Bill 190 for Schools: Ontario Washroom Compliance Guide 2025

What Ontario's Bill 190 Means for Schools

If you manage facilities for an Ontario school — whether you're a principal, custodial supervisor, or school board administrator — Bill 190 applies to you.

Starting July 1, 2025, Ontario schools must comply with new washroom cleaning requirements under OHSA s.25.3. And starting January 1, 2026, you'll need to keep written records proving compliance.

Here's what school administrators need to know about Bill 190, the recordkeeping requirements, and the penalties for non-compliance.

Bill 190 and OHSA s.25.3: The New Standard for School Washrooms

Bill 190 amended Ontario's Occupational Health and Safety Act by adding section 25.3, which requires employers to ensure washrooms are "maintained in a sanitary condition."

For schools, this means:

Elementary, middle, and high schools must keep all student and staff washrooms clean
Both public and private schools are covered
The law applies to washrooms used by students, teachers, staff, and visitors

The enforcement date is July 1, 2025. After that date, Ministry of Labour inspectors can issue orders or penalties if your school's washrooms aren't properly maintained.

This isn't a vague suggestion. It's a legal requirement with teeth.

O. Reg. 480/24: The Recordkeeping Rule Schools Can't Ignore

Complying with the cleaning standard is one thing. Proving you've complied is another.

That's where O. Reg. 480/24 comes in. Starting January 1, 2026, schools must keep records showing:

The date and time of the two most recent cleanings for each washroom
Records must be readily available for inspection

This means if a Ministry of Labour inspector shows up at your school, you need to produce proof that every washroom was cleaned at least twice recently — with timestamps.

Paper logbooks can work, but they're easy to lose, hard to audit, and often incomplete. Digital systems like Kempt automatically timestamp every cleaning and store records securely in the cloud.

Why Recordkeeping Matters for Schools

Schools face unique challenges:

Multiple washrooms across large buildings or campuses
High traffic volumes (hundreds of students per day)
Different custodial staff working various shifts
Potential for illness outbreaks if hygiene slips

Without a reliable recordkeeping system, it's nearly impossible to prove compliance during an inspection. And starting in 2026, non-compliance comes with real financial consequences.

Bill 30 Administrative Penalties: The Cost of Non-Compliance

Bill 30 introduced administrative monetary penalties (AMPs) for health and safety violations in Ontario. These penalties take effect January 1, 2026 — the same day the recordkeeping requirement kicks in.

For schools that fail to comply with OHSA s.25.3 or O. Reg. 480/24, the Ministry of Labour can now issue fines without going to court.

Penalties can include:

Fines for individual violations
Orders to immediately fix non-compliance
Potential work stoppages in extreme cases

School boards operate on tight budgets. A single preventable fine can mean less money for classrooms, sports programs, or student support services.

The good news? These penalties are entirely avoidable. You just need a system that works.

What Schools Need to Do Right Now

Here's a practical checklist for school administrators:

1. Audit Your Current Cleaning Schedule

How often is each washroom cleaned? Do you have a written schedule? Are custodial staff following it consistently?

If you can't answer these questions confidently, you have a compliance gap.

2. Implement a Recordkeeping System

Paper logs are better than nothing, but they're prone to errors and hard to manage across multiple washrooms and shifts.

Digital systems automatically record the date and time of each cleaning, making compliance effortless.

3. Train Custodial Staff

Your custodial team needs to understand:

Why Bill 190 matters
How to log cleanings properly
What happens if records aren't kept

Clear training prevents confusion and ensures everyone's on the same page.

4. Prepare for Inspections

Ministry of Labour inspectors can visit without warning. You need to be able to quickly show records for any washroom they ask about.

If you're using paper logs, where are they stored? Who's responsible for them? Can you find the right page in under 60 seconds?

Why Schools Are Choosing Digital Compliance Solutions

Many Ontario school boards are moving away from paper logs for good reasons:

Automatic timestamps: No more handwritten dates that could be inaccurate or falsified
Centralized records: Access logs for any washroom, any time, from anywhere
Audit trails: Prove who cleaned what and when
Inspection-ready: Pull up records instantly when an inspector visits
Less administrative burden: No more chasing down paper logs or deciphering messy handwriting

For a detailed overview of Ontario's requirements, see our complete Bill 190 guide.

The Bottom Line for Ontario Schools

Bill 190 isn't optional. Starting July 1, 2025, schools must maintain sanitary washrooms under OHSA s.25.3. And starting January 1, 2026, you must keep records proving compliance — or risk penalties under Bill 30.

The clock is ticking. Schools that wait until the last minute will scramble to implement systems and train staff while managing everything else on their plate.

Schools that act now will be compliant, confident, and ready for inspections.

Kempt makes Bill 190 compliance automatic for Ontario schools — see pricing.

This article is informational only and not legal advice. Consult a lawyer or the Ministry of Labour for advice specific to your business.