What Bill 190’s washroom requirements mean for custodial teams

New legislation introduced in Ontario requires employers to ensure that washroom facilities for employees are clean and sanitary. Additionally, they’ll have to keep and provide records of washroom cleaning. Keep reading for more on how to comply with the changes.

Washroom Bill 190 and what it means for custodial teams.

Custodial teams can help their customers fulfill their Bill 190 washroom obligations by cleaning regularly, keeping records, and making those records readily available. We’re going to explore the easiest ways for teams to offer this service to their clients.

This article does not constitute legal advice. For any compliance issues, refer to the law itself or consult with your legal adviser.

What is Bill 190?

Bill 190 is part of the Working for Workers Five Act, 2024 (Bill 190) in Ontario, Canada. It includes changes to the Occupational Health and Safety Act by adding two main requirements for washroom facilities provided to employees. First, the washrooms must be clean and sanitary. Second, employers must make the cleaning records for those washroom facilities available.

You can find the full text of the bill on the Ontario government website. The portions of the bill that affect washroom cleaning and records are changes to the Occupational Health and Safety Act.

What does Ontario Bill 190 require of employers?

Employers can fulfill their Ontario Bill 190 requirements by keeping workplace washrooms in a clean, sanitary condition and making cleaning logs available.

Maintaining clean and sanitary washrooms

Effective July 1, 2025

After the joint management inspection, a robust PR reporting process delivers lessons learned to the rest of the team. Follow-through is key. Be sure to:


  • Follow up with communication within the team.

  • Track the issues raised and set a time to review progress.

  • Look for any recurring issues that a client has had to raise more than once, indicating a problem with your process.


Looking for software to improve public relations audits for your clients? We’d be happy to talk about how OrangeQC’s quality tools make it easy to generate professional digital PR reports and get detailed insights from results.


Making cleaning records available

Effective January 1, 2026

Ontario Bill 190 also requires that employers make washroom cleaning records available. Ontario Regulation 480/24 clarifies that the record must be either posted conspicuously in or near the washroom, or that it’s posted digitally and workers are made aware of how to access it. The record must also include the date and time of the two most recent washroom cleanings.

Custodial teams can help their clients comply with Bill 190 by keeping a record of completed cleanings and making it accessible to workers.

Best practices to meet this requirement:

  • Have the custodial staff keep a log of completed cleanings.
  • Provide an easy way for people to check the logs, such as posting a QR code.
  • Review the service logs to ensure the washroom is being cleaned on schedule.
  • Use digital logs with timestamps and GPS locations, rather than unreliable written logs.
Tips for Bill 190 Washroom Compliance. Log each cleaning, post a QR code for checks, review logs regularly, use a digital log with GPS.

What does Bill 190 mean for custodial teams?

In-house and commercial cleaning teams alike may need to help educate their clients on the washroom requirements for Ontario workplaces and explain how they can help with compliance. For commercial teams, this might be included with the current level of service or offered as an add-on.

Custodial teams can help their organizations by:

  • Educating clients on the bill and how to stay in compliance
  • Flagging potential problems that could lead to legal penalties
  • Keeping accurate, trustworthy cleaning service logs
  • Offering an easy way to make cleaning logs accessible

The advantage of keeping digital cleaning records

Paper washroom forms are simple and inexpensive, but they can become another item needing maintenance. They also have to be checked in person.

Digital washroom records can be accessed anywhere. They look more professional, do not get lost, and do not create additional admin work. If workplace washroom service isn’t being completed, supervisors can be alerted right away.

If you’re looking for a digital solution to stay compliant with workplace washroom laws, we recommend checking out OrangeQC. Our cleaning service checklists are perfect for creating a trustworthy cleaning log with timestamps, GPS, and photos. Schedule a call with us for a full walkthrough of our tools.

Keeping digital records is crucial with the Ontario Bill 190 in effect.

FAQs

What is the Working for Workers Five Act?

The Working for Workers Five Act, 2024 is a piece of Ontario legislation that makes additions and amendments to laws affecting workers and the workplace, including workplace washroom laws. The act affects facets of employment, including hiring, job postings, protection from harassment, and more.

Which employers does the Ontario Bill 190 affect?

According to Ontario’s guide to the Occupational Health and Safety Act, OSHA applies to “most workers, supervisors, employers, and workplaces in Ontario.”

There are some exceptions to OSHA, including for teachers and certain federally run workplaces, which generally fall under different requirements.

When will the Bill 190, Working for Workers Five Act, go into effect?

Bill 190, Working for Workers Five Act has already begun to go into effect. The portions affecting washroom cleanliness came into force on October 28, 2024 and January 7, 2025. The requirement for making restroom cleaning records available is slated to go into effect on January 1, 2026.

How can you make digital cleaning records compliant with OSHA?

In order for digital cleaning logs to be compliant with OSHA:

  • The employer has to give their employees instructions regarding where and how to access the records.
  • The records have to be readily accessible within the workplace.

How long do you need to keep cleaning records?

Ontario Regulation 480/24 states that the log has to provide the dates and times of the two most recent washroom cleanings.

For construction projects, changes to Ontario Regulation 213/91 require the constructor to keep a log at the site that covers services for six months or the length of the project (whichever is shorter).

Employers should consult with their legal advisers for specific advice on how long to maintain cleaning records for compliance. OrangeQC makes washroom cleaning records indefinitely accessible in a digital format in order to track trends over long periods of time.

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