching janitors the correct method of using the cleaning products can conserve products, reduce toxicity, and save money over the long term.
Match the Product with the Need
An important element of green cleaning programs is to make sure that janitors match the cleaner they are using to the job they are performing. Using an overly strong chemical product to clean a mild stain is overkill: it not only wastes the chemical cleaning product, but it also exposes the janitor to an unnecessary risk. Janitorial managers also should give guidance to their staff on conditions in which they should use less harsh or no chemical cleaners, at least initially.
Janitorial staff also should be trained on the proper personal protective equipment and cleaning equipment to use in a specific job. The next two subsections address when and how janitorial employees should use personal protective safety equipment and cleaning tools.
Personal Protective Equipment
Compliance with relevant OSHA regulations is a key component of green cleaning programs. According to OSHA regulations, workers must use personal protective equipment (PPE) for the eyes, face, head, and extremities; protective clothing; respiratory devices; and protective shields and barriers, when they are using hazardous chemical materials. PPE used by janitors could include goggles or other types of face guards; gloves (made of a material appropriate for the task); long-sleeved shirts and long pants; hats; and respirators, among other equipment.
Employers must assess the workplace to determine if hazards are present that necessitate the use of PPE. If such hazards are present, the employer must:
Employers must train each employee how to use PPE. Each employee must learn when and what PPE is necessary for a particular job; how to properly wear PPE; the limitations of the PPE they are using; and the proper care and maintenance for the PPE.
- Select and require employees to use the PPE that will protect them from the hazards
- Communicate these selection decisions to each employee
- Select PPE that properly fits each employee
- Monitor and enforce PPE use
Employers must ensure that workers use appropriate PPE at all times in conditions where its use is warranted. Employers must emphasize to employees that requirements specifying use of PPE are for their own safety. If a worker is not using PPE and is injured on the job, the employer will likely be held liable for any injuries. Therefore, managers must make sure workers are wearing the appropriate equipment and that those workers who fail to wear their PPE are reprimanded and corrected.
If workers have complaints about PPE, such as the equipment does not fit properly or is hindering their ability to perform their jobs, management must address the complaint and either supply the worker with new, better-fitting equipment, or correct the workers' technique so PPE use is not a job hindrance.
OSHA regulations state that employers must make sure that each employee uses appropriate eye or face protection, such as goggles, when exposed to eye or face hazards from liquid chemicals, acids or caustic liquids, chemical gases, or vapors.
In case of accidental chemical spills into the eyes, eye-wash solution must be available within 10 seconds from where a janitor is located at any time. Because janitorial work involves moving around a whole office, and janitors may not always be located close to the eye wash station, janitors should keep a container filled with eye wash solution on their carts that is easily accessible in case of accidental exposure to toxic chemicals. The container should be instantly distinguishable from other liquid containers on the cart and must be equipped to dispense a constant stream of solution into the eye as the janitor moves toward the eye wash station. Managers should train their staff how to use eye wash solution, emphasizing that using the solution immediately after chemicals contaminate the eyes is the best way to prevent permanent damage from chemical exposure.
OSHA requires employers to provide respirators when necessary to protect the employee's health. Employers must set up and maintain a respiratory protection program that includes worksite-specific procedures and training on how to properly use and maintain the respirator. If janitors need to use a respirator to complete a task, they need to undergo a medical evaluation.
OSHA states that employers must require employees to use hand protection when employees' hands are exposed to hazards, such as those from skin absorption of harmful substances, chemical or thermal burns, and harmful temperature extremes.
Employers must select hand protection equipment that is appropriate to the task, conditions present, duration of use, and the hazards and potential hazards identified. For example, nitrile gloves may be more appropriate to protect hands from liquid chemicals when the janitor is cleaning bathrooms, while plain latex or rubber gloves may not provide an effective barrier due to the chemical properties of the product. Check with the cleaning product manufacturer to determine the appropriate type of glove to use (canvas or leather gloves may be more appropriate when the janitor is unloading materials from waste receptacles).
Janitors should wear sturdy leather or canvas gloves whenever they are emptying garbage receptacles or otherwise handling waste materials. Gloves made from a heavy, durable material will protect the workers' hands from toxins if the garbage is contaminated with dangerous waste materials (such as broken glass and improperly discarded medical supplies and needles). Even in a seemingly benign office setting, janitorial workers should perform their jobs assuming that they have a chance of encountering hazardous materials in unexpected places.
