Working Alone Procedures for Night Cleaning Crews in BC
A cleaner who works alone in a building after hours is working alone or in isolation under British Columbia’s Occupational Health and Safety Regulation. The employer must identify the hazards before assigning the shift, put a written check-in procedure in place, designate a named person to make contact at set intervals and record each one, include a check at the end of the shift, and review the procedure at least once a year. Sections 4.20.1 to 4.23 set this out.
Why a night cleaner usually qualifies
The test is not whether the worker is physically by themselves. Section 4.20.1 asks whether assistance would be readily available in an emergency, or if the worker is injured or in ill health. A cleaner on the eleventh floor of a tower with a guard in the lobby may still qualify, depending on whether the guard would notice their absence and knows which floor they are on. A building with a security desk is not automatically compliant, and one without is not automatically in breach.
One point is widely misstated. Section 4.22.1 imposes detailed obligations on lone workers in late-night retail premises, including time-lock safes and personal emergency transmitters, but it applies to gas stations, convenience stores and similar premises open to the public between 11 p.m. and 6 a.m. It does not cover janitorial work in a closed building. For a cleaning crew, apply the general scheme in 4.20.1 to 4.23, plus the violence provisions in 4.27 to 4.31 where a risk is identified.
| Section | Requirement |
|---|---|
| 4.20.1 | Working alone means working where assistance would not be readily available in an emergency, or if the worker is injured or ill. |
| 4.20.2 | Identify the hazards before the assignment. Eliminate each one, and where elimination is not practicable, minimize the risk to the lowest level practicable. |
| 4.21 | Put the check-in procedure in writing. State the interval, name the person who checks, record each check, say what happens if the worker cannot be reached, including emergency rescue, and check again at the end of the shift. Develop the procedure with the joint committee or worker representative, and the intervals with the worker. |
| 4.22 | Train both the worker and the person checking on them in the procedure. |
| 4.23 | Review at least annually, and sooner if the work environment changes or if it is reported as not working. |
- 1. Assess each building separately. Record the floors covered, the equipment and chemicals carried, where mobile reception fails, what a security presence would actually notice, and how emergency services would reach the worker.
- 2. Eliminate before you control. Two cleaners remove the obligation entirely. Moving parkade pressure washing to a Saturday daytime slot removes the hazard rather than managing it. The Regulation requires elimination first, and practice often reverses that order.
- 3. Set the interval with the worker. Thirty to sixty minutes suits most commercial routes, with shorter intervals in parkades, mechanical rooms and at height.
- 4. Name the person who checks. A named person on each shift and a named backup, not a department. That person records each check.
- 5. Write down what happens on a missed check. Include how many attempts were made, over what period, who attended the site, who held access cards at that hour, and when emergency services were called. This clause is most often left out, and 4.21(2) requires it.
- 6. Keep the end-of-shift check. In cleaning, this is the single most valuable provision, because a worker injured on the final task of a route would otherwise not be missed until morning.
- 7. Train both sides, in a language the worker reads, and document it. Section 3.25 requires training records.
The hazards worth assessing
Four other parts of the Regulation apply to the same shift.
Violence. Sections 4.28 to 4.30 require a risk assessment wherever violence from a person other than a worker may be present, considering previous experience at that site, experience at similar sites, and the circumstances of the work. Parkades, loading bays, and lobbies still open to the public before lockup are the usual exposures.
Lighting. Section 4.65 sets minimum levels of 22 lux in parking lots, building exteriors and basement plant areas and 54 lux in frequently used walkways and access points. A parkade’s overnight lighting setting is a measurable question, not a matter of opinion.
Mopped floors. Sections 4.39 and 4.40 require floors to be kept free of slipping hazards. Mopping creates the hazard the worker then walks across, usually with nobody nearby.
Fatigue. A note to sections 4.19 and 4.20 names fatigue as a potential source of impairment, alongside prescription and non-prescription drugs, and calls for both disclosure and adequate supervision. A worker finishing at 1 a.m. and starting a day job at 7 a.m. is a foreseeable risk.
Scheduling and breaks
Safety and scheduling are closely linked. The Employment Standards Act sets the floor: overtime at one and one-half times beyond 8 hours in a day or 40 in a week, and double time beyond 12 hours; a 30 minute unpaid meal break where the employee works more than 5 consecutive hours; a split shift completed within a 12-hour window; at least 8 hours between shifts and 32 consecutive hours free each week.
The minimum wage has been $18.25 since 1 June 2026.
Two points catch cleaning contractors in particular. Travel between buildings on a route is working time and is paid, even though the commute to the first site is not. And a crew that skips breaks to finish inside budgeted hours is telling you the route was mispriced.
