2025 OHSA Updates Essential Compliance Guide for Ontario Employers Constructors
- 5 min read
- June 3, 2025
Ontario’s Occupational Health and Safety Act (OHSA) is about to undergo significant legislative changes. Starting July 1, 2025, amendments introduced under the Working for Workers Five Act, 2024 (Bill 190) and the Working for Workers Six Act, 2024 (Bill 229) will impact all employers and constructors across the province. Understanding and preparing for these changes is critical to maintaining legal compliance and ensuring workplace safety.
Why This Matters: Legislative Compliance and Workplace Safety
Failure to comply with new regulations can lead to penalties, fines, and increased liability. These changes also reflect the Ontario government’s commitment to improving workplace conditions, supporting worker dignity, and enhancing accountability across sectors.
This blog post outlines all key updates and provides a compliance checklist for employers and safety managers.
Bill 190 – Working for Workers Five Act, 2024: Key OHSA Amendments
1. Enhanced Requirements for Washroom Facilities
One of the major focuses of Bill 190 is improving worker access to clean and adequate washroom facilities.
New employer responsibilities include:
- Maintaining washroom facilities in a clean and sanitary condition at all times.
- Updating your Health and Safety Program to include the new definition of 'washroom facility'.
- Ensuring accessibility and cleanliness of washrooms for all workers.
- Keeping and maintaining cleaning records, available in paper or electronic format.
- Making cleaning records readily available for inspections or internal reviews.
Key Questions to Ask:
- Are your current washroom facilities compliant with the updated OHSA standards?
- How are you storing and tracking washroom cleaning logs — digitally or manually?
- Have your employees been trained on new hygiene and maintenance expectations?
2. Expanded Definitions to Cover Virtual Environments
The new amendments reflect the modern shift to hybrid and remote workplaces. Updates include revised definitions of:
- "Industrial establishment"
- "Workplace harassment"
- "Workplace sexual harassment"
Each of these now explicitly includes virtual and digital interactions.
What You Should Do:
- Update your Health and Safety Program to include virtual activities in policy definitions.
- Revise employee training and awareness sessions to reflect these changes.
- Address potential risks associated with virtual harassment in all remote or hybrid environments.
3. Changes to Workplace Postings
Employers must now assess how workplace notices are displayed, especially with the growing use of digital communication.
Ensure that:
- You’ve evaluated what documents will be physically posted vs. electronically posted.
- All electronic postings are easily accessible to workers — whether on a portal, intranet, or shared system.
- Workers have clear instructions on where and how to access these postings.
4. Joint Health and Safety Committee (JHSC) Flexibility
With Bill 190, in-person JHSC meetings are no longer mandatory. Employers now have the option to host virtual meetings.
Next Steps:
- Update your JHSC Terms of Reference to formally allow for virtual meetings.
- Communicate these changes clearly to all committee members.
- Ensure minutes and safety documentation are securely stored and shared digitally.
Bill 229 – Working for Workers Six Act, 2024: More Protections for Workers
1. Personal Protective Equipment (PPE) – Proper Fit & Function
The changes introduced under Bill 229 place a stronger emphasis on the proper use of Personal Protective Equipment (PPE).
Employers must now ensure that:
- PPE is provided, worn, and used as required.
- PPE is the proper fit for each worker and suitable for specific work conditions.
- Different body types, genders, and workplace tasks.
- Special equipment required for diverse environments (e.g., chemical protection, visibility gear, ergonomic needs).
2. New Minimum Fines for Repeat Offences
Ontario is now introducing minimum fines (not just maximum penalties) for corporate offenders involved in repeat OHSA violations that lead to:
- Death
- Serious injury
This reinforces the province’s focus on employer accountability and the importance of proactive compliance.
Are You Tracking Legislative Updates?
Employers are advised to maintain an up-to-date Legislative Compliance Tracker that includes:
- All changes from Bill 190 and Bill 229Death
- Implementation dates
- Internal action plans and deadlines
- Records of updates to policies and training
This tracker serves as a compliance audit trail in case of inspections or legal inquiries.
How 4S Consulting Services Can Help You Stay Compliant
Employers are advised to maintain an up-to-date At 4S Consulting Services, we specialize in helping organizations navigate complex OHSA regulations. Our consulting and compliance support includes:
- Legislative compliance audits
- Custom policy and program updates
- Electronic and paper record-keeping solutions
- JHSC support and Terms of Reference updates
- PPE policy reviews and fit testing guidance
- On-site or virtual training
We ensure you’re fully prepared, not just informed.
Final Thoughts: Don’t Wait Until the Deadline
With the new changes taking effect July 1, 2025, the time to act is now. Delaying could mean non-compliance, penalties, or worse — harm to your workforce.
