Environmental Public Health (Amendment) Bill – NCMP Gerald Giam

By Non-Constituency MP Gerald Giam
[Delivered in Parliament on 17 Feb 2014]

Madam Speaker,

This Bill enhances the powers of the Director-General of Public Health to improve the state of cleanliness and public health in Singapore. A prominent feature of this Bill is a new requirement for all cleaning companies to be licensed and adopt a tiered wage system for their cleaners.

The Government’s intent appears to be to use licensing to compel all cleaning businesses to adopt its Progressive Wage Model (or PWM). The PWM consists of a ladder of wage levels, which is supposed to provide a pathway for cleaners to progress to higher wages as they become more skilled, more productive and take on higher responsibilities.

The PWM was introduced to counter the practice of cheap-sourcing, which the Government says prevents the market from working well to translate training, standards and productivity gains into improved wages for workers.

The Government has taken pains to emphasise that the PWM is not a national minimum wage, because it believes that wage increases must be driven by productivity growth. Hence, the PWM does not just set wage floors; it also prescribes requirements for training and certification of cleaners.

I welcome any measure that will raise the incomes of low-wage workers on a sustainable basis over the long term, and I am glad to see the wage floors introduced in the PWM. However, the PWM contains several big assumptions which must be questioned. It assumes that training and certification will translate to better work performance, which will improve cleaning standards and lead to productivity gains, which then justify the higher wages.

I am not fully convinced of the causal link between training and improved productivity in the cleaning industry. What studies has the Government done to validate this assumption?

For the Environmental Cleaning (EC) Workforce Skills Qualifications (WSQ) programmes, does the WDA require training providers to administer pre- and post-course evaluations and assessments to measure training effectiveness? If so, can the Minister share how these assessments prove that the EC training programmes conducted so far have translated into better work performance and improved business outcomes for the cleaning companies and cleaning industry as a whole?

Let’s dive a little deeper into what the EC WSQ programme entails. The basic EC WSQ Certificate requires general cleaners to undergo up to 122 hours of classroom training with approved training providers. This is over 15 working days for a full-time cleaner, or 30 working days for a part-time cleaner. It should be noted that many cleaners work part time.

The core and elective units in these courses include: Perform basic cleaning of hard floor surfaces (24 hours); perform basic cleaning of washrooms (32 hours); perform basic cleaning of carpets (24 hours); and demonstrate an understanding of the local cleaning industry (12 hours).

And that is just the first level of certification. The next level, the Higher Certificate in Environmental Cleaning, demands another 16 working days of training , while the Advanced Certificate requires another 21 working days. During this time of a nation-wide manpower crunch, it would be a significant strain on cleaning companies to have to release each of their cleaners for so many days of training.

More importantly, do general cleaners really need so many hours of classroom training to perform their work well? I believe for most general cleaners, on-the-job training (OJT), hands on experience and a good working attitude will be more effective and productive than 15 working days of classroom training. Furthermore, the methodology for many of these courses includes lectures, AV presentations and written tests. This might present a challenge for many elderly cleaning “aunties” and “uncles”.

These courses don’t come cheap either. The total course fees for the basic WSQ Certificate in EC are over $2,000 per trainee. Yes, there is government funding of up to 90% of course fees for Singapore residents, but this funding is still taxpayer money.

There are only five approved training providers for this programme, including NTUC Learning Hub and ST Electronics (e-Services). With over 55,000 resident cleaners and many more foreign cleaners to train, I wonder who is benefiting more from this mandatory certification programme: The cleaners or the training providers?

Even the Government seems to recognise that training can place a burden on companies and is not always necessary to improve work performance. Because of this, WDA allows an Assessment Only Pathway (AOP) for cleaners to obtain their WSQ certification without having to attend classroom training.

To comply with the licensing requirements and the PWM, there will many more costs for cleaning firms, over and above the higher wage bills. These include the cost of training, the cleaners’ absentee hours, the cost of training administration (which includes submission of claims), cost of assessments, and penalties for any non-compliance.

Will cleaning companies, many of whom are already operating on very thin margins, be able to bear all these costs? Is the Government prepared for the possibility that many of these cleaning companies will have to shut down as a result of these compliance costs? If this happens, many cleaners will lose their jobs and may not be able to easily find jobs in other companies because they do not hold the necessary WSQ certifications. We have to keep in mind that many cleaners are elderly workers who are not able to easily adapt to a new work environment. What is the Government’s plan to help these workers, beyond existing social assistance schemes?


I would like to seek some clarifications from the Minister regarding how the wage levels under the PWM were derived. The PWM for office and commercial cleaners dictates a wage floor of $1,000 for indoor cleaners, $1,200 for outdoor cleaners, $1,400 for multi-skilled cleaners and $1,600 for supervisors. F&B establishment and conservancy cleaners have slightly different wage levels.

How were these wage levels derived? In other countries, minimum wages are set in a much more transparent manner, using factors like age, industry sector, skill level, or cost of living and the wage required to cover the basic needs of workers and their families. Which factors were considered, and what was the methodology used by the Tripartite Cluster for Cleaners (TCC) in setting the current PWM wage levels?

I note that section 80H(3) of the Bill states that the Commissioner for Labour shall consider the recommendations by the TCC in setting the PWM wage levels. In order to increase transparency of these wage setting exercises and provide better guidance for other industries, I would like to propose that sections 80H(2) and (3) be amended as follows:

First, to require the TCC to publish a report explaining its methodology of how it derived its wage recommendations; and second, to require the Commissioner to explain his reasons for differing (if at all) from the TCC’s recommendations.


The Government has said that this is not the beginning of a national minimum wage policy, but a targeted sectorial approach to upgrading skills, quality and wages. However, by introducing this Bill which targets the cleaning industry, it has swung from a laissez-faire free market approach of letting companies determine their workers’ wages, to one featuring a high degree of micro-management of cleaning businesses by civil servants.

This is in fact a more intrusive and interventionist approach than a national minimum wage. A national minimum wage approach leaves it to companies to adapt and respond to the minimum wage levels set by the government, and the methodologies used are transparent, taking into account cost of living, economic conditions and labour market factors. The PWM leaves most of the adaptation and response to government bureaucrats, most of whom have little industry experience.

Are we sure that civil servants can do a better job at improving the productivity of the cleaning industry than the cleaning company bosses?

The Government has announced that it will soon extend the PWM to the security industry. Will it also become a template for some other industries employing low-wage workers? If so, it is important that we embark on the correct approach to raising wages, and not go overboard in introducing bureaucratic micro-management of businesses and industries, which might end up hurting both the businesses and the workers they employ.