What Does 'Readily Accessible' Actually Mean Under Ontario Bill 190?

Since Ontario’s Bill 190 came into full force on January 1, 2026, one phrase keeps coming up in conversations with HR managers, facility teams, and property managers across the province:

“Readily accessible.”

The regulation is clear that washroom cleaning records must be readily accessible to workers. What’s less clear to many employers is exactly what that means in practice — and more importantly, what it doesn’t mean.

Getting this wrong isn’t a technicality. Ministry of Labour inspectors are actively visiting Ontario workplaces, and the difference between compliant and non-compliant often comes down to this single requirement.

What the Regulation Actually Says

Ontario Regulation 480/24 under the Occupational Health and Safety Act requires employers to make washroom cleaning records available to workers in one of two ways:

Option 1 — Physical posting

The record must be posted in a conspicuous place in or near the washroom facility, where it is likely to come to the attention of workers.

Option 2 — Electronic access

The record may be made available electronically, provided workers are given clear instructions on where and how to access it.

Both options are legally acceptable. The key word in both cases is the same: the record must be somewhere workers will actually notice it and can access it without asking anyone for permission.

What ‘Readily Accessible’ Does NOT Mean

This is where many Ontario employers are currently falling short. Here are the most common mistakes.

It does not mean “available if someone asks”

If your cleaning records exist in a supervisor’s notebook, an office filing cabinet, or a manager’s email inbox, they are not readily accessible. A worker should not have to request access from a person in authority to see when their washroom was last cleaned.

It does not mean “in a system workers don’t have credentials for”

If your records are stored in a facility management software platform that workers have no login for, and you haven’t given them instructions on how to access it, you are not compliant — even if the records exist.

It does not mean “posted somewhere workers rarely go”

The regulation specifically says the record must be posted “where it is likely to come to the attention of workers.” A printout tucked behind the paper towel dispenser, posted at shoulder height behind the door, or on a cluttered staff bulletin board in a back hallway likely doesn’t meet this standard.

It does not mean “posted once and never updated”

The records must reflect the two most recent cleanings. A sign that says “this washroom is cleaned daily” with no actual date or time is not a cleaning record — it’s marketing copy. The record must show specific, timestamped entries.

Why This Matters More Than Most Employers Realize

The requirement for records to be “readily accessible” exists because the entire purpose of Bill 190’s washroom provisions is worker visibility and accountability. Workers are supposed to be able to see — at any moment — whether their washroom has been cleaned recently.

An inspector visiting your workplace isn’t just going to ask you to produce the records. They’re going to assess whether a worker could independently find and read those records without any assistance.

Think about it from that perspective: if a worker in your facility wanted to know when the third-floor washroom was last cleaned, could they find that information themselves in under 60 seconds without asking anyone? If the answer is no, your records are probably not “readily accessible” in the legal sense.

The Practical Standard: What Compliance Looks Like

The easiest way to understand what “readily accessible” means in practice is to look at what clearly meets the standard:

QR code posted inside or near the washroom

A QR code mounted at eye level inside the washroom, linking to a live digital log that updates with each cleaning. Workers can scan it at any time and see date and time entries. This is the gold standard — it’s always visible, always current, and doesn’t require any instruction beyond a “scan here” label.

A printed log posted prominently inside the washroom

A clearly visible paper log posted at eye level inside the washroom, with dated and timed entries for each cleaning. The log must be updated after each cleaning — not once a week, not at the end of a shift. After each cleaning.

An electronic system with worker access and clear instructions

A digital system where workers can log in, or a public-facing URL that doesn’t require a login, paired with a posted notice in the washroom explaining how to access the records. The notice must give enough detail that a new employee on their first day could find the records without asking a supervisor.

What the Regulation Requires in the Record Itself

Beyond accessibility, the record has to contain specific information. Under O. Reg. 480/24, the record must include the date and time of the two most recent cleanings of each washroom facility. Not one cleaning — two. Not just the date — the time as well.

This means a compliant record always shows at minimum:

• Cleaning 1: Date and time

• Cleaning 2: Date and time (must be the most recent)

If you are using a paper log, every entry needs both fields filled in. If an employee cleans the washroom and only writes the date, that entry is incomplete under the regulation.

Multi-Washroom Facilities: A Note on Separate Records

The regulation applies per washroom facility, not per building. If your workplace has three washrooms — say, one on each floor — you need a separate, accessible record for each one. A single centralized record for “all washrooms” posted in one location probably doesn’t meet the standard, because a worker on the third floor would need to go to a different floor to check the record for their washroom.

Each washroom should have its own accessible record posted in or near that specific facility.

The Safe Harbour: Digital Logs with QR Access

The most defensible compliance approach — and the one that eliminates most of the ambiguity around “readily accessible” — is a digital logging system accessed via QR code posted directly in the washroom.

Here’s why this approach works so well from a legal standpoint:

The record is always in the right location — on the wall of the specific washroom it covers. Workers can access it without asking anyone. It’s visible and prominent. The digital log provides a timestamped audit trail that is automatically updated with each cleaning. If an inspector asks to see records, you can show them the QR code, scan it together, and demonstrate a complete history instantly.

Compare that to a paper log that may be incomplete, a binder in an office, or a spreadsheet that only the facilities manager can open. The QR-based digital approach removes almost every possible compliance gap around the accessibility requirement.

Practical Takeaway for Ontario Employers

Go stand at the entrance to one of your workplace washrooms right now. Ask yourself: if a new worker at your company needed to find out when this washroom was last cleaned, what would they do?

If the answer involves asking someone, logging into a system they’ve never used before, or walking to a different part of the building — your records may not be “readily accessible” in the way the regulation requires.

The good news is that fixing this is straightforward. Whether you choose a printed log posted inside each washroom or a digital QR-based system, the standard is achievable. The important thing is to act now — Ministry of Labour inspectors don’t issue warnings before fines, and the inspections are already happening.