New legislation affects Ontario’s restroom cleaning practices
Starting July 1, 2025, a new requirement will be enforced for all employers in the province of Ontario. Adopted as part of Bill 190 – Working for Workers Five Act, this amendment requires documented proof of regular washroom maintenance, promising penalties for non-compliance. The bill is interesting because for the first time, proper sanitation is becoming a legally regulated occupational health and safety issue across the province.
This article will cover what the law says, who is affected by it, and above all, how to adapt your practices for full compliance.
What the law says
The law requires Ontario employers to practice the following, as of July 1, 2025:
- Maintain clean and sanitary washrooms conditions on an ongoing basis.
- Keep a cleaning log, indicating when maintenance is carried out and by whom.
- Keep this record for at least one year for audit or inspection purposes.
These new requirements are enshrined in the Occupational Health and Safety Act (OHSA), as amended by Bill 190.
Why the change?
Until now, no explicit requirement existed for employers to prove that washroom maintenance was being carried out regularly. Several inspections revealed concerning conditions, such as neglected sanitary facilities, lack of follow-up, and irregular cleaning practices, which led to the introduction of this new legislation.
This new regulation aims to:
- Protect workers’ health with regular, documented cleaning.
- Reduce the risk of infection and discomfort, especially in high-traffic areas.
- Empower managers by providing an opportunity for valid, trackable follow-up and labour management.
The legislation works toward a central theme of Bill 190: increased transparency, as well as simplifying the process and improving restroom cleanliness. The regulation will also help janitorial staff stay consistent and improve results, helping to highlight effective work practices and staff.
Who is affected by Bill 190?
This legislation is provincewide, encompassing all Ontario workplaces under provincial jurisdiction, including:
- Offices
- Factories
- Shopping malls
- Warehouses
- Healthcare facilities
- Schools and universities
- Construction sites (explicitly included)
In short, any company that provides “washroom facilities” for its employees will have to comply with the new legislation.
Choosing a paper or digital log
The regulation does not stipulate whether companies need a digital or paper version of the log, but there are definite advantages to both options:
With a paper log, it’s simple to implement, and very easy to use for all employees. Its is relatively cost-free, so no investment is required. However, it may not be visually appealing and could be easily misplaced, damaged, or destroyed. This type of log could be easily forged, and may be difficult to read as various employees fill in the spaces. Lastly, a paper version makes it difficult to collect data, archive results, and centralize information for multi-site businesses.
A digital log, while easy to use, may require an investment to implement. It also provides easy access to managers and staff, including valuable data like time and date stamps and times for easy tracking. This type of log is also customizable, so it can be tailored for each company’s needs, offering a more attractive option, and is a more sustainable option when compared to a paper version. Non-forgeable, this system provides reliable, real-time data with enhanced traceability and the ability to generate reports by time period or by building for accurate tracking. Many of the digital options are also compatible with certification tools (BOMA, LEED, ESG) to help companies work towards their sustainability goals.
Multi-site organizations or companies wishing to simply comply with the new regulation should seriously consider a digital solution for optimal results.
Get ready now!
Here are the 5 key steps to make sure you’re ready to implement protocols to comply with the new regulation:
- Identify all sanitary installations under your responsibility.
- Choose your tracking method (paper or digital) and create the necessary tools.
- Train relevant employees to use the register or practice new protocols.
- Establish a procedure for storing your logbooks (for a minimum of one year).
- Consider adding a dashboard or connected system to improve efficiency and transparency.
Failure to comply
Ignoring this new responsibility could have serious consequences for companies, including:
- Substantial fines (up to $100,000 for individuals, more for companies)
- Potential for inspections and guest or employee complaints
- Negative impact on certifications (BOMA, LEED, etc.).
- Loss of reputation and credibility with occupants or unions.
A step forward
Bill 190 marks an important turning point in workplace hygiene management in Ontario, making what was once good practice now a legal requirement. By setting up a clear, reliable and traceable cleaning logbook, you comply with required regulations, protecting your visitors, your staff, and your business.
Karl Bédard is the Senior Director at ValkarTech, a consulting firm dedicated to optimizing commercial cleaning contracts. As an experienced LEED Green Associates certified auditor, he conducts many building visits and evaluates customers’ various processes.
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