Under OSHA regulations, employers are responsible for maintaining the safe condition of all tools and equipment used by employees, including tools and equipment that employees furnish for themselves. OSHA standards do not apply specifically to other equipment frequently used by janitorial staff, such as mops and brooms, buckets, push carts, and other equipment, but OSHA requires that the employer make sure all of this equipment is in good working condition.
Electrical equipment used by janitorial staff includes floor waxers and polishers, hard floor strippers, vacuum cleaners, and other equipment. OSHA requires that electrical equipment be free from recognized hazards that could cause serious physical harm or death to employees, such as frayed or exposed wires or faulty on/off switches.
All electrical equipment must be durable and in good working condition and equipment should be used for purposes identified and recommended by the manufacturer or supplier.
How the equipment is used on a daily basis affects green cleaning practices. For example, vacuuming and cleaning up dirt and particles as they appear can reduce the need for harsh cleaning products use over time. It also makes sense to purchase and use a vacuum cleaner that is strong enough to withstand frequent use.
In general, janitorial managers should choose cleaning equipment that is:
New state-of-the-art-cleaning equipment can make janitorial cleaning tasks easier while also reducing indoor air pollutants. For example, the DOI green janitorial contract requires the selection and use of specific equipment, including vacuums with a high-efficiency particulate air (HEPA) filter, capable of trapping 99.97 percent of all airborne particles. This reduction in airborne particles decreases the movement of allergens throughout the building. Vacuums also can replace dust mops, which often just move dust and dirt around rather than removing it.
- Durable-equipment that lasts longer and needs replacement less frequently will not be an additional burden on the waste stream.
- Energy efficient-using equipment that saves energy is another way of promoting conservation.
- Quiet-reducing noise pollution means a healthier environment for the janitorial staff.
Another product that works well for deep cleaning in bathrooms or other areas of the office that have tile floors is a medium-pressure washer/vacuum. These products manufactured by Kaivak or Nobel, release a water and chemical mixture that can clean tile floors and then suction the chemical mixture to keep toxic products from being left on the floor.
When selecting air freshener systems, managers should use the same criteria in selecting the product as any other cleaning product-environmentally preferable and chemically benign. The product should utilize either a battery-operated pump, or involve an automated drip or flush system.
Janitors also should avoid using aerosol spray canisters. The CFCs released from these canisters are not resource-efficient because they are difficult to recycle. In addition, the propellants are flammable and can be harmful to the environment, and janitors also have little control over where the product is released. Foaming sprayers and trigger sprayers give janitors better control over where the product is released and also release less of the product than aerosol sprayers. In addition, there are some instances in which janitors should use a product apportioner or mixer that ensures that the proper amount of any given chemical is dispensed. Managers should determine what chemical products should be dispensed using such a mechanism to avoid problems with mixing incompatibility and spills.
Janitorial managers also can contract with a company that will wash the cloth rags that the janitors use to apply cleaning solutions. That way, the janitors will not have to use disposable rags, and this will decrease the amount of hazardous waste that they have to handle.
Because product suppliers might be involved in training management and janitorial staff on how to properly use the equipment, consideration should be given to their training ability and their expertise with green janitorial products and cleaning, in addition to price and other traditional considerations.
Equipment maintenance also aids waste reduction efforts, as equipment that is properly cared for will break down less often and last longer. Janitors must heed manufacturers' directions when using equipment and tell supervisors when equipment shows signs of malfunctioning. Replacing equipment parts is less expensive-and less wasteful-than replacing an entire piece of equipment. Cleaning and storing equipment properly also will add to the equipment's life span.
OSHA requires cleaning product suppliers to tell employers about any hazards associated with the chemical mixtures used in janitorial work under the so-called "Hazard Communication Standard" or "Worker Right-to-Know" regulations. Employers are responsible for educating their employees about these hazards. Information sharing can take place through container labeling and other forms of warning, Material Safety Data Sheets (MSDSs), and formal employee training programs.
