Whose Job Is HazCom When Your Crew Works in Someone Else’s Building?

Short answer: both of you, and the split is clean. You are responsible for the chemicals you bring and for training your own people on them. The host is responsible for telling you about the hazardous chemicals on their site that your crew could be exposed to. Under 29 CFR 1910.1200 neither duty cancels the other, and in practice the second one usually has to be asked for.

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Why this catches out cleaning crews and contractors

A janitorial crew, a mobile detailer, a maintenance contractor: the work happens somewhere else, every day, in a building somebody else runs. The instinct is that the building’s owner holds the paperwork. They hold theirs. Yours travels with your products.

The practical consequence is that the binder in your office is in the wrong place. What matters is whether the person actually using the degreaser at eleven at night, in a building with poor signal, can reach the sheet for it.

The split, plainly

Yours, always:

• A safety data sheet for every product your crew brings and uses.
• Labels on anything you decant — a spray bottle filled from a drum is a container you created, and it needs to say what is in it.
• Training your own employees on those products, and documenting that it happened.
• Your written HazCom program, covering how you do all of the above across sites.

Theirs:

• Telling you about hazardous chemicals their operations could expose your crew to.
• Their own labelling and their own employees’ training.

The part that goes wrong: nobody asks

The host's written program must say how it will give other employers on site access to safety data sheets (29 CFR 1910.1200(e)(2)), but in practice the information often has to be asked for. Both sides then assume the other has it covered.

Ask once, in writing, at the start of the contract: are there hazardous chemicals stored or used in the areas our crew works, and can we have the hazard information for them? Keep the reply. If there is no reply, keep the request — a documented question that went unanswered puts you in a completely different position from never having asked.

Unknown containers

Crews find things: an unlabelled drum in a back room, a decanted bottle by a sink. The rule that keeps people safe is simple and worth training into everyone — if it is not identified, treat it as hazardous and do not use, move or mix it. Report it to the host and to your own supervisor. Assuming an unlabelled container is harmless is exactly how an unknown chemical gets mixed or splashed.

What “reachable” actually means on a mobile crew

A sheet nobody can open at the moment they need it is not available in any sense that matters. For a crew moving between sites, that means the route to the sheet has to survive a basement with no signal and a phone belonging to whoever is on shift, not just the supervisor.

Whether you solve that with paper in each vehicle or something on a phone that works offline is your call. The test is the same either way: can the person holding the bottle read the sheet for it, tonight, where they are standing?

Frequently asked questions

If my crew works in a client's building, whose HazCom program applies?

Both. You are responsible for the chemicals you bring and for training your own employees on them. The host employer is responsible for informing you about hazardous chemicals your crew could be exposed to on their site. Neither duty cancels the other.

Do I have to carry safety data sheets to every job?

Your employees must be able to reach the sheets for the products they use during their shift. That does not have to mean paper in every van - it means reachable, by whatever route actually works when someone needs it, including with no signal.

Does the building owner have to give me their safety data sheets?

Under 29 CFR 1910.1200 a host employer must make hazard information available for chemicals their operations expose your workers to. In practice you often have to ask, and asking in writing is worth doing.

Who trains the workers on a shared site?

You train your own employees, on your own products and on any site hazards you have been told about. A host cannot discharge your training duty for you, and you cannot discharge theirs.

What if the client refuses to tell us what is stored on site?

Document the request and treat unknown containers as hazardous until identified. A written request that went unanswered is a materially different position from never having asked.