This article identifies some of the most common reasons that documentation for feature X11.2 - Select Preferred Cleaning Products - is marked as pending in preliminary documentation review (WELL Certification) or round 1 (WELL at scale) reviews. This guidance does not include all possible reasons for a pending status, but provides information and context based on common review issues. 

List All Surface Cleaning and Disinfection Products

The most common issue project teams encounter when submitting documentation for feature X11.2 is that the product list included in the cleaning policy is not comprehensive. To avoid this, ensure that your cleaning policy explicitly identifies a complete list of all products used in the project. To avoid ambiguity, it may be helpful to include a statement that the list of products included in your policy is complete and specific to the project.

Additionally, generic product lists are not sufficient to document compliance with this feature part. Ensure that specific products are listed, and that they meet applicable requirements in sections a and b.

Document Compliance for Each Product

To comply with feature X11.2, all products identified must demonstrate compliance with the requirements in sections a and/or b. All products in your cleaning policy should specify which section (a or b) they are complying with, and include Safety Data Sheets (SDS) or Ingredient Lists as applicable.

Be sure to check that products included in the policy do not contain any specific ingredients flagged as non-compliant in sections a or b:

• For cleaning products, if pursuing section a-2, ensure there are no ingredients listed in the disclosure document present at 100 ppm (0.01%) or above that are classified with the following codes and hazard statements as defined by the Globally Harmonized System (GHS): H311, H312, H317, H334, H340, H350, H360, H372
  • For certain exceptions, check the provided list of pre-approved alternatives.
• For disinfectants, ensure section 2 of the SDS does not contain the following GHS codes: H311, H312, H317, H334, H340, H350, H360, H372, AND that the disinfectant only contains active ingredients from the following list: citric acid, hydrogen peroxide, L-lactic acid, ethanol, isopropanol, peroxyacetic acid, sodium bisulfate, chitosan.
  • For certain exceptions, check the provided list of pre-approved alternatives.

If your product’s SDS does not include H-codes, you may use Pubchem to search for them. Use the CAS number listed in the SDS or the compound name to search. Once you find the information, you can go to section 'Safety and Hazards' and retrieve the H codes, if any.

Verify Third-Party Certification

Some products may demonstrate compliance with feature X11.2 by holding a third-party certification, or through meeting local governmental regulations. When this is the case, it is not adequate to state that the product meets a certification or regulation.

Instead, your documentation should verify that certifications are recognized by the local government or ISO 14024-compliant (type 1) Ecolabel. Verification can be provided through specific product codes, safety data sheets, and/or product ingredient lists. It may be helpful to include a link to, or a screenshot of, a third-party certification’s product directory page clearly displaying the product’s certificate to demonstrate that a given product is third-party certified.

Ensure Cleaning Policy is implemented at the time of submission

To comply with Feature X11.2, the project’s cleaning policy including the list of all surface cleaning and disinfection products must be fully implemented at the time of submission for review. Your project must demonstrate actual implementation of the policy rather than just an intent to comply. In addition, documentation must be current, active, and not include any out of date information.

Finally, all products (100%) must comply with the requirements of Feature X11.2 - partial compliance is not sufficient to meet the feature requirements.