Published: September 22, 2025
If you’re an Ontario employer, there’s a critical change coming that affects how you manage workplace washrooms. New legislative requirements are now in effect—and more are coming in 2026—that could impact your business operations and compliance obligations.
What’s Changed? The Legal Landscape
Ontario has taken workplace hygiene to a new level of enforcement. As of July 1, 2025, employers are now legally required to keep washroom facilities for employees “clean and sanitary” under section 25.3 of the Occupational Health and Safety Act (OHSA).
But here’s what makes this significant: it’s not just a guideline anymore—it’s enforceable law.
“What this means is that the requirement to maintain washroom facilities in a clean and sanitary condition is now enforceable,” explains Kristin Onorato, WSPS Health and Safety Consultant. Businesses that fall short can receive orders from inspectors at the Ministry of Labour, Immigration, Training and Skills Development (MLITSD).
These changes stem from the Working for Workers Five Act amendments to the OHSA passed in 2024, signaling the government’s commitment to workplace health and safety standards.
Mark Your Calendar: January 1, 2026
While the cleanliness requirement is already in effect, there’s another crucial deadline approaching. Starting January 1, 2026, employers must keep detailed records of washroom cleanings.
The good news? “Since the requirement to keep records of the cleanings is not in effect until the new year, employers have time to put policies and procedures in place to ensure compliance by that date,” notes Kristin.
That gives you a window of opportunity—but don’t wait until December to act.
What Does “Clean and Sanitary” Actually Mean?
Let’s get specific. “Clean and sanitary condition” isn’t just about appearances.
According to Kristin, it means washrooms should be:
- Free from dirt, grime, germs and contaminants that pose a health risk
- Well-maintained, with prompt repair of broken fixtures like toilets and sinks
- Properly stocked with essential supplies—hand towels, toilet paper, and soap
This is about creating a hygienic environment that protects worker health, not just passing a visual inspection.
The Chemical Safety Connection: WHMIS Requirements
Here’s something many employers overlook: the cleaning products you use might trigger additional legal obligations.
“Some of the products used for cleaning and sanitizing may fall under WHMIS Regulation 860: Workplace Hazardous Materials Information System,” Kristin points out.
How to Know If WHMIS Applies
Take time to assess your cleaning products. If they have:
- Hazardous symbols on the label
- Safety Data Sheets (SDSs)
Then they’re regulated under WHMIS, and you must:
- Ensure products are properly labeled
- Make SDSs available to workers
- Train employees on safe use, handling, and storage of each product
- Provide PPE training (gloves, masks, etc.) if required by the SDS, including safe use, care, and disposal
This isn’t optional—it’s a legal requirement for all hazardous products used, handled, or stored in your workplace.
How Often Should You Clean?
There’s no one-size-fits-all answer. The regulation wisely recognizes that cleaning frequency depends on your specific situation.
Consider these factors:
- How often is the facility used?
- How many people use it?
- What type of workplace do you operate?
Industry Examples
High-traffic environments (restaurants, retail): May need cleaning several times daily
Office settings: Could require cleaning every few days or once weekly
Manufacturing facilities: Typically need daily cleaning
The golden rule? “Clean as often as required to meet the legislative requirement to keep the washroom clean and sanitary at all times,” advises Kristin.
Best Practices: The Checklist Approach
Want to ensure compliance while maintaining standards? Bathroom cleaning checklists are your friend.
“This helps to establish a process and procedures for cleaning, and sets a standard for what ‘clean’ looks like,” says Kristin. “Providing pictures of how the washroom should look can be beneficial.”
Essential Checklist Elements
Your checklist should include:
- Date and time of cleaning
- Signature of the person performing the cleaning (employee or contractor)
- Contact information for reporting if the washroom is found in poor condition
- Specific tasks completed (toilets cleaned, supplies restocked, etc.)
This documentation serves double duty: it creates accountability now and prepares you for the 2026 record-keeping requirements.
2026 Record-Keeping Requirements: What You Need to Know
Ontario Regulation 480/24 spells out exactly what’s expected. Starting January 1, 2026, your cleaning records must:
1. Include Specific Information
Document the date and time of the two most recent cleanings of each washroom facility
2. Be Accessible to Workers
You have two options:
Option A: Post records in a conspicuous place in or near the washroom where workers are likely to see them
Option B: Post records electronically, where workers can access them—but you must provide clear directions on where and how to access these records
This transparency requirement ensures workers can verify that washrooms are being properly maintained.
Taking Action: Your Compliance Roadmap
Kristin recommends companies use this transition period wisely to:
Develop or update programs: Review your housekeeping and records retention programs to incorporate the new requirements
Train your team: Ensure workers and supervisors understand both the cleaning standards and record-keeping obligations
Involve safety committees: Your joint health and safety committee (JHSC) or health and safety representative should check washroom conditions and verify records as part of monthly workplace inspections
Establish clear procedures: Create standardized processes so everyone knows what’s expected
Getting Support
The Workplace Safety and Prevention Services (WSPS) offers resources to help Ontario employers navigate these requirements:
Building Blocks Program
Connect with a WSPS consultant for support developing programs, policies, and procedures covering:
- Housekeeping
- Records retention
- Workplace inspections
- Chemical management
Training Resources
WHMIS Awareness (Free course, 30 minutes)
WHMIS Online Training (eCourse, 1.5 hours)
Additional Resources
- WHMIS: what you need to know about hazardous materials in the workplace
- MLITSD Occupational Hygiene Campaigns Toolkit: WHMIS and Exposure to Chemical Agents
The Bottom Line
These new requirements represent more than just regulatory compliance—they’re about respecting your workers’ health and dignity. Clean, well-maintained washrooms are a basic workplace right that employees deserve.
With the January 1, 2026 deadline approaching, now is the time to:
✓ Assess your current cleaning practices ✓ Develop or refine your documentation systems ✓ Train your team on new requirements ✓ Review your cleaning products for WHMIS compliance ✓ Establish record-keeping procedures
Don’t wait until inspectors come knocking. Use these next few months to build a comprehensive, compliant washroom maintenance program that protects both your workers and your business.
Call Kitchener Clean to know how you can get your facility up todate:
You can reach us at info@kitchenerclean.com or (519) 513 3965
Remember: The information in this article is accurate as of its publication date. For the most current information on compliance requirements, consult with the Ministry of Labour, Immigration, Training and Skills Development or qualified health and safety professionals.