ACECQA's Regulation 77 mandates "adequate health and hygiene practices" without specifying which cleaning products achieve this standard, leaving centres to navigate overlapping requirements from Safe Work Australia, the TGA, and Quality Area 2 performance standards. This guide explains what ACECQA actually requires, clarifies the three-part compliance framework, and shows how to build documentation systems that satisfy assessors during rating visits.
What ACECQA Actually Requires For Cleaning Supplies
Regulation 77 And The "Adequate Health And Hygiene" Standard
Regulation 77 requires approved providers to ensure nominated supervisors, staff, and volunteers implement adequate health and hygiene practices, but provides no product specifications or approved brand lists. ACECQA determines "adequate" by reference to external frameworks including Australian food safety standards, state health requirements, and Safe Work Australia guidance.
The practical implication is documentation. You must demonstrate your product selection, handling procedures, and staff competency align with these external frameworks.
Quality Area 2 Requirements For Children's Health And Safety
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Element 2.1.2 requires clear, demonstrable health practices that minimise infection transmission risk.
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Assessors check whether your cleaning practices protect children from foreseeable harm, with a focus on high risk areas such as nappy change stations, food preparation surfaces, and bodily fluid spill zones.
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Your Quality Improvement Plan must show evidence based decision making about cleaning and disinfection.
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Generic cleaning schedules are not sufficient.
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Provide documented rationale for product selection, the specified contact times, and how you verify that staff follow dilution ratios and procedures.
The Documentation Gap That Creates Liability
Regulation 168 requires documented policies reflecting actual practice, not aspirational standards. Most centres have policies stating "we maintain clean, hygienic environments" without specifying products, procedures, or verification systems. During assessment, this gap becomes apparent when you cannot provide evidence that practices match policies.
We help centres close this gap by providing product-specific documentation connecting policies to actual cleaning supplies, complete with Safety Data Sheets, usage protocols, and training records demonstrating staff competency.
The Three-Part Compliance Framework Every Centre Must Understand
ACECQA Operational Requirements Under The National Quality Framework
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Regulation 77 sets the baseline for adequate health and hygiene practices.
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Regulation 106 requires adequate laundry and hygiene facilities with secure storage for cleaning materials away from children.
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Regulation 168 mandates documented policies that are reviewed regularly and updated to reflect evidence based practice.
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The National Quality Framework treats these as an integrated system:
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You cannot satisfy Regulation 77 without appropriate facilities under Regulation 106.
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You cannot demonstrate adequate practices without documentation under Regulation 168.
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Assessors evaluate the complete system.
WHS Obligations Via Safe Work Australia For Chemical Management
Work Health and Safety regulations create four mandatory requirements: maintain a register of all hazardous chemicals, obtain and keep current Safety Data Sheets (updated within five years), ensure correct GHS labelling, and provide adequate staff training on safe handling and emergency procedures.
The register must include product name, manufacturer, SDS location, and risk assessment for each chemical. Many centres fail compliance not because they lack documents, but because staff don't know how to access them during emergencies. Make sure to evaluate your suppliers as well.
TGA Requirements For Disinfectants And Sanitisers
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Hospital grade disinfectants that claim to kill viruses, spores, tuberculosis, mycobacteria, or fungi must be listed on the Australian Register of Therapeutic Goods.
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Check the label for an ARTG number, then verify it on the TGA website to confirm the product is approved.
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ARTG listed disinfectants go through more rigorous testing than household grade options, so they are the safer choice for high risk tasks.
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If your policy says you use hospital grade products in nappy change areas, be ready to show the ARTG listing during an assessment.
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Generic supermarket disinfectants rarely meet this standard.
Chemical Register And SDS Requirements That Assessors Check
What Must Be In Your Hazardous Chemicals Register
Your chemical register must list every hazardous chemical used at your service, including product name, manufacturer contact details, SDS location, storage location, risk rating, and required control measures. The register must be kept onsite and updated whenever new products are introduced.
Many centres maintain incomplete registers listing only obviously hazardous products like bleach while omitting surface cleaners, bathroom products, or laundry detergents. If a Safety Data Sheet exists for a product, that product belongs in your register.
