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2.15 Right-to-Know & Hazard Communication Policy

Scope and Commitment

THE COMPANY complies with the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard (29 C.F.R. § 1910.1200) and all applicable federal and state requirements. To fulfill these obligations, THE COMPANY follows the official SUBWAY Safe Dining Commitment (SSDC) Hazard Communication Program, administered through our approved chemical supplier, Ecolab.

THE COMPANY uses only Ecolab-approved cleaning, sanitation, and chemical products. No outside chemicals may be brought into or used within the restaurant unless expressly approved through the SSDC Program.

 

Hazard Communication Program Administrator

Each restaurant location designates a Hazard Communication Program Administrator, which is the Restaurant Manager unless otherwise assigned. The Administrator works in coordination with SSDC/Ecolab and is responsible for:

  • Ensuring Ecolab chemical products are used exclusively.
  • Preventing the introduction or use of unapproved or outside chemicals.
  • Maintaining the SSDC/Ecolab Hazard Communication Program Binder containing the written program, chemical inventory, Safety Data Sheets (SDS), and required training records.
  • Confirming that SDS are accessible to Team Members during all shifts.
  • Ensuring Team Members complete SSDC/Ecolab chemical-safety training before they handle any cleaning or sanitizing products.
  • Updating the chemical inventory and SDS Binder whenever products are added, changed, or removed.

 

Safety Data Sheets (SDS)

  • All SDS are supplied through Ecolab and maintained within the SSDC Program Binder at each restaurant.
  • SDS are also made available on the Team Member Portal for review.
  • Team Members may review SDS at any time during their shift.
  • No chemical product may be used until its SDS is available and has been reviewed by the Administrator.

OSHA requires that SDS be accessible without barriers, meaning Team Members must not need to ask permission or leave the premises to review them.

 

Labels and Secondary Containers

  • All chemical containers provided by Ecolab arrive properly labeled. Labels must never be removed, altered, defaced, or covered.
  • If a chemical is transferred to a secondary container (such as a spray bottle or bucket), an SSDC-approved workplace label must be applied immediately.
  • Unlabeled bottles, handwritten labels, or “mystery containers” are strictly prohibited and must be removed from service immediately.

 

Training Requirements

All Team Members handling chemicals will receive Hazard Communication training:

  • At the time of hire
  • Before handling any chemical product
  • Annually if required by law or THE COMPANY
  • Whenever a new chemical or significant hazard is introduced into the workplace

Training will be conducted using SSDC/Ecolab-approved resources in a language and vocabulary Team Members understand. Training records will be maintained at each restaurant.

 

Non-Routine Tasks and Vendors

If a Team Member must perform a non-routine task involving chemicals (such as deep-cleaning procedures, equipment descaling, or unexpected chemical exposure):

  • The Administrator will provide hazard information and required protective measures before the task begins.
  • For outside vendors using chemicals on-site (e.g., pest control, hood cleaning, floor stripping):
  • The Administrator will obtain SDS in advance,
  • Communicate hazards and safety measures to all affected Team Members, and
  • Ensure appropriate precautions are taken to prevent exposure.
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