Janitors can carry their MSDSs in their supply carts and should be taught how and when to consult them when the need arises. The MSDSs also should be kept in an on-site storage area that the janitors can access. For illiterate or foreign-language-speaking employees, the information in the MSDSs can be translated into pictoral format or the foreign language for easier comprehension.
OSHA also outlines labeling requirements for hazardous materials. Labels must identify hazardous chemicals contained in mixtures and include written warnings, pictures, or symbols on the chemical hazards. Additionally, chemical suppliers or employers that find out any significant, new information on a chemical being used must revise the chemical's labels within 3 months, and employers must alert their employees of the new hazard.
Labels also must include instructions on how to safely handle the chemical product, including appropriate hygienic practices, protective measures janitors should take when repairing contaminated equipment, and procedures for cleaning spills and leaks.
Under OSHA's regulations, employers must educate employees about the hazardous chemicals and equipment they are using at the time of their initial assignment and also whenever they begin using a new, potentially hazardous, chemical or piece of equipment. Information and training can cover categories of hazards (e.g., flammability, carcinogenicity) or focus on specific chemicals. Chemical-specific information must always be available through labels on the products themselves and MSDSs.
OSHA requires employee training to include at least the following:
Janitor training should include information on how to minimize the amount of chemicals used for any cleaning job, how to safely mix and store the chemicals, and when product substitution and maintenance cleaning can reduce the amount of chemicals needed in a particular task. More detail on each of these ideas is included in previous sections of this chapter.
- How to detect the presence or release of a hazardous chemical in the work area.
- The physical and health hazards of the chemicals in the work area.
- How employees can protect themselves from these hazards. This includes specific procedures that the employer has set up to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used.
- The company's hazard communication program, including an explanation of the labeling system and the MSDS, and how employees can get and use the appropriate hazard educational information.
Green Seal also requires that the product manufacturer, its distributor, or a third-party offer training or training materials on the proper use of the product. This training should include step-by-step instructions for the proper dilution, use, disposal, and the use of equipment. Manufacturers also should put in place product labeling systems to assist non-English-speaking or illiterate personnel and to aid employees with limited comprehension skills or mental disabilities. These labeling systems can include bilingual translations and the use of symbols, such as a "skull and crossbones" emblem to indicate that a product is toxic or hazardous, along with an explanation in the worker-training program telling what the symbols mean.
Green Seal also requires that the manufacturers' label states clearly and prominently that dilution with water from the cold tap is recommended and should also state the recommended level of dilution for each product. The manufacturer also should include detailed instructions for proper use and disposal and whether the janitorial staff should use PPE when using the product.
Janitorial managers also must determine if their janitors need to receive training on how to handle bloodborne pathogens and medical supplies. OSHA does not generally consider maintenance personnel and janitorial staff employed in non-health care facilities to have occupational exposure; it is the employer's responsibility to determine which job classifications or specific tasks and procedures involve occupational exposure. For example, OSHA expects products such as discarded sanitary napkins to be discarded into waste containers lined in such a way as to prevent the janitor's contact with the contents. Overall, it is up to the management to determine what conditions the employees work under and the training they will need.
Select OSHA Training Requirements
|OSHA Standard Summary of Training Required
||Frequency of Training
||Training requirements apply to all employees who may come in contact with hazardous materials at work. Employee must be trained on the potential health effects of the materials, the steps they can take to protect themselves (such as wearing PPE), and how to identify the hazard. Employees must also be trained on methods for safe handling of materials:
||Before initial assignment, when a new hazardous material is introduced, and as frequently thereafter as required to ensure understanding.|
|Personal Protective Equipment (PPE)
||Training requirements apply to all employees who wear personal protective gear. Employers must train employees to know which PPE to use and when to use it, how to correctly wear PPE, the limitations of the equipment, the proper care of PPE, and how to identify problems with the equipment (for example, checking for holes in a glove before putting it on). Training must be documented in writing.||The employer must provide training to any employee who wears PPE. Retraining is required when changes occur or if the employee does not retain adequate understanding.|
Training requirements apply only to employees who wear respirators (even if the use is voluntary). Employers must train any employees who wear respiratory protection on how to choose the correct respirator, the limitations of respirators, and how to clean, maintain and store respirators. Additionally, OSHA requires employees who wear respirators to be medically qualified to do so.
|Training required at least annually.
||Training requirements apply only to employees who are reasonably anticipated to come in contact with blood or other potentially infectious materials, primarily in medical facilities. OSHA does not generally consider discarded feminine hygiene products to fall within the definition of regulated waste. OSHA does expect such products to be discarded into waste containers, which are properly lined with plastic or wax paper bags. Such bags should protect the employees from physical contact with the contents. If employees can come in contact with blood or other potentially infectious materials at work, they must be trained on the transmission of bloodborne diseases, PPE, how to handle incidents, and signs and labels.||Employees must receive training initially. Employees that have been trained within the last year need only be trained on items not previously covered.