Safety Data Sheets And The Five-Year Currency Rule
Safety Data Sheets contain 16 standardised sections covering chemical composition to emergency response procedures. SDS documents must be reviewed by manufacturers at least every five years, and using outdated sheets indicates poor chemical management.
During assessment visits, authorised officers commonly request Safety Data Sheets for products they observe in use. If you cannot immediately provide a current SDS, you've demonstrated a compliance gap. We maintain digital SDS libraries and automatically notify centres when updated versions become available.
GHS Labelling Requirements For Workplace Chemicals
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All workplace chemicals must display GHS compliant labels showing hazard pictograms, signal words, hazard statements, and precautionary statements.
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When centres decant products into smaller containers, the new container must display product name, GHS hazard pictograms, signal words, and key safety statements.
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Handwritten labels on spray bottles do not comply.
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We provide GHS compliant labelling supplies and training to centres that decant products while maintaining regulatory compliance.
Product Selection Criteria For Different Childcare Areas
Nappy Change Areas And Bodily Fluid Spills
Nappy change areas require hospital-grade disinfectants with demonstrated virucidal efficacy against faecal pathogens. Look for ARTG-registered products listing specific pathogens in approved claims, with practical contact times for surfaces to remain visibly wet.
Your procedures must specify the two-step process: clean first to remove organic matter, then disinfect to kill pathogens. Using disinfectant on visibly soiled surfaces reduces efficacy because organic matter shields microorganisms from chemical contact.
Food Preparation Surfaces And Food-Safe Sanitisers
Food preparation areas require products that are both effective against pathogens and safe for food contact surfaces. Food-safe sanitisers typically use quaternary ammonium compounds, food-grade hydrogen peroxide, or other approved ingredients, with labels explicitly stating suitability for food contact surfaces.
Your procedures should specify cleaning with detergent and water, followed by sanitising with appropriate contact time, followed by rinsing or air drying depending on product specifications.
Toys And Equipment Cleaning Requirements
Toys require frequent cleaning because children put them in mouths and share them constantly. For hard plastic toys, dishwasher cleaning provides effective pathogen kill through high temperature and detergent action. For toys that cannot withstand dishwasher temperatures, cleaning with detergent followed by child-safe disinfection is appropriate.
Soft toys and fabric items require laundering at temperatures sufficient to kill pathogens which is generally 60 degrees Celsius or higher. Your policies must address how frequently different toy categories are cleaned based on use patterns and contamination risk.
Sleep Areas And Linen Hygiene Protocols
Sleep areas require protocols for bedding, cots, and sleep mats preventing pathogen transmission between children. Each child should have individual bedding that's not shared, and cots or mats require cleaning between different users with products effective against respiratory pathogens.
Bedding requires hot water laundering at frequencies reflecting usage patterns—sheets, pillowcases, and blankets used daily need weekly washing at minimum, with immediate laundering if visibly soiled or contaminated with bodily fluids.
Common Audit Findings And Compliance Gaps
Missing Or Outdated Safety Data Sheets
The most frequent finding during assessment visits is missing or outdated Safety Data Sheets. Assessors select products at random during facility walkthroughs and request immediate access to SDS documents. If you need to search filing cabinets or admit you don't have the document, you've demonstrated inadequate chemical management.
We eliminate this gap by maintaining a digital SDS library accessible through your account portal, with automatic notifications when manufacturers publish updates.
Inadequate Staff Training Documentation
Staff responses reveal whether your training is genuine or box-ticking. If educators cannot explain why they use specific products for nappy change areas, what contact time is required, or where to find the SDS during a chemical spill, your compliance system has failed.
Training documentation must show what specific training was provided, when each staff member received training, who conducted it, how competency was verified, and when refresher training is scheduled.
Unlabelled Decanted Products And Storage Violations
Decanted products must carry labels meeting GHS requirements—writing "cleaner" on masking tape doesn't comply. Chemicals must be stored separately from food, prevented from child access through locked cabinets or 1.5 metres minimum height, with incompatible chemicals separated and adequate ventilation provided.
