Is Logging Enough? By Sanjaya Abeysinghe | CTO, Optisolve Ltd Reference Material: Ontario legislative sources, industry research Bill 190 isn’t just about keeping records it’s about building a culture of transparency and trust. The organizations that see this early will be the ones that lead. What does Bill 190 actually require? Since July 1, 2025, Ontario employers subject to the Occupational Health and Safety Act have been legally required to maintain washroom facilities in a clean and sanitary condition, as set out in new Section 25.3 added by Bill 190 (Working for Workers Five Act, 2024). Since January 1, 2026, under Ontario Regulation 480/24, employers must also keep, maintain, and make available records of washroom cleaning specifically, the date and time of the two most recent cleanings, accessible to workers either posted near the washroom or in a readily accessible electronic format. Many organizations have done a great job getting logging systems in place, whether paper-based, QR codes, or digital platforms. That’s a significant and necessary step forward. But when you read the legislation closely, something interesting stands out: there are actually two distinct obligations, not one. “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 Section 25.3(1), as amended by Bill 190 The first obligation is the standard clean and sanitary. The second is the record documented proof of cleaning. Both matter. And it’s worth asking: does your current compliance approach address both? A question worth considering: what does a timestamp tell us? A cleaning log records that a staff member was present at a certain time. That’s valuable it creates accountability and a paper trail. But here’s a question worth thinking about: does a timestamp tell us what was actually done during that visit? For example, does it confirm that all high-touch surfaces faucet handles, flush handles, stall locks, door handles were properly disinfected? Does it tell us whether the right product was used at the correct dilution? Does it speak to whether the washroom, at this moment, meets the “clean and sanitary” standard the law describes? These aren’t criticisms of logging, logging is essential and required by the regulation. They’re simply questions that many facility managers are beginning to ask as enforcement becomes more active. Why this matters more now than ever As of January 1, 2026, Ontario’s enforcement landscape has changed. The Working for Workers Seven Act (Bill 30) introduced Administrative Monetary Penalties (AMPs) under the OHSA (implemented through Ontario Regulation 365/25), giving Ministry of Labour inspectors an additional enforcement tool. Under the new framework, inspectors may impose administrative penalties for OHSA contraventions through an administrative process. The Ministry may also publicly name employers who receive such penalties. This is a meaningful shift. It means that compliance is no longer just about having documentation ready if someone asks it’s about being able to demonstrate, at any point, that the standard itself is being met. For facility managers and operations leaders, it’s a good time to ask: if an inspector walked into one of our washrooms today, would we be confident in both the record and the result? OHSA violations can result in significant financial penalties, and organizations that receive administrative penalties may be publicly identified including publication on the internet. Beyond the financial risk, there’s also the question of reputation and the trust that workers, tenants, and clients place in your facility. Four questions that can help you assess your readiness We’ve found it helpful to think about Bill 190 compliance as four questions. They’re not a test they’re a conversation starter for teams that want to make sure they’re genuinely prepared:If you can confidently answer yes to all four, you’re in a strong position. If any of them give you pause, that’s not a problem it’s an opportunity to strengthen your approach before it’s tested by an inspection. Moving from documentation to confidence Many of the organizations we work with started their Bill 190 journey with a logging solution, and that was absolutely the right first step. Over time, some have found it valuable to build on that foundation with additional layers: Structured checklists that go beyond a single timestamp to capture what was cleaned, which fixtures, which surfaces, whether supplies were restocked. This gives the record more substance and creates a clearer picture of what actually happened during each visit. Standardized procedures so that every staff member follows the same steps, uses the correct products at the right dilution, and addresses the surfaces that matter most. When guidance is available at the point of work especially in the languages your team needs, consistency improves naturally. Trackable training that documents not just that orientation happened, but that each person demonstrated understanding of the specific procedures they’re expected to follow. Digital training platforms make this easier to manage, especially across multiple sites and shifts. Outcome validation some form of evidence that cleaning was effective, not just completed. This could range from supervisor spot-checks to more advanced approaches like surface imaging, which can reveal contamination invisible to the naked eye and provide before-and-after visual proof. None of these layers replace logging they build on it. Together, they help move an organization from “we can show the record” to “we’re confident in the result.” “Belief in cleanliness is not proof. But proof builds confidence for your team, your workers, and anyone who walks through your doors.” The bigger picture: preparing for what’s ahead Bill 190 is part of a broader trend in Ontario’s workplace legislation toward transparency, documentation, and accountability. The Working for Workers Acts Four through Seven all reflect this direction. Industry observers have also suggested that similar legislation may extend to other Canadian provinces in the future. Organizations that invest in building a strong compliance foundation now