Preparing for Bill 190: What Ontario Employers Need to Know About Washroom Cleaning Records

On October 28, 2024, Ontario passed the Working for Workers Five Act, 2024 (Bill 190), marking a notable shift in workplace health and safety legislation. Among the changes, new requirements for washroom cleaning records stand out as a practical but impactful addition for employers and facility operators across the province.

What the New Regulation Requires

Under Ontario Regulation 480/24, which comes into force on July 1, 2025, employers and constructors must:

• Maintain records of cleaning for all washroom facilities.

• Post these records in a conspicuous place in or near the washroom, or

• Make the records electronically accessible to workers, with clear instructions on how to access them.

The regulation applies to any washroom that is provided for worker use under the Occupational Health and Safety Act (OHSA).

This initiative is intended to promote transparency and consistent hygiene practices while also enabling workers to feel confident in the cleanliness and maintenance of workplace facilities.

Why This Matters

Washrooms have always been a high-traffic, high-risk area for contamination and dissatisfaction in the workplace. While many organizations already keep logs for cleaning, the new law formalizes and standardizes expectations across industries.

This change supports:

• Workplace dignity: Ensuring washrooms are clean and properly maintained.

• Employee trust: Visibility into cleaning schedules and accountability.

• Hygiene and safety: Improved routines and checks can reduce the spread of germs.

For facility managers, cleaning supervisors, and operations teams, this means a shift from informal or internal checklists to a system that can stand up to regulatory scrutiny.

Common Challenges Employers May Face

While the intent is straightforward, implementation may present hurdles for some organizations:

• Paper logs are easy to overlook or damage.

• Tracking across multiple locations or shifts can be inconsistent.

• Posting physical records near every washroom may not be practical, especially in large or mobile workforces.

• Ensuring worker access to electronic records also raises questions around systems, training, and communication.

Options for Compliance: Manual vs. Digital Systems

Employers have flexibility in how they meet the requirement, but they must ensure records are accurate, accessible, and updated in real time. Here are two broad approaches:

Manual Log Sheets

Some organizations may choose to stick with paper tracking:

• Pros: Simple to set up; no technology required.

• Cons: Prone to human error, difficult to centralize, and may require regular re-posting or physical inspection.

Digital Record Systems

More advanced organizations are adopting digital checklists and reporting platforms that centralize cleaning logs and automate compliance:

• Track who cleaned what, when, and where.

• Provide real-time dashboards for managers.

• Support exportable reports for audits or inspections.

• Enable electronic access for workers across sites and shifts.

Digital systems help standardize the process and reduce the administrative overhead that often accompanies compliance.

How Technology Can Support Compliance

As employers evaluate ways to meet the new washroom cleaning record requirements under Bill 190, digital tools offer an efficient and scalable path forward. But not all systems are created equal. It’s important to look beyond surface-level digitization and consider how well a solution truly aligns with the regulation and the realities of your work environment.

Why Flexibility Matters

Some digital platforms, like those designed primarily for commercial offices, rely heavily on stable infrastructure (Wi-Fi, Bluetooth, IoT sensor networks) to operate effectively. While these systems may work well in high-tech, urban office towers, they can fall short in remote job sites, temporary facilities, or older buildings without consistent connectivity.

Optisolve SAVI stands apart with offline functionality that enables users to collect and store data without internet access, syncing once connectivity resumes. This makes it ideal for use in construction, industrial, educational, or mobile work environments where reliable infrastructure isn’t guaranteed.

More Than Just a Digital Log

Some compliance tools take a broad-strokes approach to digitizing washroom logs. But meeting regulatory expectations — and building a reliable hygiene strategy — requires more than checking boxes.

SAVI offers a modular framework tailored to the actual expectations of Bill 190. Instead of a generic “washroom cleaned” timestamp, SAVI can guide users through structured checklists that include:

• Health & safety requirements

• Cleaning product verification

• Surface-specific cleaning quality checks

• Optional surface testing integrations

This detailed structure ensures that your records aren’t just digital — they’re comprehensive, standardized, and aligned with the legislation.

Verifying Cleanliness, Not Just Activity

Some vendors rely solely on motion sensors or occupancy tracking to indicate that cleaning may have occurred. While this can help infer activity, it doesn’t verify how well a surface was cleaned.

Optisolve’s Pathfinder technology brings cleaning validation to the next level. Using advanced surface imaging, Pathfinder can detect residual contamination and visually confirm cleaning effectiveness — something a sensor simply cannot do. This makes it a powerful addition to any compliance program, especially when documentation and accountability matter most.

What Employers Can Do Now

Although the regulation doesn’t take effect until 2026, early preparation is key. Employers should consider:

1. Auditing current cleaning record practices to identify gaps.

2. Consulting with operations teams and JHSCs to explore the most practical posting options.

3. Testing digital solutions or hybrid systems in high-use locations.

4. Training staff on proper documentation, whether paper-based or digital.

5. Communicating with workers about where and how to find these records.

Final Thoughts

Bill 190 reflects a growing recognition that workplace hygiene and dignity go hand-in-hand. For employers, it’s both a compliance requirement and an opportunity to build more trust and accountability into daily operations.

Whether through traditional means or modern tools, the core goal is the same: to make washroom cleanliness records clear, accessible, and reliable. Organizations that invest in strong systems now will be well-positioned for the regulatory shift, and better aligned with their workforce’s expectations.