The safety, waste and key rules that apply on every cleaning site

Greymill AcademyUK6 min readReviewed Oct 202643 primary sourcesUS version

The short answer

There is no licence to clean in the UK, but chemicals, work at height, sharps, asbestos, waste and keys all carry rules, and an accident or a lost key is when you find out whether you followed them.

The takeaway. No licence to clean, but assess every chemical, avoid ladders where poles work, report injuries on time, register to carry waste, and log every key.

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Written for owners of UK cleaning businesses: contract cleaners for offices, schools, healthcare and soft FM subcontracts, domestic cleaning firms, agencies and apps, and specialists in after-builders, end-of-tenancy, window, carpet and biohazard cleaning.

The short version

  1. Assess every chemical before anyone uses it.Write a COSHH assessment for each product and task, keep the safety data sheet, and never mix chlorine bleach with acid descalers or ammonia.
  2. Use poles before ladders, and report injuries.Work at height rules have no minimum. If an injury keeps someone off over 7 days, report it within 15 days (As of Oct 2026).
  3. Register to carry waste and log keys.A client's waste in your van needs upper-tier waste carrier registration. Log every key. Lose one? Tell the client and insurer that day.

There is no general licence for a cleaning business. You register for the activities you actually carry out, such as payroll, VAT and CIS for builders' cleans, and check whether you owe the ICO fee. The rest is about the work itself: the chemicals you use, how you reach high places, what is in the bins, and whose keys and waste you carry.

Chemicals

The rule

COSHH

Write an assessment for each product and task before anyone uses it. Control the risk by substitution first, then dilution systems and PPE, and give information and training, with the supplier's safety data sheet on file.

Control of Substances Hazardous to Health Regulations 2002 regs 6, 7 and 12

Never mix chlorine bleach with acid descalers or ammonia: it releases toxic gas. Wet work and detergents cause dermatitis, so provide gloves and moisturiser and check skin.

Work at height

The rule

There is no 2 metre rule

The Work at Height Regulations 2005 apply wherever a fall could cause injury, with no minimum height. Avoid work at height where you can: water-fed poles from the ground before ladders, ladders only for short, low-risk tasks, and cradles or rope access only on systems the building owner maintains and inspects. A MEWP needs a thorough examination at least every 6 months, a rescue plan and trained operators. As of Oct 2026.

Work at Height Regulations 2005 reg 6; LOLER 1998 reg 9(3)

The rule

Reporting injuries

Report a death or specified injury without delay, and make sure the report is received within 10 days. An injury that keeps a cleaner off normal work for more than 7 days is reported within 15 days. Record over-3-day injuries. As of Oct 2026.

RIDDOR 2013 regs 4 and 6

AvoidLetting a window cleaner work off a ladder at 1.5 metres because harnesses are "only needed above 2 metres".
Do this insteadSwitching the round to water-fed poles from the ground, and keeping ladders for short, low-risk tasks.

There is no 2 metre threshold. A 1.5 metre fall that keeps a cleaner off work for 3 weeks is reportable under RIDDOR within 15 days, and your employers' liability insurer needs to hear about it.

Needles, asbestos and working alone

Needles in washroom bins and bags are the commonest serious hazard. Have a needlestick procedure, sharps bins, same-day occupational health referral, and hepatitis B vaccination where your risk assessment calls for it. On healthcare premises the Health and Safety (Sharp Instruments in Healthcare) Regulations 2013 bind you as the cleaners' employer; elsewhere COSHH covers biological agents.

  1. First aid.Encourage bleeding, wash and cover.
  2. The same day.Occupational health or A&E for a blood-borne virus assessment.
  3. Record and review.Record it, then review the COSHH assessment and the sharps procedure.
  4. Report if needed.Report under RIDDOR if the cleaner is off for more than 7 days or a reportable disease follows.

In non-domestic premises built before 2000, the client manages asbestos as dutyholder. Ask for the asbestos register before drilling, scraping old floor tiles, stripping floor finishes or entering ceiling voids, and stop and report any damage.

Night and lone cleaners need a lone working risk assessment and a check-in system, with emergency contacts for each site (Management of Health and Safety at Work Regulations 1999 reg 3).

Waste, keys and insurance

The rule

Waste duty of care

Describe the waste, hand it only to an authorised person, and keep waste transfer notes for 2 years. As of Oct 2026.

Environmental Protection Act 1990 s.34

Carrying a client's waste in your van, or any construction or demolition waste, needs upper-tier waste carrier registration with the Environment Agency in England, Natural Resources Wales, SEPA in Scotland or NIEA in Northern Ireland. Upper-tier registrations in England are currently renewed every 3 years, subject to the forthcoming regime; diarise the renewal date your own regulator gives. As of Oct 2026.

Holding keys so you can clean needs no licence; selling keyholding or alarm response as a service does, under the Private Security Industry Act 2001. Keep a key register, coded tags with no address, and signed issue and return. If a key is lost, tell the client and your insurer the same day: the keys extension on your policy is the first source of payment for a re-key.

Check your public liability too: damage caused by the cleaning itself, such as a bleached carpet, etched marble or a stripped floor finish, is often excluded. Buy the treatment risk extension, check its sub-limit, and set your keys cover limit to the worst master key system you hold.

A contractor you hand waste to who then fly-tips it can bring it back to you. Check their registration on the nation's waste carrier register before the first collection.