one that covers the full chain from records to training to verification will be well positioned regardless of where the regulatory landscape goes next. For Building Service Contractors, this also represents an opportunity. Clients who are working through their own Bill 190 compliance may welcome partners who can help them go beyond the basics not just with logging, but with the training, procedures, and validation that round out a complete compliance program. It’s a meaningful way to add value and differentiate your service. How Optisolve can help At Optisolve, we’ve spent years working with facility teams to improve cleaning quality, standardize operations, and build compliance programs that hold up under scrutiny. Our platform is designed around the idea that compliance is a chain each link strengthens the others:You don’t need to implement everything at once. Many organizations start with SAVI 360 for records and build from there as their needs evolve. The platform is modular, and most teams are fully operational within two to three weeks. Where do you stand? A few questions worth discussing with your teamAs Bill 190 enforcement becomes more active, it may be helpful to revisit your current approach with fresh eyes: Are we documenting what was cleaned in each washroom, or just when someone was present? Do our cleaning staff have access to a standardized washroom procedure? Could we provide an inspector with verifiable training records for each staff member? Do we have any way to confirm that our washrooms are actually sanitary after cleaning? If any of these spark a conversation, we’d welcome the chance to explore them with you.+1 800-481-2207 | [email protected] | www.optisolve.net Be inspection-ready for Bill 190 Standardize washroom cleaning records and ensure worker access with SAVI 360. View Bill 190 Solution This article is intended for general informational purposes only and does not constitute legal advice. The legislation and regulations referenced are subject to change, and their application may vary depending on your specific circumstances. For compliance guidance tailored to your organization, please consult with a qualified legal professional. For questions about how Optisolve’s tools can support your operational approach, we’d be happy to help contact us at the information above. Read More of Our Recent PostsOptisolve Announces Attestation of HIPPA Compliance.Higher Level Cleaning Validation Meets the MomentWhat to Know About GBAC Star™ AccreditationsOptisolve And Viken Detection Partner To Launch The Pathfinder™ – An Innovative Surface Imaging Device
Structured checklists that go beyond a single timestamp to capture what was cleaned, which fixtures, which surfaces, whether supplies were restocked. This gives the record more substance and creates a clearer picture of what actually happened during each visit. Standardized procedures so that every staff member follows the same steps, uses the correct products at the right dilution, and addresses the surfaces that matter most. When guidance is available at the point of work especially in the languages your team needs, consistency improves naturally. Trackable training that documents not just that orientation happened, but that each person demonstrated understanding of the specific procedures they’re expected to follow. Digital training platforms make this easier to manage, especially across multiple sites and shifts. Outcome validation some form of evidence that cleaning was effective, not just completed. This could range from supervisor spot-checks to more advanced approaches like surface imaging, which can reveal contamination invisible to the naked eye and provide before-and-after visual proof. None of these layers replace logging they build on it. Together, they help move an organization from “we can show the record” to “we’re confident in the result.” “Belief in cleanliness is not proof. But proof builds confidence for your team, your workers, and anyone who walks through your doors.” The bigger picture: preparing for what’s ahead Bill 190 is part of a broader trend in Ontario’s workplace legislation toward transparency, documentation, and accountability. The Working for Workers Acts Four through Seven all reflect this direction. Industry observers have also suggested that similar legislation may extend to other Canadian provinces in the future. Organizations that invest in building a strong compliance foundation now one that covers the full chain from records to training to verification will be well positioned regardless of where the regulatory landscape goes next. For Building Service Contractors, this also represents an opportunity. Clients who are working through their own Bill 190 compliance may welcome partners who can help them go beyond the basics not just with logging, but with the training, procedures, and validation that round out a complete compliance program. It’s a meaningful way to add value and differentiate your service. How Optisolve can help At Optisolve, we’ve spent years working with facility teams to improve cleaning quality, standardize operations, and build compliance programs that hold up under scrutiny. Our platform is designed around the idea that compliance is a chain each link strengthens the others:You don’t need to implement everything at once. Many organizations start with SAVI 360 for records and build from there as their needs evolve. The platform is modular, and most teams are fully operational within two to three weeks. Where do you stand? A few questions worth discussing with your teamAs Bill 190 enforcement becomes more active, it may be helpful to revisit your current approach with fresh eyes: Are we documenting what was cleaned in each washroom, or just when someone was present? Do our cleaning staff have access to a standardized washroom procedure? Could we provide an inspector with verifiable training records for each staff member? Do we have any way to confirm that our washrooms are actually sanitary after cleaning? If any of these spark a conversation, we’d welcome the chance to explore them with you.+1 800-481-2207 | [email protected] | www.optisolve.net
