Bill 190 Compliance Guide for Ontario School Boards

Ontario school boards face a distinctive challenge when it comes to Bill 190 washroom compliance: scale.

A single urban school board may be responsible for dozens or hundreds of buildings, each with multiple washroom facilities across multiple floors. The Ministry of Labour’s requirements under O. Reg. 480/24 — that every washroom must have a cleaning record accessible to workers — creates a compliance obligation that extends across every single one of those facilities.

For school board facility directors, maintenance managers, and HR leaders trying to get their hands around this, here is a practical guide to what Bill 190 requires and how boards across the province are approaching compliance.

Who Counts as a ‘Worker’ in a School Board Context?

Before getting into the specifics of the regulation, it’s worth clarifying who these washroom records actually need to be accessible to.

Under the OHSA framework, the requirement to make cleaning records “readily accessible” applies to workers — meaning employees of the organization. In a school board context, this means:

• Teachers and educational assistants

• Custodial and maintenance staff

• Administrative staff

• Occasional teachers, supply staff, and contract workers

• Before-and-after-school program staff

Students are not workers under OHSA, so the legal obligation to make records accessible applies to staff, not the student population. That said, many boards are choosing to make records accessible to anyone who enters the facility — including students and parents — as a matter of transparency and community trust.

The Scale Problem

Consider a mid-sized Ontario school board with 60 schools. Assume an average of 8 washrooms per school — including staff washrooms, student washrooms by gender, and accessible washrooms. That’s potentially 480 individual washroom facilities, each requiring a separate cleaning record posted on-site and accessible to workers.

Under a paper-based system, this means 480 clipboards, 480 paper log templates, a system for distributing and replacing logs as they fill up, and a manual process for verifying that each log is current and being accurately maintained.

For boards that haven’t done this before, the setup effort alone is significant. The ongoing management is more so.

This is why most school boards evaluating their Bill 190 compliance strategy are looking at digital cleaning log systems rather than paper-based approaches. The difference in management overhead at scale is substantial.

What the Record Must Contain — and What ‘Accessible’ Means in a School

The regulation is clear on content: the record must show the date and time of the two most recent cleanings for each washroom facility.

Accessibility in a school setting has some additional nuances worth thinking through:

For staff washrooms, accessibility is straightforward — the record should be posted visibly inside or near the washroom in a place staff will notice.

For shared washrooms (staff and students use the same facility), the record still needs to be accessible to staff. Posting it inside the washroom is the safest approach.

For custodial staff, the act of cleaning and logging their own work in a digital system covers both the compliance obligation and their operational record-keeping in one step.

For supply and occasional teachers, who may not be familiar with where electronic records are stored, posting a visible QR code in or near the washroom is the simplest way to ensure accessibility without requiring any briefing.

Practical Compliance Approaches for School Boards

Based on the scale and staffing realities of Ontario school boards, here are the approaches that work best:

Option 1: QR-Based Digital Logs (Recommended for Boards)

A unique QR code is mounted in each washroom. When custodial staff complete a cleaning, they scan the QR code. The cleaning is logged with an automatic timestamp. Workers who want to check the record can scan the same QR code with any smartphone.

For school boards, the advantages of this approach are significant:

• A central dashboard gives facility directors real-time visibility across all schools and all washrooms

• Missed cleanings are automatically flagged without requiring a manager to physically inspect each building

• Compliance reporting for the entire board can be generated in minutes rather than days

• Custodial staff don’t need to carry paper logs or fill in forms — a scan takes seconds

• The record is always current and always accessible, which means any worker at any school can check any washroom record without calling facilities

Option 2: Centrally Managed Paper Logs

For boards with limited budget or technology infrastructure, a paper-based system is still legally compliant — but requires more operational discipline.

A standardized log template should be used across all schools. Each log should be printed, laminated where possible, and mounted visibly in each washroom. Custodial staff should be trained to record the date and time after each cleaning (not at the end of a shift). Supervisors should do weekly checks to verify logs are current and accurately maintained.

The weakness of paper at school board scale is that there’s no central visibility. A facility director responsible for 60 buildings cannot efficiently verify that 480 paper logs are being maintained correctly without physically visiting each location.

Option 3: Hybrid Approach

Some boards are using a hybrid model: QR-based logs for custodial compliance (cleanings are scanned and logged digitally) with a printed summary posted in each washroom for physical accessibility. This gives the auditability of digital records with the visible physical presence that makes accessibility unambiguous.

Staff Communication and Training

Bill 190 requires that if cleaning records are provided electronically, workers must be given clear instructions on where and how to access them. For school boards, this has training implications.

At minimum, boards should:

Brief all staff on the new requirement. Workers should know that cleaning records now exist and that they have the right to access them. A one-page memo or staff briefing at the start of the school year is sufficient.

Post access instructions in washrooms. Whether you’re using QR codes or a URL, the access method should be posted visibly in or near the washroom so workers don’t need to ask anyone for help.

Train custodial staff on the logging process. This is the most important piece — custodial staff are the ones creating the records. They need to understand what’s required (a scan or entry after each cleaning, not at the end of a shift), why it matters, and what happens if records are incomplete.

Include Bill 190 compliance in onboarding. Supply teachers and new hires should be informed of the records system as part of their orientation.

What Inspectors Will Look For in Schools

Ministry of Labour inspectors visiting Ontario schools for Bill 190 compliance will assess the same things they assess in any workplace — but school settings have some additional considerations:

Multiple washrooms mean multiple records. Inspectors will not look at one washroom and assume the others are compliant. If your board has consistent digital logging across all facilities, this is straightforward. If each school is managing its own paper system, inspector results will vary from school to school.

Custodial staffing gaps create compliance gaps. Schools often have custodial staff changes — illness, short-term supply, summer changeover. A good system ensures that any custodial worker — regular or supply — knows how to log a cleaning. This should be built into your custodial onboarding process.

After-hours cleaning is common in schools. Cleanings that happen after students leave (afternoon/evening shifts) still need to be logged. Workers who arrive the next morning should be able to see that the washroom was cleaned the previous evening. Digital systems handle this naturally — the timestamp reflects when the cleaning occurred.

Starting Point for School Boards Not Yet Compliant

If your board hasn’t yet addressed Bill 190 washroom compliance, here’s where to begin:

4. Do a washroom inventory. Count the number of washroom facilities across all your schools. This is your compliance scope.

5. Audit your current cleaning documentation. Are cleanings currently being recorded anywhere? What format? Is it accessible to workers?

6. Choose a system. Paper at small scale, digital at board scale. The cost difference between paper and digital is smaller than most boards expect, and the management savings are significant.

7. Establish a training plan for custodial staff. The cleaning record is only as good as the people creating it.

8. Document your rollout. Being able to demonstrate to an inspector that you implemented a compliance program — with training records, system documentation, and rollout dates — is itself a form of compliance evidence.

The Ministry of Labour has made clear that Bill 190 is being actively enforced. Ontario school boards, as large public employers with significant washroom footprints, are exactly the type of organization that enforcement activities tend to focus on. The time to get compliant is now, not when an inspector is standing in front of you.