Quick answer: The 2025 UK Cleaning Compliance Standards introduced a formal Hygiene Management Plan (HMP) as a documented requirement for professional cleaning operations. An HMP is not a single document — it is a structured management framework that covers cleaning schedules, chemical management, staff training, equipment maintenance, audit and verification, and corrective action. The requirement sits alongside existing COSHH obligations and does not replace them. Contractors operating in healthcare, food manufacturing and pharmaceutical environments are most immediately affected, but the HMP framework is increasingly expected across all professional cleaning contracts.
A Hygiene Management Plan is a documented, systematic approach to managing the hygiene and cleanliness outcomes of a cleaning operation. Where previously many cleaning contracts operated on informal schedules and undocumented chemical management, the 2025 standards introduce the expectation that professional cleaning operations maintain a formal, auditable HMP.
The HMP framework reflects a broader shift in how cleaning is regulated and procured — away from activity-based specifications (clean this area three times a week) towards outcome-based specifications with documented evidence of achievement. For principal contractors and facilities managers, this means that cleaning sub-contractors are increasingly expected to demonstrate HMP compliance as part of contract pre-qualification.
What a Hygiene Management Plan must contain
While there is no single prescribed format for an HMP, the 2025 guidance sets out the core elements that a compliant plan must address:
- Scope and responsibility — clear definition of the areas and activities covered by the plan, and named individuals responsible for delivery and oversight
- Cleaning schedules — documented frequency, method and responsible operative for each cleaning task within scope
- Chemical management — list of all chemical products in use, current Safety Data Sheets, dilution ratios, application methods and storage requirements. Must reference updated hazard classifications post-August 2026 deadline — see: Chemical hazard reclassification August 2026
- Equipment specification and maintenance — list of cleaning equipment in use, maintenance schedule, inspection records and replacement criteria
- Staff training and certification — records of induction training, chemical handling training, equipment operation training and any sector-specific certification required
- Audit and verification — documented evidence that cleaning tasks have been completed to the required standard, including any ATP hygiene testing, visual inspection records or client sign-off processes
- Corrective action procedure — documented process for identifying and resolving non-conformance, including who is notified, within what timescale and how resolution is evidenced
Connection to existing compliance obligations
An HMP does not replace existing statutory obligations. It sits alongside and is informed by them:
COSHH Regulations 2002 require assessment of hazardous substances used in cleaning — the HMP's chemical management section must be consistent with the COSHH assessment for each product in use. Where chemical hazard classifications have been updated under the August 2026 GB CLP changes, COSHH assessments and HMP chemical management records must both be updated.
PUWER 1998 requires that cleaning equipment is suitable for purpose, properly maintained and that operators are trained in its use. The HMP equipment section must reflect PUWER compliance — maintenance records, inspection dates and training records for all cleaning machines.
For cleaning operations on notifiable construction sites, CDM 2015 applies. The HMP should be consistent with the Construction Phase Plan where cleaning activities form part of a notifiable project.
In healthcare settings, the HMP must align with HTM cleaning standards and CQC requirements. In food manufacturing, the HMP must be consistent with HACCP and BRC/BRCGS cleaning verification requirements.
Equipment specification within the HMP
The equipment section of an HMP should specify not just which machines are in use but why those machines are appropriate for the tasks and environments covered. For dust extraction, the HMP must specify the extraction class — L-Class, M-Class or H-Class — and confirm that the class specified is appropriate for the hazards present. A general-purpose vacuum specified in an HMP for a site where asbestos-containing materials may be disturbed would represent a significant compliance failure.
Related guidance
COSHH Regulations 2002 PUWER 1998 CDM 2015 M-Class extraction H-Class extraction Healthcare hub Food manufacturing hub Facilities management hub Cleaning trade hub
