Post-Construction Cleaning and Ontario's Construction Regulations

Post-construction cleaning is often treated as the last, simple step before handover. Legally and practically, it is not simple. Until the project is handed over, a cleaning crew working in a new build or a fit-out is working on a construction project, with the same site rules and many of the same hazards as the trades. This guide explains how Ontario's construction rules apply to cleaning crews and what a general contractor or owner should expect from a post-construction cleaning company. Our existing checklists cover the cleaning tasks themselves; this article covers the rules around them.

The legal framework

Health and safety on Ontario construction projects is governed by the Occupational Health and Safety Act (OHSA) and its Construction Projects regulation, O. Reg. 213/91. Other regulations apply alongside it, including the rules on designated substances and on worker training. The key idea for cleaning crews is that the regulation applies to the project, not to the type of trade, so a cleaning company working on site is an employer on a construction project with duties to its own workers.

Constructor and employer: who is responsible for what

The OHSA gives the constructor, usually the general contractor or the owner acting as constructor, overall responsibility for health and safety on the project and for making sure every employer and worker on site complies with the Act and regulations. Each employer, including the cleaning contractor, is responsible for its own workers: their training, their equipment and their safe work practices. In practice, that means the cleaning company follows the constructor's site rules and also manages its own crew's safety.

Site orientation and personal protective equipment

Most sites require every worker to complete the constructor's site orientation before starting. Under O. Reg. 213/91, workers on a construction project must wear protective headwear and protective footwear, and other PPE such as eye protection, hearing protection or respirators is required where the hazards call for it. A cleaning crew arriving in running shoes is not ready to work on an active site.

• Complete the constructor's site orientation before the first shift
• Hard hats and safety footwear on every worker while the site is an active project
• High-visibility clothing where the site requires it
• Eye protection and respiratory protection matched to the dust and chemicals involved
• Sign in and out using the site's procedure

Dust: why dry sweeping is a problem

Construction dust is not ordinary dust. Cutting and grinding concrete, masonry, tile and some other materials creates respirable crystalline silica, and silica is a designated substance in Ontario under the Designated Substances regulation (O. Reg. 490/09). Exposure has to be controlled. For cleaning crews, that changes the method: dry sweeping and blowing dust with compressed air put fine dust back into the air, while HEPA-filtered vacuums and wet or damp methods capture it. Respiratory protection may be needed depending on the work and the levels of dust present.

Asbestos and other designated substances in renovations

Renovations in older buildings can disturb materials that contain asbestos or other designated substances. Under the OHSA, the owner of a project must prepare a list of the designated substances present at the site, and that list must be provided to the contractors before they start. Asbestos work on construction projects is governed by its own regulation (O. Reg. 278/05), which sets out how asbestos work must be done and who may do it. A post-construction cleaning crew should never clean up suspected asbestos debris; work must stop and the constructor must be told.

• Ask the constructor for the designated substances list before cleaning starts on a renovation
• Treat dust in areas where asbestos work took place as off-limits unless the constructor confirms clearance
• Stop and report any suspect material uncovered during cleaning

Working at heights

Final cleans often involve high windows, ledges, light fixtures and the tops of cabinets. Ladders must be the right type and in good condition, and work near open edges or on elevated platforms brings in the regulation's fall protection rules. Workers on construction projects who may use certain fall protection systems must complete approved working at heights training under Ontario's training regulation (O. Reg. 297/13). Plan high work with the constructor so the right access equipment is available.

Chemicals on a construction site

Post-construction cleaning uses stronger products than daily cleaning: residue removers, adhesive and paint removers, and floor finish strippers. These are covered by WHMIS, with labels, safety data sheets and worker training required. The basics are covered in our guide to WHMIS for cleaning chemicals.

On site, keep the contractor's own chemicals separate from the trades' materials, and do not use another trade's products without checking the SDS.

Paperwork a general contractor will ask for

• A current WSIB clearance certificate for the cleaning company
• A certificate of commercial general liability insurance
• Proof of required training, such as working at heights where it applies
• The cleaning company's health and safety policy and any site-specific safe work procedures
• A crew list for site sign-in

CMG Clean holds WSIB clearance and commercial liability insurance, and both certificates come with our construction quotes or on request. To get them for your project file, contact us for a quote.

Why the first item protects the constructor and the owner is explained in our guide to WSIB clearance for cleaning contractors.

Timing the cleaning around the project

Because dust keeps falling for days after the trades leave, post-construction cleaning usually runs as a rough clean after the heavy work, a final clean before handover, and a touch-up after furniture and fixtures go in. Each pass should be scheduled with the constructor so it does not clash with trades still on site. The cleaning phases and what each one includes are explained on our page about post-construction cleaning in Toronto.

For debris removal and dust control on larger sites before the final clean, see construction site cleanup in Toronto.

What to agree before the first visit

A short pre-start conversation between the constructor and the cleaning contractor prevents most problems on site. Agree these points in writing:

• Which areas are ready for cleaning, and which are still active work zones
• Access times, sign-in procedure and where the crew can park and store equipment
• Who removes bulk construction waste, and where cleaning debris goes
• Water and power the crew may use
• How deficiencies found during cleaning, such as damaged finishes, are reported
• The standard expected at handover, ideally with a walk-through at the end

Electrical and building systems

Near the end of a project, electrical panels, fixtures and building systems may be energized and still being commissioned. Cleaning crews should not wet-clean live electrical equipment, open panels or move temporary wiring, and should keep water away from electrical rooms. If an area has exposed wiring or open panels, it should be left until the electrician confirms it is safe.

A handover standard everyone agrees on

Disputes at handover usually come from different ideas of clean. Agree a handover standard in advance: which surfaces must be dust-free, whether inside cabinets and drawers are included, how windows and frames are to be left, and how floors should look after protection is removed. A joint walk-through before the final invoice closes the job cleanly for both sides.

How CMG Clean works on construction projects

Our crews complete the constructor's site orientation, wear the PPE the site requires, and follow the constructor's directions on access and restricted areas. We include a current WSIB clearance certificate and our certificate of insurance with construction quotes, and we use HEPA-filtered vacuums and damp methods for construction dust rather than dry sweeping.

This article is a plain-language summary, not legal advice. Check the current OHSA, O. Reg. 213/91 and related regulations, and the constructor's own site rules, for the requirements on your project.