Ontario Bill 190: Washroom Cleaning Record Requirements (2026 Overview) Workplace hygiene has long been a core responsibility under Ontario’s occupational health and safety framework. With the passage of Ontario Bill 190, the province has taken an additional step by formalizing how washroom cleaning records must be documented and made accessible to workers. As these Bill 190 washroom cleaning record requirements come into force in January 2026, employers across Ontario need to understand what is changing, who is affected, and how to prepare for compliance. What Is Bill 190? Bill 190, formally titled the Working for Workers Five Act, 2024, was passed by the Ontario government on October 28, 2024. The legislation amended several existing laws, including the Occupational Health and Safety Act (OHSA), with the goal of strengthening worker protections and workplace standards. A key theme of Bill 190 is accountability. The government is placing greater emphasis on not just doing the right thing, but being able to show that it’s being done consistently. That’s where washroom cleaning records come in. While employers have always been expected to keep washrooms clean and sanitary, Bill 190 makes this expectation more visible. It introduces clear requirements to document when washrooms are cleaned and make that information accessible to workers. The goal is to give employees confidence that basic hygiene standards are being met, and to give inspectors a clear way to verify compliance. In short, Bill 190 turns what was often an informal or behind-the-scenes practice into something that is transparent, trackable, and easier to enforce. When Do Ontario Bill 190 Requirements Take Effect? The washroom cleaning record requirements are set out in Ontario Regulation 480/24 and are in force as of January 1, 2026. From this date forward, employers and constructors must ensure that required records are maintained and accessible in accordance with the regulation. Who Does the Regulation Apply To? Bill 190’s washroom requirements apply to most Ontario workplaces under the Occupational Health and Safety Act, including: Offices and corporate facilities Retail stores and shopping centres Manufacturing and warehouses Healthcare facilities Hospitality and food service Recreation centres and gyms Educational institutions Multi-tenant commercial buildings Exceptions: Federally regulated workplaces (banks, airlines, telecommunications) fall under separate federal requirements. Private residences used solely as homes are excluded. Construction projects have additional requirements under Ontario Regulation 482/24. What Are Employers Required to Do Under Ontario Bill 190? 1. Keep a record every time a washroom is cleaned Employers must keep a record showing when each workplace washroom was cleaned. At a minimum, the record must show the date and time of the two most recent cleanings for each washroom facility. This ensures that cleaning information is always current and prevents records from becoming outdated or incomplete. 2. Make cleaning records accessible to workers The regulation requires that workers be able to view washroom cleaning records. Employers may do this in one of two ways: Post the record in a conspicuous place in or near the washroom, or Provide electronic access to the record Both options are compliant, but they are not equally effective in practice. While paper logs are permitted, electronic records are generally more reliable and easier to manage, especially in workplaces with multiple washrooms, shifts, or locations. 3. Clear instructions are required for both methods Clear instructions are required regardless of the format. Whether records are kept on paper or electronically, workers must be able to easily find and understand the cleaning information. Records that are difficult to locate, unclear, or effectively inaccessible do not meet the intent of the regulation. The focus is on real-world transparency, not just meeting the requirement on paper. Paper vs. Electronic Washroom Cleaning Records Ontario Regulation 480/24 permits washroom cleaning records to be maintained either on paper or electronically. While both formats are compliant, they present different levels of operational risk and inspection readiness. Paper records Legally permitted under the regulation Higher risk of being lost, damaged, or inconsistently completed Difficult to standardize across multiple washrooms, shifts, or locations More likely to contain missing or retroactive entries Limited audit trail during Ministry of Labour inspections Electronic records Explicitly permitted under the regulation Automated date and time stamping improves accuracy Easier to standardize across sites and teams Faster access for workers and inspectors Stronger documentation history and audit readiness To support organizations preparing for the 2026 enforcement date, SAVI 360 includes a Bill 190 washroom compliance checklist designed to help employers consistently document cleaning activity, maintain accessible records, and demonstrate alignment with the regulation’s requirements. Making Digital Washroom Cleaning Records Accessible