GN9.5: Embedding sustainability within cleaning services

Guidance Note purpose 

The purpose of this Guidance Note is to provide asset managers, property managers and facilities managers with guidance for incorporating sustainability into the procurement, implementation and on-going management of cleaning services. 

Context 

Incorporating sustainability within cleaning contracts involves the identification of environmental and social issues relating to cleaning activities and ensuring that they are adequately considered during the procurement of human resources and materials at all stages of the cleaning life cycle. 

Environmental issues could involve, for example, the selection and disposal of cleaning materials which may be hazardous to the environment. 

Social issues could involve, for example, ensuring that cleaning contractors have taken relevant precautions beyond merely checking Right to Work documents to ensure modern slavery risk is effectively managed. 

Importance 

The procurement of cleaning services without adequate due diligence, or with poor management of the cleaning contractor or service provider, has the potential to: 

  • Lead to significant environmental damage. 
  • Present a serious risk to human health and wellbeing. 

As cleaning services are subject to a range of regulations, alongside potentially damaging the reputational of both property and asset managers, non-compliance also introduces operational and financial risk through exposure to penalties and fines. 

Relevant environmental legislation relating to the incorporation of sustainability within cleaning contracts includes: 

  • Control of Substances Hazardous to Health (COSHH) Regulations SI 2002/2677. 
  • Regulation (EC) 1907/2006, on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH). 
  • UK Registration, Evaluation, Authorisation & Restriction of Chemical (REACH). 
  • REACH Enforcement Regulations SI 2008/285. 
  • Waste (England and Wales) Regulations SI 2011/988. 
  • Part 3 of the Environmental Protection Act 1990 [the main legislation relating to statutory nuisances]. 

Relevant social legislation to consider in in relation to the incorporation of sustainability within cleaning contracts includes: 

  • The Modern Slavery Act 2015. 

Responsibilities & Interests

The table below summarises the key activities associated with embedding sustainability within cleaning contracts, and highlights where asset managers, property managers and facilities managers are likely to have a responsibility or specific interest. 

  • AM - Asset Manager
  • PM - Property Manager
  • FM - Facilities Manager

1. Procurement practice  

Stakeholder:

2. Products 

Stakeholder:

3. Training 

Stakeholder:

4. Cleaning and environmental performance 

Stakeholder:

5. Ongoing monitoring 

Stakeholder:

6. Supply chain management 

Stakeholder:

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How to

Intro

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Property managers play a key role in embedding sustainability requirements within cleaning services, and, alongside facilities managers, checking that contractors are operating as intended.  Asset managers have an interest in ensuring that cleaning services comply with regulations alongside any additional requirements they may specify. 

The way in which sustainability is incorporated within cleaning contracts must be stringent, fair and comprehensive to enable the intended interpreted by cleaning contractors and service providers. However, there must also be flexibility for a property manager to take into account any additional requirements guidance or best practice specified by asset managers. 

The UK Cleaning Products Industry Association (UKCPI) have published a sustainable cleaning user guide, ‘How to Clean Green - UKCPI’ which describes best environmental practice with regard to sustainable cleaning.  

Embedding sustainability requirements within cleaning services involves the consideration of the following elements:  

1: Procurement practice

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The procurement stage provides the primary opportunity to influence the sustainability impacts of cleaning contracts. 

When agreeing the lease, sustainability issues should have been documented between the asset manager and its occupiers.  Relevant sustainability requirements can then be cascaded within cleaning services contracts to define and confirm acceptance of responsibilities. 

Due diligence and pre-screening questionnaires should include consideration of the requirements of the Modern Slavery Act.  As this Act acknowledges cleaning as a high-risk service in relation to modern slavery, it is important that full checks have been undertaken in contractor selection processes prior to instruction.  

A cleaning contractor should also support the right to collective bargaining and freedom of association and encourage ways of maintaining open dialogue with employees, for example, through employee forum meetings, employee ombudsmen, and channels for reporting concerns, with the option to do so anonymously. Appropriate whistleblowing channels should be available for cleaning personnel to report and ensure any issues raised are dealt with fairly, clearly, efficiently and appropriately, without fear of retaliation. 

Pre-screening should include checking whether cleaning sub-contractors have been convicted or had a notice served upon them for infringement of environmental legislation, with further investigation into the circumstances, accompanied by subsequent action, where necessary. 

Ideally, cleaning sub-contractors should be required to operate a certified Environmental Management System, or at least have a documented process for identifying and managing significant environmental and/or social sustainability aspects and impacts. 

It is important that property managers consider the development of specific clauses relating to sustainability for inclusion within cleaning contracts.  The information set out within this guidance note may be helpful in guiding the development of these clauses. 

