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, as set out in OHSA Section 25.3(1). The second is the record — documented proof of cleaning, as required by Ontario Regulation 480/24. 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.

What are the penalties for not complying with Bill 190?

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.

How can you assess your Bill 190 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:

#	The question	What it helps you evaluate
1	Do we have a documented record of each washroom cleaning with the date and time?	Whether your record-keeping satisfies Ontario Regulation 480/24
2	Do our cleaning staff follow a standardized, documented washroom procedure?	Whether the cleaning is consistent regardless of who performs it or which shift they’re on
3	Can we show verifiable training records for each person responsible for washroom cleaning?	Whether you could demonstrate to an inspector that your staff are trained and competent
4	Do we have any way to verify that a washroom is actually sanitary after it’s been cleaned?	Whether you can provide evidence of the outcome, not just the activity

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.

What does a strong washroom cleaning program look like?

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.”

Could Bill 190 requirements spread beyond Ontario?

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 programs that hold up under scrutiny. Our platform is designed around the idea that readiness is a chain — each link strengthens the others:

What you need	How we help	What it looks like in practice
Cleaning records	SAVI 360™	Digital, timestamped records with a purpose-built Bill 190 checklist. Documents what was cleaned, not just when. Accessible to workers via QR code or web dashboard.
Standardized procedures	Hey Walter™ AI	On-demand, verified cleaning guidance at the point of work in 140+ languages. Helps ensure every team member follows the same procedure with the right products and techniques.
Training documentation	Hey Walter™ Academy	Professional certification platform with self-paced modules, competency assessments, and manager reporting. Provides verifiable proof that staff were trained on the procedures they’re expected to follow.
Outcome validation	Pathfinder™	Surface imaging technology that reveals contamination invisible to the naked eye. Provides visual, before-and-after evidence that cleaning achieved the “clean and sanitary” standard — not just that it was attempted.

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.