to Employees To meet the intent of the regulation, employees should be able to view washroom cleaning records without needing to ask a supervisor, request login credentials on the spot, or navigate complex systems. Practical ways organizations commonly provide access include: Posting a QR code in or near the washroomA simple QR code can link directly to the most recent cleaning record for that specific washroom. This allows workers to access records instantly using a personal or shared device. Providing shared-device accessIn facilities where personal devices are not permitted, a tablet or kiosk can be made available in a common area, preloaded with access to washroom records. Clear on-site instructionsSignage near washrooms should explain how to access digital records (for example, “Scan the QR code to view the most recent washroom cleaning record”). Accessibility includes knowing where and how to look. During an inspection, Ministry of Labour officers may ask a worker to show how washroom cleaning records are accessed. Inspectors typically look for records that are immediately available, clearly linked to the specific washroom, and current. If access requires special permission, multiple steps, or staff assistance, it may be viewed as not readily accessible. The test is practical: can a worker reasonably view the most recent cleaning records during their shift, without delay? Preparing for Ontario Bill 190: Practical Next Steps for Employers Although the washroom cleaning record requirements under Bill 190 do not take effect until January 1, 2026, employers can reduce compliance risk by preparing well in advance. Early planning helps avoid rushed implementation, inconsistent records, and inspection issues once enforcement begins. Organizations should consider the following practical steps: Inventory all washroomsIdentify every washroom used by workers, including fixed washrooms, portable units, temporary facilities, and shared washrooms provided as part of the workplace. Choose and standardize a record-keeping methodDecide whether washroom cleaning records will be maintained on paper or digitally, and apply that approach consistently across all locations, shifts, and teams. Assign clear accountabilityDefine who is responsible for logging each cleaning event on every shift, including evenings, weekends, and periods of staff absence. Confirm worker accessEnsure workers know where cleaning records are located and how to access them independently during their shift, without needing to ask a supervisor. Test accessibility in real conditionsPeriodically ask frontline employees to demonstrate how they would access washroom cleaning records, mirroring how inspectors typically verify compliance. Review records regularlyConduct routine checks to confirm records are current, washroom-specific, and clearly show the two most recent cleanings, as required by the regulation. Taking these steps now allows organizations to embed compliant documentation into everyday operations, rather than treating washroom records as a last-minute administrative task. Be inspection-ready for Bill 190 Standardize washroom cleaning records and ensure worker access with SAVI 360. View Bill 190 Solution Read More of Our Recent PostsTransforming Your Record Keeping to Lower Liability Risks in Facility ManagementA Four-Step Approach to Becoming a Best-in-Class FacilityThe Optisolve Difference: How We Go Above and Beyond for Our ClientsOptimize Customer Satisfaction Of Your Commercial Cleaning and Janitorial Services
Although the washroom cleaning record requirements under Bill 190 do not take effect until January 1, 2026, employers can reduce compliance risk by preparing well in advance. Early planning helps avoid rushed implementation, inconsistent records, and inspection issues once enforcement begins. Organizations should consider the following practical steps: Inventory all washroomsIdentify every washroom used by workers, including fixed washrooms, portable units, temporary facilities, and shared washrooms provided as part of the workplace. Choose and standardize a record-keeping methodDecide whether washroom cleaning records will be maintained on paper or digitally, and apply that approach consistently across all locations, shifts, and teams. Assign clear accountabilityDefine who is responsible for logging each cleaning event on every shift, including evenings, weekends, and periods of staff absence. Confirm worker accessEnsure workers know where cleaning records are located and how to access them independently during their shift, without needing to ask a supervisor. Test accessibility in real conditionsPeriodically ask frontline employees to demonstrate how they would access washroom cleaning records, mirroring how inspectors typically verify compliance. Review records regularlyConduct routine checks to confirm records are current, washroom-specific, and clearly show the two most recent cleanings, as required by the regulation. Taking these steps now allows organizations to embed compliant documentation into everyday operations, rather than treating washroom records as a last-minute administrative task.
