Bill 190 Compliance for Retail Stores — 2026 Guide

If you operate a retail store in Ontario — from a single boutique to a multi-location chain — your washrooms are now subject to mandatory cleaning log requirements under Bill 190. Many retail owners don't realize this applies to them because their washrooms are 'staff only.' It doesn't matter. If any worker uses the washroom, you need records. This guide covers what's required and how to get compliant in 10 minutes.

Does Bill 190 apply to your retail store?

Yes. Every retail store in Ontario with a washroom accessible to workers must comply with OHSA s.25.3 and O. Reg. 480/24. This includes clothing stores, grocery stores, pharmacies, hardware stores, convenience stores, big-box retailers, shopping mall tenants, and any other retail operation. Even if your washroom is 'staff only' and not open to customers, it's still a workplace washroom under the Act. The only exemption would be if you genuinely have no washroom on premises — but workplace safety regulations require employers to provide washroom access, so this is extremely rare.

What the law requires

01

Clean & Sanitary

All washrooms must be maintained in a clean and sanitary condition. This is a legal obligation under OHSA s.25.3, enforceable since July 1, 2025.

OHSA s.25.3

02

Log Every Cleaning

You must record the date and time of the two most recent cleanings for each washroom. No record means non-compliance.

O. Reg. 480/24

03

Post or Share Records

Cleaning records must be posted near washrooms or made digitally accessible to all workers as of January 1, 2026.

Bill 30 — AMPs

Retail-specific compliance concerns

Retail stores face specific challenges with washroom compliance: Single-washroom operations. Many small retail shops have exactly one washroom, shared by staff. When it's just one facility, a missed log is immediately visible to an inspector. There's no buffer. Part-time and rotating staff. Retail relies heavily on part-time employees. When your Saturday staff is different from your Tuesday staff, consistency in logging breaks down. Paper logs in the back room don't survive shift changes. Shopping mall compliance. If you're a mall tenant, your lease likely requires you to maintain your own staff washrooms — you can't rely on mall common-area washrooms for compliance. Even if your staff uses mall washrooms, your obligation under OHSA s.25.3 is tied to your premises. Seasonal staffing. Retail peaks during holidays when you're busiest and least focused on compliance. This is exactly when an inspector might visit — and when gaps in your records are most likely. Customer-accessible facilities. If customers can use your washroom (common in grocery, pharmacy, and big-box retail), the foot traffic makes cleanliness harder to maintain and documentation even more important.

Common mistakes retail store owners make

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Thinking 'staff only' washrooms are exempt — they're not. Any washroom a worker uses falls under OHSA s.25.3

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Relying on the mall's cleaning staff — as a tenant, you're the employer and responsible for your own compliance

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Only cleaning at open and close — for busy retail locations, the regulation requires records that reflect actual cleanliness throughout the day

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Not training part-time staff on logging — when your Saturday closer doesn't know about the cleaning log, you have a gap in your record

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Assuming your landlord handles it — commercial landlords are not responsible for tenant washroom compliance under OHSA

How to get compliant in 10 minutes

1

Sign up in 2 minutes

Create your free account and add your washrooms. No credit card needed.

2

Print your QR codes

Print them instantly from your dashboard. Takes 10 minutes, no setup.

3

Stay compliant automatically

Staff tap the QR code. Logs are timestamped and inspector-ready automatically.

Frequently asked questions

Ready to get compliant?

Choose the path that works for you.

Take the 2-min compliance checkDownload free PDF checklist

Also see: Bill 190 for Restaurants | Bill 190 for Gyms | OHSA s.25.3 Guide