Ontario Bill 190: What the New Workplace Washroom Cleaning Records Requirement Means for GTA Businesses

What Is Bill 190 and Why Does It Matter for Cleaning?

Bill 190, the Working for Workers Five Act, 2024, received Royal Assent on October 28, 2024. It is a broad piece of Ontario employment and workplace safety legislation that amended several Acts including the Employment Standards Act (ESA), the Occupational Health and Safety Act (OHSA), and others. Most media coverage focused on ESA changes — job posting rules, interview feedback requirements, sick note prohibitions. The OHSA amendments, including the washroom cleaning provisions, received far less attention.

For GTA employers — whether you run an office, a restaurant, a clinic, a warehouse, or a retail store — the OHSA amendments are the ones that affect your day-to-day cleaning and facilities obligations.

The full text of Bill 190's OHSA amendments is available on the Ontario e-Laws website.

The Three OHSA Changes That Affect Workplace Cleaning

1. Electronic Posting Now Accepted — In Force October 28, 2024

Before Bill 190, certain OHSA documents — health and safety committee member names, the annual injury/illness summary, the OHSA poster, the occupational health and safety policy — were required to be posted "in a conspicuous place" at the workplace. This meant a physical notice board.

Bill 190 added a new subsection 1(5) to the OHSA allowing all of these to be posted instead "in a readily accessible electronic format," provided:

• The employer provides workers with direction on where and how to access the information
• The information is in an electronic format that can be readily accessed by workers in the workplace

This applies to washroom cleaning records as well (see below). A digital log — a shared Google Sheet, a facility management app, a posted QR code linking to a cleaning record — now satisfies the posting requirement, provided workers can actually access it.

2. Employer Duty to Keep Washrooms Clean — In Force July 1, 2025

Bill 190 added a new section 25.3 to the OHSA:

"An employer shall ensure that the washroom facilities, if any, that are provided by the employer for the use of workers are maintained in a clean and sanitary condition."

— OHSA s.25.3(1), in force July 1, 2025

This is not a new concept in practice — most employers already clean their washrooms. What's new is that it is now a statutory obligation under the OHSA, enforceable by a Ministry of Labour inspector with the full range of enforcement tools available under that Act.

A parallel obligation under new section 23.1 applies to constructors on construction projects. The constructor obligation and the employer obligation are mutually exclusive — if a constructor provides washrooms on a project, the constructor is responsible, not the individual employers on that site.

3. Washroom Cleaning Records — In Force July 1, 2025

This is the part most employers have missed. Section 25.3(3) states:

"The employer shall keep, maintain and make available records of the cleaning of washroom facilities as prescribed."

— OHSA s.25.3(3), in force July 1, 2025

"As prescribed" means the specific record format and content requirements are set by regulation, not by the Act itself. Under the regulations, employers are required to log the date and time of cleanings — records of the most recent cleanings must be kept current and posted conspicuously in or near the washroom (or electronically, as described above) so they are available to workers and to a Ministry of Labour inspector on request.

This is consistent with how cleaning log requirements work in regulated settings like food service (DineSafe) and healthcare (IPAC) — a visible, dated log near the washroom or service area.

Who This Applies To

Section 25.3 applies to any employer in Ontario who provides washroom facilities for the use of workers. That is a very broad category. It includes:

• Office buildings — any employer with staff washrooms
• Restaurants and food service — washrooms for kitchen and front-of-house staff
• Retail stores — staff washrooms (note: customer washrooms are covered by different regulations)
• Medical and dental clinics — staff washrooms in the facility
• Warehouses and distribution centres — washroom facilities for warehouse workers
• Industrial facilities — any employer with worker washrooms
• Schools and institutions — where they are the employer

If you have employees and provide them with a washroom to use at work, this applies to you.

What You Actually Need to Do

Practical compliance breaks down into three things:

1. Clean the washroom and keep it clean

The standard is "clean and sanitary condition." This is already the baseline for most workplaces, but the OHSA now gives a Ministry of Labour inspector standing to cite you if your worker washrooms are not maintained — previously this was more of a landlord/tenant or municipal bylaw issue.

2. Log every cleaning with a date and time

A simple paper log sheet posted inside or outside the washroom door, showing when each cleaning occurred, satisfies the requirement. Many facilities management operations use a laminated log card — date, time, initials. A spreadsheet accessible via QR code at the washroom also works under the electronic posting provision.

3. Make the records available

Records must be available to workers and to a Ministry of Labour inspector on demand. If you use digital records, workers need to be told where and how to access them. If you use paper, the log must be posted at or near the washroom.

The Connection to Your Cleaning Contract

This is where working with a professional cleaning company directly helps with compliance. At Zusashi Maintenance, we have provided written service logs with every clean since 2007 — date, time, tasks completed, staff present. That documentation is already part of how we operate. Under Bill 190, that log now serves a dual purpose: it is both your operational record and your OHSA compliance record.

If your cleaning is currently handled in-house by a staff member with no documentation trail, Bill 190 creates a direct incentive to formalize that process. The simplest approach is a cleaning log card at the washroom that staff fill in — paper or digital — every time a clean is completed.

If you want a professional team to handle washroom cleaning and documentation together, contact Zusashi Maintenance for a free quote. We serve offices, clinics, restaurants, and warehouses across the GTA — Toronto, Markham, Mississauga, Vaughan, Brampton, Scarborough, North York, and Richmond Hill.

Frequently Asked Questions

Bottom Line

Bill 190 didn't overhaul how Ontario workplaces approach cleaning — but it did create a new, enforceable legal baseline: keep your worker washrooms clean, and document that you're doing it. For most businesses already using a professional cleaning service, compliance is a matter of ensuring that cleaning is documented and the record is accessible near the washroom. For businesses still relying on informal or undocumented cleaning routines, July 1, 2025 was the prompt to formalize that process.

If you want to review your washroom cleaning program or get professional cleaning with built-in documentation, request a free quote from Zusashi Maintenance. We serve GTA workplaces across Toronto, Markham, Mississauga, Vaughan, Brampton, Scarborough, North York, and Richmond Hill.

Note: This post is for informational purposes only and does not constitute legal advice. For specific compliance questions about your workplace, consult a licensed Ontario employment lawyer or contact the Ontario Ministry of Labour, Immigration, Training and Skills Development. The full text of Bill 190 and its amendments to the OHSA is available at ontario.ca/laws.