British Columbia has no predictive scheduling law, so a published commitment to fixed rosters and a stated notice period for changes is a genuine differentiator rather than a restatement of the law.
If you hire the cleaning rather than do it
Two mechanisms connect a property manager to all of the above.
First, the prime contractor rule. Where workers of two or more employers are on site at the same time, someone must coordinate health and safety across all of them. Without a written, signed agreement naming a prime contractor, the owner holds the role, and the owner may be the property owner, a tenant, a property manager, or an agent. Verbal agreements are not valid.
Second, the clearance letter. It confirms a contractor is registered with WorkSafeBC and paying premiums. If you hire a contractor that is not, you may be liable for those premiums. To protect you, the letter must be addressed to your organization, so a copy the contractor forwards does not count. Request your own.
Five questions worth asking before signing
- 1. Does a written working alone procedure exist for this building, and when was it last reviewed?
- 2. Who checks on the crew, and how often?
- 3. What happens if a check is missed, and who attends the site?
- 4. Can you supply a clearance letter addressed to us?
- 5. Are the crew directly employed or subcontracted?
A contractor who cannot answer the first three has not written the procedure.
Where to get advice
The Employers’ Advisers Office advises employers on health and safety obligations at no charge, and recommends contacting them before hiring a contractor. For employment standards questions, contact the Employment Standards Branch. Whether a worker is an employee or an independent contractor, and whether particular work counts as asbestos abatement, are questions for a lawyer.
This article is general information rather than legal advice, and applies to British Columbia only. Employment standards and occupational health and safety are provincial jurisdictions.
At JF Professional Services, every cleaner is a direct employee rather than a subcontractor, which means one employer handles the hazard assessment, check-in procedure, and training for every building on the route. If you manage a commercial property and want to see how we write a working-alone procedure for your site, get in touch.
Not sure how your current contractor answers these?
| Source | Covers |
|---|---|
| OHS Regulation Part 4 | Working alone 4.20.1 to 4.23, violence 4.27 to 4.31, lighting 4.65, impairment 4.19 and 4.20, floors 4.39 and 4.40 |
| OHS Regulation Part 3 | Orientation 3.23, training records 3.25 |
| OHS Guidelines Part 4 | WorkSafeBC’s interpretation of the working alone sections |
| Working alone or in isolation | Employer handbook and practical resources |
| Working alone risk assessment and check-in | A usable model for check-in records |
| Prime contractor role and responsibilities | Information sheet, July 2025 |
| Why do I need a clearance letter | Liability for a contractor’s unpaid premiums |
| Hours of work and overtime | Overtime, breaks, split shifts, travel time |
| Minimum wage | Changes every 1 June |
| Workers Compensation Act | Consolidated 2019; section numbers renumbered |
| Employers’ Advisers Office | Free advice to employers |
Frequently Asked Questions (FAQs)
Does a cleaner count as working alone if a security guard is in the building?
Possibly, yes. Section 4.20.1 asks whether assistance would be readily available in an emergency, not whether another person is present somewhere in the building. A guard at a lobby desk who does not know which floor the cleaner is on, and who would not notice their absence for several hours, may not meet that test. The employer has to assess it building by building rather than assume either answer.
How often does a lone worker have to be checked on?
The Regulation sets no fixed interval. Section 4.21(2) requires the written procedure to state one, and section 4.21(6) requires it to be developed in consultation with the worker assigned to the shift. A note to the section states that higher risk activities require shorter intervals. For commercial cleaning, thirty to sixty minutes is typical, with shorter intervals in parkades, mechanical rooms, and at height
Is a check-in app enough on its own?
An app satisfies the recording requirement in section 4.21(3), but not the whole obligation. The written procedure must also set out what happens when a worker cannot be reached, including provisions for emergency rescue, and section 4.22 requires both the worker and the person checking on them to be trained in it. The note to section 4.21 also prefers visual or two-way voice contact, with one-way systems acceptable only where two-way contact is not practicable.
Does a worker who chooses to stay late count as working alone?
The obligation attaches to assigned work. The BC Public Service’s own guidance distinguishes between a worker assigned to work alone, where the rules apply, and an employee who decides independently to come in early or stay late. That distinction is worth settling in your own policy, because in practice cleaning routes often overrun and the line blurs.
If we contract the cleaning out, whose responsibility is this?
The contractor’s, for their own employees. The property owner or manager may still hold the prime contractor role, which carries a duty to coordinate health and safety across every employer on site. Without a written, signed agreement naming someone else, that role sits with the owner by default, and the owner can be the property owner, a tenant, a property manager, or an agent.
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