Chemical register for cleaning companies: from a binder in the storeroom to an emergency plan in your pocket
Ask a cleaning company where the chemical register is, and the answer is usually "in the binder in the storeroom". Then ask which chemicals are used in the building at Storgata 12, who has used chlorine in the last three months, and what the cleaner should do if she gets Virkon in her eyes, and the answer is three different places, if it exists at all.
It is not because companies do not care. It is because the requirements are spread across several regulations, and because a paper register only answers the first question. This article goes through what is actually required, and how a chemical register that is connected to the tasks and the buildings answers all three. We use CleanFlow as the example, because that is where we built it.
What the law requires
For Norwegian cleaning companies the requirements sit mainly in the regulation on the performance of work, with the Working Environment Act as the frame:
- Chemical register (chapter 2). The employer must keep a register with safety data sheets for all hazardous chemicals in use, and it must be available to the workers where the work is done. A binder in the storeroom is available to whoever is in the storeroom.
- Risk assessment and training (chapter 3). The employer must assess the risks of the chemicals and make sure workers are trained in safe use, protective equipment and first aid. The training must be documentable.
- Emergency preparedness. There must be procedures for what to do in a chemical accident, and they must be known to those doing the work.
- Exposure register (chapter 31). If you use chemicals that are carcinogenic, mutagenic or toxic to reproduction (CMR substances), you must keep a register of which workers have been exposed, and keep it for 60 years.
None of the requirements are new. What is new is that inspectors ask for the documentation, not the binder. "Show me which chemicals are used in this building, and who has been trained in them." A tidy set of safety data sheets in a storeroom twenty kilometres away does not help much then.
One register, not one per building
The first step is to keep the chemical register in one place, for the whole company. In CleanFlow it sits under Chemical register: each chemical with manufacturer, form, GHS hazard pictograms, hazard and precautionary statements, protective equipment, dosing, eco-labels and the safety data sheet as a PDF. The register keeps track of what otherwise slips: safety data sheets that have expired or lack an expiry date, risk assessments not done, CMR substances that need extra measures, and employees missing training.
The "Inspection report (PDF)" button produces the whole overview as one document. That is the answer to the inspector's first question, without searching.
Link the chemicals to the tasks, not to the buildings
This is the most important step, and what separates a digital chemical register from a digitised binder. Chemicals are not used in buildings. They are used in tasks. Chlorine is used in sanitary cleaning, Antibac in disinfection, Virkon in deep cleaning. A building has its chemicals because it has rooms with those tasks.
In CleanFlow you tick which chemicals are used in each task template, once, under the Task links tab. From then on the system works out which chemicals each building has: the rooms in the building have room types, the room types have tasks, and the tasks have chemicals.
The Chemicals tab on each building shows the result: a list of the chemicals in the building, with the task templates they come from. If the building gets a new room with a kitchen, the kitchen chemicals come in by themselves. If you switch from one product to another in the template, every building switches at once. Chemicals used in the building outside the templates, for example on a one-off job, are added by hand as extra chemicals.
The cleaner sees the same links on the task in the app: which chemicals the task uses, with hazard symbols and the safety data sheet one tap away. The register is available where the work is done, as the regulation requires.
Who has been in contact with what
The third question, who has been exposed to which chemicals, cannot be answered afterwards from a binder. It has to be logged as it happens.
CleanFlow does it in two ways. The first is automatic: when a task is checked out, the chemicals the task uses and the person who did it are logged. It is assumed contact derived from the task plan, not a measurement of actual consumption, but it gives a running picture of who works with what, per chemical and per building. The Usage tab shows it in total.
The second is the exposure register under the Exposure tab, for incidents: spills, splashes, inhalation, or work with CMR substances that must be recorded. Here the person, the chemical, the incident and the measures are recorded. Each person sees their own exposures, management sees all of them, and the register stays there for the 60 years the regulation requires.
The emergency plan builds itself, and sits in your pocket
Once the building knows which chemicals it has, the emergency plan can be generated from them. The Emergency plan tab on each building shows the emergency numbers, 113 and the Poison Information Centre, and for each chemical in the building the emergency procedures from the safety data sheet: first aid for skin contact, eye contact, inhalation and swallowing, and what to do in a spill.
The same plan is in the app, for the building the cleaner is standing in. The safety data sheets are stored on the phone, so the plan and the PDFs are available in the basement without coverage too. If someone gets Virkon in their eyes, the first aid and the number for the Poison Information Centre are two taps away, not in a binder in the storeroom.
Training before the task, not after the accident
The regulation requires that those who use hazardous chemicals have been trained. In practice that means the training must happen before the first shift, and it must be documentable per person.
In CleanFlow you create courses under Training, with text, images and questions, and employees take them in the browser or in the app. A course can be linked to task templates and set to block: tasks that require the course cannot then be started in the app until the course is completed. The cleaner sees "Complete training first" on the task, with a link straight to the course. The chemical can also be marked as requiring training, and the register shows how many employees are missing it.
So it connects: chlorine is linked to sanitary cleaning, sanitary cleaning requires the course in safe use of chlorine-based products, and a new cleaner cannot start the toilets before the course is done. The documentation writes itself.
Everything in the same app
The point of tying the chemical register to the tasks is that it ends up in the same tool the cleaner uses for everything else: today's tasks, deviations with photos, extra work, clock-in and chat with the team. The chemicals are not a separate app or a separate reference, they are part of the task. See the checklist for cleaning apps for what else the app should do.
Get started in an afternoon
- Enter the chemicals. Name, manufacturer and safety data sheet. The register reads the hazard symbols and statements, and flags what is missing.
- Tick per task template. Which chemicals are used in sanitary cleaning, deep cleaning, kitchens. The buildings get their overview automatically.
- Create one course per risk group. Chlorine-based products, disinfection, acids. Link to the task templates and switch on the block.
- Check the emergency plan on one building. Open it in the app, without coverage, and see that it works.
- Print the inspection report. Put it in the HSE binder, and write in the binder where the rest is.
Frequently asked questions
Do we need a chemical register if we only use ordinary cleaning products? Yes, for all chemicals with hazard labelling, and that covers most professional cleaning products. Products without hazard labelling can be included for completeness.
How long must the exposure register be kept? The register of workers exposed to carcinogenic, mutagenic or reproduction-toxic chemicals must be kept for at least 60 years.
Are the safety data sheets available without a connection? Yes. The emergency plan and the safety data sheets for the building are stored on the phone once the app has had coverage, and can be opened without it.
Want to see the chemical register linked to your plan? Read more about the chemical register in CleanFlow, or try it free for 14 days.