While there are currently no set, standard sustainability clauses relating to cleaning contracts, property managers should consult a range of sources to develop relevant clauses that will drive continual improvement, and that are likely to be consistent with requirements set for cleaning contractors across the real estate sector.  This process may include: 

  • Engaging facilities managers within a property or asset manager’s wider supply chain. 
  • Reviewing experience with existing contractors. 
  • Peer-to-peer discussions with other property managers in open forums. 

2: Products

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Property managers should require and check that cleaning products comply with relevant third-party sustainability certification standards. 

The International Council of Chemical Associations’ (ICCA) Responsible Care Initiative demonstrates a chemical company’s commitment to sustainability which is also supported by the European Chemical Industry Council (CEFIC).  

Where possible and safe, cleaning service contracts should require that cleaning products should be diluted on site to reduce associated transport emissions and promote reuse of cleaning product containers. 

The International Association for Soaps, Detergents and Maintenance Products (A.I.S.E.) has developed a ‘Charter for Sustainable Cleaning’ across Europe and its logo can be found on all member organisations’ products.  

3: Training

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A cleaning contractor has the potential to influence a property’s sustainability performance, in particular in relation to energy and water consumption and waste generation. 

It is important that early and ongoing engagement with cleaning contractors is undertaken to raise awareness sustainability objectives and targets, and to confirm that employees receive appropriate training.   

Key aspects of awareness raising and training for cleaners relates to:  

  • The use of cleaning products to meet asset and property managers’ requirements, including spill kit training. 
  • The efficient and effective use of cleaning equipment 
  • The appropriate use of a property’s lighting, heating and air-conditioning resources. 
  • Appropriate cleaning procedures, particularly relating to COVID-19 protocols. 
  • Streamlined and prompt reporting of environmental incidents, for example, oil spills, fly-tipping, noise, odour and smoke. 
  • Appropriate use of pesticide and rodenticide, where necessary. 

Training and sustainability performance targets should be reviewed periodically to support maintenance of high standards.  Property and facilities managers should consider providing training material in other languages in addition English, to align with the demographics of the cleaning contractor’s personnel. 

4: Cleaning and environmental performance 

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The activities of cleaning contractors can have a significant impact on a building’s sustainability performance. 

Lighting, heating and air-conditioning (HVAC) 

In many properties, cleaning staff operate outside of normal office hours and consideration should be given to minimising the use of lighting and HVAC resources used by cleaning staff while they undertake their duties at these times.  

A property manager should liaise with both the asset manager and occupiers to discuss how cleaning schedules can be best managed and examine how they can be aligned to any sustainable waste, water or energy strategy.  

If cleaning staff operate outside of the main office hours, HVAC system controls should be adjusted to reflect the change in HVAC demand.  It may not be necessary to heat or ventilate a whole building if cleaning is isolated to certain areas and staff are cleaning in rooms for a limited period of time. 

In many buildings, lighting and HVAC often remain on much longer than is necessary. A good first step is to use inexpensive time controls to automatically switch off the heating at the end of a normal working day and ensure cleaning staff are trained to minimise their energy usage when working outside these hours.  

It may also be necessary to observe the working patterns of the cleaning staff and align their cleaning schedules to certain times of the day where energy savings can be made. 

COVID-19 

As part of arrangements to control COVID-19, more frequent cleaning along with increased use of single-use face coverings and personal protective equipment (PPE) will generate extra non-recyclable waste.  This waste type must be disposed of promptly and appropriately, and in line with the latest government guidelines. 

Cloth face coverings can be washed and re-used to prevent and reduce waste, and further opportunities to avoid waste and promote circularity in relation to cleaning products should be sought out and implemented where safe. 

5: Ongoing monioring

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Performance standards 

In order to ensure that high sustainability performance standards are achieved and maintained, it is important to review both the services provided and products used on a regular basis.  This review should be against a clear set of output-based KPIs, and undertaken as part of annual contract reviews.  

For cleaning, this could include, for example, number of spills of chemicals used in cleaning or the outcome of environmental audits relating to the labelling and storage of cleaning materials. 

Where standards are found to be lacking, property managers should work collaboratively with the service provider to establish the reason for under-performance.  This may relate to, for example, insufficient resourcing, training or communication.  Following the review, an improvement plan should be mutually agreed and implemented. 

Regulatory requirements 

Facilities Management should ensure there is a formal process in place to review changes in legislation and to ensure any applicable changes in legislations are included in contract renewals. 

6: Supply chain management

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As cleaning falls into a high-risk service category in respect of employment processes, checks should be undertaken routinely on the service provider. 

This should include checking that directly employed staff and, as far as possible, any other staff in the supply chain are offered a safe place to work where there is no bullying, harassment,  discrimination or unreasonable working conditions of any kind, fro example, unpaid work, excessive working hours.  The Property Manager has responsibility for ensuring that there are demonstrable policies and processes in place to ensure this. 

Related Guidance Notes

The following Guidance Notes contain related information: 

Additional Resources