Training requirements apply to employees who perform housekeeping operations in an area containing materials made with asbestos. These employees must be trained on the health effects of asbestos, where asbestos is in the building and how to recognize it, and what to do if fibers are released. Employees must also be trained on special housekeeping requirements for cleaning if asbestos debris are present and on caring for floors that contain asbestos.
|Training must be provided on initial assignment and at least annually thereafter.
OSHA does not specify required training time (hours) under these standards. OSHA does require that the training be effective and that the employees understand and retain information, and that employees are retrained as necessary when circumstances change and to ensure continued understanding.
Product Application, Handling, Storage, and Disposal
A green cleaning program can feature a host of alternative methods of applying and handling cleaning products and equipment. For example, in a green cleaning program, when floors and carpets need to be sprayed, buffed, or spot-cleaned, solutions should be applied from a sprayer in a stream, instead of a fine mist. This will minimize the amount of material atomized and potentially inhaled and reduce over-application.
When floors and carpets need to be stripped, recoated, or extracted, management should notify the building occupants ahead of time. Janitorial staff should conduct major cleaning activities like these during the weekend or other extended times when the building is unoccupied. This provides enough time for the building to be ventilated prior to the return of the occupants.
Building management also must determine if there is asbestos materials on the property that the janitors are cleaning and whether the janitors work in the same vicinity as the asbestos. Janitorial supervisors are required to tell their staff where any asbestos is located and its condition. Janitors should take precautions to avoid disturbing the asbestos so that it is not distributed into the air.
Product Storage Issues
OSHA limits the amount of flammable materials that can be stored in one location, though most janitorial storage cabinets probably would not exceed these limitations. OSHA's standards on container storage apply only to the storage of flammable or combustible liquids in drums or other containers that do not exceed a 60 gallon individual capacity.
OSHA also has issued the following requirements for storage rooms used to hold flammable or combustible materials:
Similar standards hold for flammable material storage cabinets or lockers as well. OSHA's standard limits the amount of materials that can be stored in one area and states that storage cabinets must be fire-resistant. The standard outlines requirements for both metal and wooden cabinets.
- The room must be fire-resistant. The room must be separated from other areas of the building by walls, and the room must have a fire rating of at least 1 hour.
- Each storage room must include a ventilation system (passive or active). If an active or mechanical exhaust system is used, it must be controlled by a switch located outside of the door, and ventilating equipment and any lighting fixtures must operate from the same switch.
- If Class I flammable liquids are stored in the room, a pilot light must be installed next to the switch.
- There must be at least one clear aisle at least 3 feet wide in the room.
- Containers more than 30-gallon capacity may not be stacked upon each other.
The National Fire Prevention Association (NFPA) has a rating system for identifying hazardous chemical materials. The system is characterized by the "diamond shape" placard that identifies the hazards of a material and the degree of severity of the health, flammability, and instability hazards. Hazard severity is indicated by a numerical rating that ranges from zero, indicating a minimal hazard, to 4, indicating a severe hazard. The hazards are arranged as follows: health at nine o'clock position, flammability at twelve o'clock position, and instability at three o'clock position. In addition to the spatial orientation that can be used to distinguish the hazards, they also are color-coded as follows: blue for health, red for flammability, and yellow for instability.
For more information, visit NFPA's Web site at www.nfpa.org.
RCRA requires certain practices for storing and managing hazardous waste. First management needs to determine whether they may potentially "generate" a "hazardous waste" as it is defined by RCRA. Once an organization determines it may generate a regulated hazardous waste, the organization must determine its generator category (which is based on the amount of waste generated per month). Most office buildings would fall into the Conditionally Exempt Small Quantity Generator (CESQG) or Small Quantity Generator (SQG) categories.
