# How Long Do You Need to Keep Washroom Cleaning Records in Ontario?


It's one of the most common questions Ontario employers are asking since Bill 190 came into force: "How long do I have to keep these cleaning records?"

It sounds like a simple question. The answer requires a bit more nuance than most guides online provide — because it depends on who you are, what sector you're in, and what your broader compliance strategy looks like.

Here's the complete picture.

## What O. Reg. 480/24 Actually Says

Ontario Regulation 480/24 — the regulation that came into force on January 1, 2026 under the Occupational Health and Safety Act — is surprisingly specific about what the record must contain, but relatively silent on how long you need to keep it.

The regulation specifies that the posted record must show the date and time of the two most recent cleanings for each washroom facility. This is the active display requirement: at any given moment, workers should be able to see the last two cleanings for their washroom.

What the regulation does not specify is a mandatory archival or retention period. It does not say "keep records for six months" or "keep records for one year." The ongoing display of the two most recent cleanings is what's mandated.

This creates an important practical question: if you only need to display the two most recent cleanings, do you even need to keep historical records?

The answer, from a risk management perspective, is clearly yes.

## Why You Should Keep Records Well Beyond the Minimum

Even though the regulation doesn't prescribe a specific retention period, there are several strong reasons to maintain a meaningful archive of cleaning records:

**Ministry of Labour inspections** When a Ministry of Labour inspector visits your workplace, they may ask to review cleaning records to assess whether your washroom maintenance program is genuinely active or merely performative. An employer who can only show the two most recent cleanings — with no history — will have a much harder time demonstrating a real compliance program than one who can produce months of consistent, timestamped records.

**Worker complaints and grievances** If a worker files a complaint about washroom conditions, the Ministry of Labour may investigate. Historical cleaning records are your primary evidence that the washroom was being maintained appropriately. Without them, it becomes a "he said, she said" situation with no documentation to support your position.

**OHSA-related proceedings** If a health and safety incident occurs in or near a washroom facility, cleaning records could become relevant to any legal proceeding that follows. Courts and tribunals look more favourably on employers who maintained thorough records than those who can only document the most recent two cleanings.

**Internal auditing and quality control** A rolling history of cleaning records lets your facilities team identify patterns — washrooms that are consistently cleaned late, locations where cleaning frequency drops off, and time periods where coverage was inadequate. You can't manage what you don't measure.

## What Expert Guidance Recommends

While the regulation itself doesn't set a retention period, published guidance from Ontario public health units recommends retaining washroom cleaning records for a minimum of 12 months. This aligns with common practice across other regulated documentation in Ontario workplaces — many health and safety records are maintained for at least one year as a baseline.

For some sectors, sector-specific regulations set additional requirements. Healthcare facilities operating under Ontario Regulation 67/93, for example, have more prescriptive documentation requirements that go beyond the OHSA washroom provisions.

## Construction Projects: A Different Rule

If you're a constructor on a construction project, the rules are different and more specific.

Under Ontario Regulation 482/24 — the companion regulation to O. Reg. 480/24 that applies specifically to construction sites — constructors must keep a log that covers cleaning and servicing records for the past six months or the duration of the project, whichever is shorter.

This six-month period is a prescribed retention requirement, not guidance. It means:

*   If your project runs three months, you keep records for the full project
    
*   If your project runs eighteen months, you maintain records for the most recent six months at all times
    

This is distinct from the standard employer requirement — it's a legislated retention window, not just best practice.

## Sector-Specific Retention Considerations

Beyond the OHSA framework, several sectors have additional compliance contexts that affect how long cleaning records should be kept:

**Healthcare facilities** Long-term care homes, hospitals, clinics, and similar facilities operate under both OHSA and sector-specific health regulations. In these settings, infection prevention documentation requirements may necessitate longer retention periods — often two years or more. If you operate in a healthcare setting, consult your compliance team for the applicable standard.

**Food service** Restaurants, cafeterias, and food processing facilities are subject to public health inspections in addition to OHSA. Public health inspectors may review facility maintenance records as part of their inspections, and the applicable retention standard may be set by the Ministry of Health rather than the Ministry of Labour.

**Schools and publicly funded institutions** School boards and publicly funded facilities often have their own records management policies that exceed the OHSA minimum. If your organization has a records management policy, that policy may set a longer retention period that you are expected to follow.

## The Practical Answer: Keep Records for at Least 12 Months

For most Ontario employers, the practical standard is clear: keep a full history of washroom cleaning records for a minimum of 12 months, and consider 24 months if you operate in a higher-risk sector or are frequently subject to regulatory oversight.

If you're using a paper-based system, this means preserving completed log sheets rather than discarding them. A binder per washroom, filed by month, stored in your records management system.

If you're using a digital system, most platforms retain all historical cleaning data automatically. The burden of retention essentially disappears — every cleaning is permanently timestamped and retrievable. This is one of the often-overlooked practical advantages of moving from paper to digital logs.

## What a Ministry of Labour Inspector Actually Wants to See

Based on how OHSA inspections typically work, a Ministry of Labour inspector visiting your facility regarding washroom compliance will likely want to see:

1.  That the active record — the two most recent cleanings for each washroom — is posted and accessible
    
2.  That the records look credible: consistent timing, reasonable frequency, evidence of actual cleaning activity rather than pre-signed entries
    
3.  That you can demonstrate your cleaning program is genuinely active, not retroactively documented
    

Inspectors are experienced at identifying paper-log compliance that exists on paper only. Gaps in records, identical timestamps, suspiciously round numbers, entries made in the same handwriting at the same time — all of these raise flags.

A digital system with automatic timestamping eliminates most of these credibility concerns. The record reflects exactly when the QR code was scanned — no human adjustment possible.

## Practical Takeaway

Here's a simple decision framework for Ontario employers on the question of retention:

| Situation | Recommended Retention |
| --- | --- |
| Standard Ontario employer (OHSA only) | Minimum 12 months |
| Healthcare or regulated sector | 24 months or per sector guidance |
| Construction project | 6 months or project duration (whichever is shorter) |
| Organization with records management policy | Whichever period is longer — OHSA baseline or internal policy |

When in doubt, keep more rather than less. The cost of retaining an extra year of digital records is essentially zero. The cost of not having records during an inspection or complaint investigation is much higher.

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*This article is for informational purposes only and does not constitute legal advice. For compliance guidance specific to your workplace, consult a qualified legal advisor or visit* [*ontario.ca*](http://ontario.ca)*.*