A Review of the IICRC Safety and Health Field Guide for Cleaners (Pt. 1)
By James (Lee) Senter
The IICRC is a standards writing organization and a certification body for the cleaning and restoration industries. The standards written by the IICRC are referred to as ANSI voluntary consensus standards for products, services, processes, systems, and personnel. These standards are procedural standards. They are not safety standards. ANSI has a different criterion for the development of procedural standards versus the development of safety standards. Because of this, the IICRC decided to develop safety and health field guides to supplement their existing standards. The same field guides are used as a reference for standards that are in development or are in the revision stage.
The Safety and Health Field Guides are not ANSI-approved. They are considered IICRC reference documents. The development of the field guides falls under the umbrella of the IICRC Standards Committee and follows a procedure similar to the manner in which our standards are developed. The field guide has been through a peer review. The document has also passed a double legal review.
There are two safety field guides being developed. The first document which was just completed and released for purchase is for the professional cleaner. This field guide is written to follow the general industry requirements of 29CFR1910 OSHA industrial regulations. A second safety field guide based on the construction regulations is being written for the restoration industry and is anticipated to be released in the summer of 2023.
The cleaners’ field guide was written for the following purpose according to chapter A2 of the guide: “to define safe work practices and outline the criteria of required safety plans that shall be used by cleaning companies and their personnel. The Guide will identify specific ideas on hazard identification and controls that should be used in establishing work plans and procedures.”
The field guide is written for the following entities according to chapter A3: This document is written primarily for cleaning companies and their personnel, and secondarily for other materially interested parties (MIPs).
Beginning an ongoing field guide series
This article is the first of a series that will help you navigate the field guide, and understand the principles behind hazard assessment and hazard controls. It is written by practitioners who actually provide professional cleaning services. It is not written by industrial hygienists. This is important because this field guide will help you develop the mandatory safety plans a company shall have and should be the driver for a cleaning company’s standard operating procedures.
Yes, I did say mandatory safety plans. At the bare minimum, all cleaning companies shall have a written hazard communication program, a respiratory protection plan, and a written exposure control plan.
In most circumstances, cleaning companies shall also have a fire protection plan and an emergency action plan. Both these plans should be written plans, but OSHA does allow an exemption for companies of 10 employees or less to have a verbal plan instead. The fines for not having such safety plans can run as high as $14,502.00 per offense.
The field guide will also help you develop standard operating procedures for your cleaning business by explaining the recordkeeping responsibilities of a company and how to access the safety statistics generated by this reporting specific to your business”˜ NAICS code.
The field guide will discuss at length the different ways of performing hazard assessments through written and certified hazard assessments, risk assessments, job hazard analyses, job safety analyses, and through accident and incident investigations.
Rethinking health and safety
I hope through reading this series of articles, I can change your paradigm of thinking on health and safety. When I was a professional cleaner, cleaning houses every day for decades, I never thought about safety. But here I am 44 years later, in severe pain almost every day of my life, as a result of a lack of safety protocols.
I was never ergonomically fit for a carpet cleaning wand, so I pushed a wand for decades in a bad position that has given me half a vertebrae near my neck and full-blown DDD (degenerative disc disease) in my lower back.
I was never taught hazard communication, so I used cleaning chemistries with no gloves. And I wonder why I have neuropathy!
I was never taught about the dangers of hazardous materials like asbestos, and I shudder to think about the number of times I sucked in fallen fire spray off of old ceiling deckings.
I hope you will read this series of articles on the health and safety field guides. It may save you and your employees some years of your life, and a better quality of life while you are at it.
It will improve your systems which may help you get better job-seeking candidates. It will probably bring down your workman’s compensation rates. And most importantly it will inspire job applicants to want to work for your company. A company that worries about their employees first over profits.
Yes, health and safety are way more than providing and donning PPE. As a matter of fact, at the end of this series of articles you will know and understand that in the world of health and safety, PPE is a means of last resort.
James (Lee) Senter is a technical specialist for Dry-It Corp in Richmond Hill, ON. Lee has been in the cleaning and restoration industry since 1978. He serves as the President of the CFCRA and the Chairperson of the IICRC Safety and Health Field Guides.