A CESQG generates no more than 220 pounds per month of hazardous waste. A SQG generates between 220 pounds and 2,200 pounds per month of hazardous waste. To remain exempt from full hazardous waste regulations that apply to Small and Large-Quantity Generators, CESQGs must accurately identify the hazardous wastes they are generating, comply with storage quantity limits, and ensure proper disposal and treatment of waste. Consider liquids to weigh comparable to water at 7.3 pounds per gallon.
SQGs, and some CESQGs, need to obtain an EPA Identification Number. EPA and states use these 12-character numbers to monitor and track hazardous waste activities. Organizations must use the identification number when they send waste off-site to be managed. To obtain an identification number, companies should contact their state hazardous waste management agency or EPA Regional Office and ask for a copy of EPA Form 8700-12, "Notification of Hazardous Waste Activity," and complete and return the form.
The following techniques can make chemical storage safer, while also reducing the amounts of hazardous materials lost through discards and spills:
Cleaning products that are routinely stored in the office building must be kept in a well-ventilated area, and the storage containers themselves must be clearly marked to indicate their materials. The containers themselves should be in good condition, without any holes or tears, and lids should be tight fitting or sealed shut. Signage on the storage room door should indicate if the materials housed in the room are toxic or otherwise hazardous to human health and the environment. Building managers must make sure that they are complying with all local laws governing storage of potentially hazardous materials and should inform the building occupants in writing what and where materials are being stored.
- Store products with incompatible ingredients separately from on another. For example, janitors should store glass cleaner containing ammonia apart from tub and tile cleaner, which contains bleach.
- If space is available, store products with acid or other strong ingredients in plastic tubs or containers so leaks will not harm the storage rack or janitor's closet or result in a discharge to the sewer system.
- Rotate the stock of stored products so the oldest ones are used first. Some janitorial products (i.e., bleach) have a specified shelf life. The purpose is to use up all products before their expiration date.
Waste Disposal Issues
RCRA outlines management and disposal requirements for hazardous waste generators. To determine whether RCRA regulations are applicable, building managers first need to figure out whether the used cleaning products being disposed of by the janitorial staff are hazardous under the RCRA definition. EPA has published two handbooks for small businesses, "Understanding the Hazardous Waste Rules" and "RCRA: Reducing Risk from Waste," which provide detailed guidance on this issue. Copies can be ordered through the RCRA Hotline, at 800 424-9346 or TDD 800 533-7672.
According to RCRA, waste is considered hazardous if it appears on one of four lists published by EPA. Currently, more than 400 wastes are on this list. If the waste being generated does not appear on this list, it might still be hazardous if it exhibits one of the following characteristics, which can be determined through testing or knowledge of the waste:
Once a generator has determined that it generates hazardous waste as defined by RCRA, the company must follow a number of requirements, including:
- It is an ignitable waste - It catches fire under certain conditions. In green cleaning programs, the preference is to use products that have a high flashpoint compared to those with a low flashpoint.
- It corrodes metals or has a very high or low pH. In green cleaning programs, the preference is to use products with a neutral pH (closer to 7) as compared to those with extreme pH (closer to 1 or 14).
- It is a reactive waste - It is unstable, explodes, or produces toxic fumes, gases, and vapors when mixed with water or under other conditions such as heat or pressure. Material Safety Data Sheets should list what chemicals in cleaning products react with other chemicals, or even non-chemicals such as water.
- It is a toxic waste - It is harmful or fatal when ingested or absorbed, or it leaches toxic chemicals into the soil.
RCRA also requires hazardous waste generators to develop a program to reduce the quantity and toxicity of the waste. The proposed method of treating, storing, or disposing of the waste must be the best method currently available to the generator to minimize the present and future threat to human health and the environment.
- Keeping records on quantities and types of hazardous waste being generated.
- Labeling containers used to store, transport, or dispose of hazardous waste.
- Using appropriate containers for holding hazardous waste.
- Providing information on the chemicals in the hazardous waste to the waste hauler.
- Tracking hazardous waste generated to ensure it is disposed of safely.
For more information about hazardous waste management requirements, contact the RCRA Hotline, at 800 424-9346 or TDD 800 553-7672.