Asked in Greymill

Example question and answer from Rules & Licensing
You
One of my window cleaners fell off a ladder last week, about 1.5 metres up. Sprained wrist, doctor says three weeks off. Harnesses are only needed above 2 metres, so we're fine there. Do I still need to report it?
Rules & Licensing
Yes. Report it under RIDDOR within 15 days (As of Oct 2026). RIDDOR is the law on reporting injuries at work. An injury that keeps a cleaner off normal work for more than 7 days must be reported, and three weeks is well over.

There is no 2 metre rule. The Work at Height Regulations 2005 apply wherever a fall could cause injury, with no minimum height. A ladder at 1.5 metres was always covered.

This week:
1. Tell your employers' liability insurer about the fall.
2. Move the round to water-fed poles from the ground.
3. Keep ladders for short, low-risk tasks only.

From now on: record any injury that keeps a cleaner off work for more than 3 days (As of Oct 2026).

Say the word and I'll draw up a site checklist: chemicals, waste, keys and these reporting deadlines.

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Ask it about your own business

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Your question

I run a cleaning business in the UK. We clean [types of site, for example offices, gyms or a GP surgery] in [nation], use [main chemicals or products], and [do or do not] work at height, carry waste in our vans, or hold client keys. Give me a checklist of the assessments, registrations and procedures I need, with the reporting deadlines, and draft a COSHH assessment for [product and task].

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Sources

The primary sources behind this lesson, checked Oct 2026.

  1. regs 6, 7, 12 (Health and safety: chemicals, height, sharps and asbestos)
  2. HSE skin and cleaning guidance (Health and safety: chemicals, height, sharps and asbestos)
  3. regs 2, 6 (Health and safety: chemicals, height, sharps and asbestos)
  4. reg 9(3) (Health and safety: chemicals, height, sharps and asbestos)
  5. SI 2013/645 (Health and safety: chemicals, height, sharps and asbestos)
  6. reg 4(1), (5)(a) (Health and safety: chemicals, height, sharps and asbestos)
  7. s.34; Waste (England and Wales) Regulations 2011 (Registrations, waste, keys and data)
  8. Upper tier (Registrations, waste, keys and data)
  9. start date; SSI 2012/148 (Registrations, waste, keys and data)
  10. Sch 2 (Registrations, waste, keys and data)
  11. ICO monitoring workers; DPA 2018 Sch 1 (Registrations, waste, keys and data)
  12. EPR 2016 regs 12(1)(b), 38; Sch 21 para 3(1)(a); WIA 1991 s.118(1), (1A), (5) (Registrations, waste, keys and data)
  13. Uber [2021] UKSC 5; Autoclenz [2011] UKSC 41 (Hard cases: pay, tax, domestic and site)
  14. regs 30(b), 36, 39(1) (Hard cases: pay, tax, domestic and site)
  15. reg 16A (Hard cases: pay, tax, domestic and site)
  16. regs 4(2), 9(b) (Hard cases: pay, tax, domestic and site)
  17. WAHR 2005; RIDDOR reg 4 (Hard cases: pay, tax, domestic and site)
  18. Civil penalties (Hard cases: pay, tax, domestic and site)
  19. reg 3(2A); LGPS reg 64 (Hard cases: TUPE, CONTRACTS and TENDERS)
  20. Kimberley [2008] ICR 1030 (Hard cases: TUPE, CONTRACTS and TENDERS)
  21. s.73(1); SI 2024/716 reg 5(3), (4)(a) (Hard cases: TUPE, CONTRACTS and TENDERS)
  22. 2026-27 rates, announced 15 October 2026, implement by 1 May 2027 (Hard cases: TUPE, CONTRACTS and TENDERS)
  23. reg 36 (Hard cases: TUPE, CONTRACTS and TENDERS)
  24. Employment Rights Act 2025 Sch.12 para.13; SI 2026/954 reg.4 and Schedule table 2; TUPE reg.12(2) and (6) (Hard cases: TUPE, CONTRACTS and TENDERS)
  25. reg 11(6) (Who must sign off: time-critical steps first)
  26. reg 13(4) (Who must sign off: time-critical steps first)
  27. www.legislation.gov.uk (Who must sign off: time-critical steps first)
  28. s.51 (Who must sign off: time-critical steps first)
  29. s.15 (Who must sign off: time-critical steps first)
  30. regs 10 and 13 (Who must sign off: time-critical steps first)
  31. Reporting (Pay, TUPE, VAT and CIS dates)
  32. Current rates (Pay, TUPE, VAT and CIS dates)
  33. Deadlines (Pay, TUPE, VAT and CIS dates)
  34. Re-enrolment duties (Pay, TUPE, VAT and CIS dates)
  35. End of year (Pay, TUPE, VAT and CIS dates)
  36. reg 59 (Operations and software)
  37. reg 35 (Operations and software)
  38. Rynda (UK) Ltd v Rhijnsburger [2015] EWCA Civ 75 (Pitfalls that embarrass the product)
  39. reg 18 (Pitfalls that embarrass the product)
  40. reg 2 (definition of work at height) (Pitfalls that embarrass the product)
  41. s.3 (Pitfalls that embarrass the product)
  42. Gangmasters Licensing (Exclusions) Regulations 2013 Sch Part 1 para 3 (Pitfalls that embarrass the product)
  43. How much cover; Fines (Insurance and claims)

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