We provide centres with compliant storage solutions and help design layouts that satisfy safety requirements within existing facility constraints.
Cleaning Schedules That Don't Match Actual Practice
Your documented cleaning schedule creates a compliance standard you'll be assessed against. If schedules state "disinfect all toys daily" but assessors observe toys that obviously haven't been cleaned daily, you've documented your own non-compliance.
Practical schedules balance infection control needs with operational reality, specifying what areas or items require cleaning, how frequently, what products and methods are used, who is responsible, and how completion is verified.
How Complete Wholesale Suppliers Supports Your Compliance
Every product in Complete Wholesale Suppliers’ catalogue comes with complete documentation such as Safety Data Sheets, TGA registration verification where applicable, and usage protocols aligning with ACECQA expectations. Our account managers conduct compliance audits identifying gaps in chemical registers, outdated documentation, or inappropriate product selection, then provide replacement products and systems to close those gaps.
We maintain digital documentation accessible 24/7 through your account portal. When assessors request Safety Data Sheets during visits, your staff can access them immediately. We track SDS currency and proactively notify you when updates are available. Training resources covering proper product usage, contact times, dilution ratios, and emergency procedures are included with delivery. When regulations change, we update documentation and notify affected customers before compliance deadlines.
FAQs
Does ACECQA approve specific cleaning product brands?
No, ACECQA does not approve specific brands. Regulation 77 requires "adequate health and hygiene practices" without specifying products. You are responsible for selecting products that satisfy Safe Work Australia's chemical management requirements and, where relevant, TGA disinfectant regulations.
Do we need hospital-grade disinfectants for all areas?
Hospital-grade disinfectants are necessary for high-risk areas like nappy change stations and bodily fluid spill zones. General play areas, floors, and furniture typically require only regular cleaning with detergent or household-grade disinfectants based on your risk assessment.
How often must Safety Data Sheets be updated?
Manufacturers must review SDS documents at least every five years. You must obtain current versions from suppliers and replace outdated documentation. Using SDS documents more than five years old indicates poor chemical management during ACECQA assessments.
What are the penalties for non-compliance with Regulation 77?
Non-compliance carries maximum penalties of $10,000 for individuals or $50,000 for corporations. Regulatory authorities can issue compliance notices requiring immediate corrective action or, in serious cases, suspend service approval until compliance is restored.
Can we use household cleaning products from supermarkets?
Yes, household products are acceptable for many childcare cleaning tasks, provided they are appropriate for the specific use and you maintain required documentation. High-risk areas may require hospital-grade disinfectants with proven pathogen efficacy.
What's the difference between cleaning, sanitising, and disinfecting?
Cleaning removes visible dirt using detergent but doesn't necessarily kill pathogens. Sanitising reduces bacterial populations to safe levels, typically killing 99.9% of bacteria. Disinfecting kills nearly 100% of bacteria, viruses, and other pathogens. Each process has appropriate applications in childcare settings.
Do we need separate products for food preparation areas?
Yes, food preparation surfaces require food-safe sanitisers specifically formulated for food contact surfaces. Not all disinfectants are appropriate because they may leave harmful residues or produce odours affecting food while meeting food safety requirements under Australian standards.
How should we store cleaning chemicals to comply with WHS requirements?
Chemicals must be stored in locked cabinets or at minimum 1.5 metres above floor level, separate from food and medications. Products must remain in original containers with intact labels, or if decanted, display GHS-compliant labels. Storage areas require adequate ventilation with incompatible chemicals segregated.
What training do staff need for handling cleaning chemicals?
Staff require training on safe handling procedures for every hazardous chemical, including hazard identification, proper dilution, required PPE, emergency response, and accessing Safety Data Sheets. Training must be documented showing what was covered, who received it, when, and how competency was verified.
How do we verify if a disinfectant is TGA-registered?
Visit the TGA website and search the Australian Register of Therapeutic Goods using the product name or ARTG number shown on the label. Hospital-grade disinfectants making specific pathogen claims must be ARTG-listed before being supplied in Australia.