OSHA Inspections — Janitorial (NAICS 561720)

OSHA Inspections in Tennessee Commercial Cleaning (2026)

TOSHA is widely regarded as one of the more aggressive state-plan enforcers for hospitality and commercial cleaning — its six area offices generate approximately 1,400 inspections per year, and the Nashville and Memphis food-service and hotel sectors regularly yield citations against janitorial contractors for LOTO, bloodborne pathogen, and HazCom violations.

State Plan (TOSHA — Tennessee Occupational Safety and Health Administration, Division of Tennessee Department of Labor and Workforce Development)Statute: Tennessee Occupational Safety and Health Act of 1972, Tenn. Code Ann. §50-3-101 et seq.; T.C.A. §50-3-906 (public sector program); T.C.A. §50-3-910 (local government election); TDLWD Rule 0800-01-04-.16(2) (penalty calculation factors); adopts 29 CFR 1910/1926/1928 by referenceEffective: Current; TOSHA state plan received Initial Approval July 5, 1973; 18(e) Final Approval August 26, 1985; TOSHA penalty schedule tracks federal OSHA CPI adjustments (T.C.A. §50-3-305)Last reviewed: Q2 2026
State
Tennessee
Governing Statute
Tennessee Occupational Safety and Health Act of 1972, Tenn. Code Ann. §50-3-101 et seq.; T.C.A. §50-3-906 (public sector program); T.C.A. §50-3-910 (local government election); TDLWD Rule 0800-01-04-.16(2) (penalty calculation factors); adopts 29 CFR 1910/1926/1928 by reference
29 CFR 1910.147 (adopted by TOSHA — LOTO); 29 CFR 1910.1030 (Bloodborne Pathogens); 29 CFR 1910.28 (Fall Protection); 29 CFR 1910.1200 (HazCom); 29 CFR 1910.303 (Electrical); Tennessee Right to Know Law (TDLWD Rule 0800-10-01)
Enforcement Agency
TOSHA — Tennessee Department of Labor and Workforce Development, Division of Occupational Safety and Health. Central Office: 220 French Landing Drive, Nashville, TN 37243; (615) 741-2793 / (800) 249-8510. Six area offices: Nashville (Central), Jackson (225 MLK Blvd, (731) 423-5640), Knoxville (2700 Middlebrook Pike Suite 100, (865) 594-6180), Chattanooga (1301 Riverfront Pkwy Suite 202, (423) 634-6424), Gray (5788 Bobby Hicks Hwy, (423) 224-2042), Memphis (40 S. Main St. Suite 500, (901) 543-7259)
Civil Penalty
Serious: up to $16,550 per violation; Willful/Repeat: up to $165,514 per violation (TOSHA tracks federal OSHA CPI-adjusted maximums; T.C.A. §50-3-305 requires TOSHA penalty levels at least as effective as federal). Penalty factors per TDLWD Rule 0800-01-04-.16(2): size, gravity, good faith, and history.

Who enforces OSHA in Tennessee commercial cleaning

Tennessee operates a full state plan (Initial Approval: July 5, 1973; 18(e) Final Approval: August 26, 1985) covering all private-sector workplaces and all state and local government workers. The enforcing agency is TOSHA, the Tennessee Occupational Safety and Health Administration, a division of the Tennessee Department of Labor and Workforce Development (TDLWD). Commissioner Deniece Thomas heads the Department. TOSHA's central office is at 220 French Landing Drive, Nashville, TN 37243; (615) 741-2793 / (800) 249-8510. TOSHA operates six area offices across the state: Nashville (Central), Jackson, Knoxville, Chattanooga, Gray (northeast TN), and Memphis — covering one of the fastest-growing hospitality and commercial cleaning markets in the Southeast. TOSHA Safety Compliance conducts approximately 1,400 inspections per year statewide. Federal OSHA retains jurisdiction over maritime employment, USPS, federal agencies, and military installations in Tennessee.

