Washroom Compliance for Ontario Property Managers — A Practical Guide

If you manage commercial properties in Ontario, Bill 190 and O. Reg. 480/24 land squarely in your world — but the compliance picture is more complicated than it might appear at first glance.

Unlike a single-employer workplace where responsibility is clear, commercial properties typically involve a landlord, multiple tenants, and potentially one or more cleaning contractors. Figuring out who is responsible for washroom compliance — and how to actually execute it — requires working through a few layers.

This guide is for commercial property managers, condominium corporation managers, and others who oversee multi-tenant buildings in Ontario.

The Core Question: Who Is the ‘Employer’ Responsible for Washroom Records?

Ontario Regulation 480/24 places the washroom cleaning record obligation on employers — the entities that employ workers who use the washroom facility. In a commercial property context, this means the obligation primarily sits with the tenants, not with the landlord or property manager.

Here’s why: each tenant in your building is an employer with workers. The washroom that their workers use — whether it’s a private washroom inside their leased suite, a common-area washroom on their floor, or a shared washroom in the building — is a facility “provided to workers” by their employer (either directly, or through the building’s common facilities).

The practical compliance picture, though, is rarely so clean. Consider the following scenarios:

Scenario 1 — Private washrooms in leased suites: A law firm that has its own washrooms inside its leased office space. The law firm is clearly the employer. The cleaning of those washrooms is their operational responsibility, as is the cleaning record. If they use a building janitorial service, they still own the compliance obligation.

Scenario 2 — Common-area washrooms shared by multiple tenants: A multi-tenant office floor with shared men’s and women’s washrooms used by workers from three different companies. Who maintains the cleaning record? Technically, each employer has an obligation to make cleaning records accessible to their workers. In practice, the building — through the property manager — is the one cleaning the washrooms and would be the logical party to maintain the record. But this needs to be made explicit.

Scenario 3 — Single-tenant buildings under a facilities management agreement: A property manager who manages a building on behalf of an owner and has a facilities management agreement that includes janitorial services. In this case, the property manager may be the party with the most practical ability to implement a compliant system.

What Property Managers Should Do

Given the complexity above, here’s the practical approach for property managers:

Step 1: Audit which washrooms are in common areas vs. tenant spaces

Common-area washrooms — those controlled and cleaned by the building rather than by any individual tenant — are where property managers have direct operational responsibility. These are the washrooms you should prioritize for compliance.

Washrooms inside leased suites are primarily the tenant’s responsibility. However, your service agreement with cleaning contractors likely covers these too, and your tenants may look to you for guidance.

Step 2: Implement cleaning records for all common-area washrooms

For every common-area washroom in your properties, implement a compliant cleaning record immediately. This means:

• A visible cleaning log (paper or QR-based) in every common-area washroom

• A cleaning program that logs the date and time of each cleaning

• Records that reflect at least the two most recent cleanings at all times

This is directly within your operational control as property manager, and there’s no dependency on tenant action.

Step 3: Communicate the requirement to tenants

Send a clear communication to all tenants explaining:

• Bill 190 and O. Reg. 480/24 are now in force

• Employers are required to ensure cleaning records are maintained for washrooms their workers use

• For common-area washrooms, the building is maintaining records (if this is true) — here’s how workers can access them

• For private washrooms inside leased suites, the tenant is responsible for maintaining their own records

This communication serves two purposes: it helps tenants meet their compliance obligations, and it documents that you notified them of the requirement. In any future dispute about responsibility, that paper trail matters.

Step 4: Review your cleaning contracts

Your janitorial service contracts should be reviewed in light of Bill 190. Specifically:

• Does the contract specify what gets logged and when?

• Who is responsible for maintaining the cleaning records — the contractor or the building?

• If the contractor maintains records, do you have access to them for compliance reporting?

• If a Ministry of Labour inspector asks to see cleaning records, can you produce them quickly?

If your janitorial contracts predate January 2026, they likely don’t address these questions. Update them or add a compliance addendum.

Step 5: Ensure worker access to records

For common-area washrooms, your tenants’ workers need to be able to access the cleaning records. This means:

• For paper logs: the log must be posted prominently inside or near the washroom — not at the building reception desk or in the property management office

• For QR-based systems: the QR code should be mounted visibly in the washroom with a clear “Scan for cleaning record” label

• For electronic systems: workers need to be told how to access the records, without requiring them to get login credentials from their employer or from building management

Lease Provisions and Compliance Obligations

If you’re negotiating new commercial leases or renewing existing ones, consider adding a clause that:

• Acknowledges Bill 190 and O. Reg. 480/24

• Specifies which party is responsible for maintaining cleaning records for which washrooms

• Requires tenants to notify you if Ministry of Labour orders are received relating to washroom facilities in your building

This protects both parties and prevents future ambiguity about responsibility. Your legal counsel can help draft appropriate language.

Multi-Residential and Condo Properties: A Different Analysis

For property managers who manage multi-residential buildings or condominium corporations, the analysis is different.

In a residential building, the tenants are residents, not workers in the OHSA sense. The washroom compliance obligation under Bill 190 applies to employer-employee relationships — it doesn’t apply to residents using washrooms in their own homes.

However, if your residential building has staff — a superintendent, maintenance workers, security personnel, or property management staff who work in the building — those workers are covered by OHSA. Any washroom facility they use as part of their work (the staff washroom in the mechanical room, the washroom in the management office, etc.) is subject to the Bill 190 compliance requirement.

For condominium corporations, the employer relationship is more complex — the condominium corporation employs (or contracts) workers, and the OHSA obligations apply to those workers. Common amenity washrooms used by condo staff (concierge, cleaning, security) require cleaning records. Washrooms in common amenity areas used by residents are a different analysis — legal counsel familiar with condominium law and OHSA can provide guidance specific to your situation.

The Property Manager’s Advantage: Scale and Systems

Here’s where property managers have an advantage over most other employers dealing with Bill 190: you’re already operating cleaning programs at scale. You already manage contracts, scheduling, and building maintenance systems. Adding washroom cleaning documentation to that infrastructure is a natural extension.

The most efficient path for property managers with a portfolio of multiple buildings is a digital QR-based system that provides centralized visibility across all locations. When a Ministry of Labour inspector wants to see cleaning records for a washroom in one of your buildings, the ability to pull up a timestamped history in thirty seconds — from a laptop or a phone — is far more impressive than a folder of paper logs.

It also scales. Managing fifty buildings with paper logs requires a significant manual audit process. Managing fifty buildings with a central digital dashboard is a five-minute review.