Top-cited standards (janitorial NAICS 561720)

  • 29 CFR 1910.147 (TOSHA adoption) — Lockout/Tagout: The #1 penalty-generating citation for NAICS 561720. Tennessee's large hotel and resort sector (Nashville's Convention Center corridor, Gatlinburg resort strip, Memphis hotel district) involves LOTO obligations for back-of-house kitchen equipment, laundry machines, trash compactors, and HVAC systems. TOSHA enforcement in hospitality cleaning is aggressive — documented machine-specific procedures are essential.
  • 29 CFR 1910.1030 (TOSHA adoption) — Bloodborne Pathogens: Required Exposure Control Plan, annual training, and HBV vaccine offer for cleaning crews at Vanderbilt University Medical Center, HCA Healthcare facilities (headquartered in Nashville), and the many hotel and entertainment venues where blood/OPIM exposure in room cleaning is routinely anticipated.
  • 29 CFR 1910.28 (TOSHA adoption) — Fall Protection: Required for cleaning at elevated positions in Nashville's booming mid-rise and high-rise commercial construction corridor, Knoxville's University of Tennessee complex, and multi-story hospitality properties across the state.
  • 29 CFR 1910.1200 (TOSHA adoption) — Hazard Communication: Full GHS compliance for all cleaning chemicals. TOSHA inspectors in the hospitality sector frequently check for Spanish-language SDS access and training documentation — a persistent gap in Tennessee's hospitality cleaning workforce.
  • Tennessee Right to Know Law (TDLWD Rule 0800-10-01) — Tennessee-specific: This state law supplements HazCom requirements for chemical manufacturers and users, and TOSHA enforces it against cleaning contractors whose workers use concentrated industrial cleaning agents. All cleaning chemicals must have accessible SDS binders and workers must be informed of specific chemical hazards in their language.

What's specific to Tennessee

  • TOSHA has a documented history of aggressive enforcement in hospitality cleaning. Nashville's explosive hotel and entertainment venue growth (1,600+ hotels statewide) creates a large and visible NAICS 561720 enforcement target. TOSHA conducts both programmed inspections in high-hazard industries and complaint-driven investigations, with hospitality cleaning among its regular programmed-inspection targets.
  • Tennessee Right to Know Law (TDLWD Rule 0800-10-01) is enforced independently of federal HazCom. Janitorial companies using any chemical classified as hazardous must maintain an accessible MSDS/SDS file for each chemical and ensure all employees (not just supervisors) have been trained on the specific chemicals they use.
  • TOSHA's Public Sector section (T.C.A. §50-3-906) separately covers cleaning crews working in state agencies, school systems, and municipal facilities. TOSHA monitors each public-sector entity registered with the TDLWD. A janitorial contractor cleaning both private offices and a public school in the same shift must comply with TOSHA standards in both settings.
  • TOSHA offers free on-site consultation through the TDLWD Division of Occupational Safety and Health Consultation Program — separate from enforcement, confidential, and available to both private and public employers. Contact the Nashville central office at (800) 249-8510.

2026 penalty structure

TOSHA penalty maximums are required under T.C.A. §50-3-305 to be "at least as effective as" federal OSHA. TOSHA tracks federal OSHA's annual CPI adjustments. As of Q2 2026, TOSHA maximums mirror federal OSHA: Serious violations — up to $16,550 per violation; Willful or Repeat — up to $165,514 per violation; Failure to Abate — up to $16,550 per day. Penalty calculation factors per TDLWD Rule 0800-01-04-.16(2): size of business, gravity of violation, good faith of employer, and history of previous violations. Penalties may be contested before the Board of Review under T.C.A. §50-3-610.

Practical first steps

  • For any hotel, resort, or convention-center cleaning contracts in Nashville, Memphis, or Gatlinburg, develop machine-specific Lockout/Tagout procedures under 29 CFR 1910.147(c)(4) for all powered equipment in back-of-house areas — TOSHA's enforcement focus on hospitality cleaning makes documented LOTO programs a priority for every Tennessee cleaning contractor.
  • Review the Tennessee Right to Know Law (TDLWD Rule 0800-10-01) compliance obligations for all cleaning chemicals — this is a TOSHA-unique requirement that operates in addition to federal HazCom and is actively cited in janitorial inspections.
  • Confirm that Bloodborne Pathogen Exposure Control Plans include a site-specific exposure determination for each client facility type (hotel, healthcare, gym) and that HBV vaccine offer documentation is current for all workers with anticipated OPIM exposure.
  • Contact the nearest TOSHA area office to identify any current Local Emphasis Programs (LEPs) targeting the janitorial or hospitality sector in your region before bidding major contracts.

Primary sources

Sources

This page is informational only. It does not constitute legal advice, tax advice, or a professional compliance determination. Laws vary by state and locality, change over time, and apply differently depending on your specific facts and circumstances. Before taking any action with legal or business consequences, consult a licensed attorney or CPA qualified in your jurisdiction.