Preparing Your Washrooms for September 1st: A Manitoba Employer's Checklist

5 hours ago

Last updated: June 12, 2026

On September 1, 2026, every workplace in Manitoba will be required to provide free pads and tampons at no cost to employees. Manitoba is the first province in Canada to make this a workplace safety obligation — and the Workplace Safety and Health Branch will enforce it through routine inspections.¹

If you're an HR or facilities manager, you have about six weeks of buffer before the deadline starts to feel uncomfortable. This is a step-by-step playbook for getting your washrooms ready — written for the person who actually has to make it happen.

What changes on September 1, 2026 (and what doesn't)

The regulation amends Manitoba's Workplace Safety and Health Regulation under the Workplace Safety and Health Act. In plain English, three things become non-negotiable as of September 1:

Pads and tampons must both be provided. Not one or the other.
They must be free. No vending machines that require coins. No reimbursement schemes.
They must be in washrooms or another accessible location. The standard expectation is the workplace washrooms employees actually use.

What doesn't change: the existing Workplace Safety and Health Act's general inspection regime. Inspectors will use the same mechanism they use for other workplace safety obligations.² No new department. No new inspector role. No new paperwork — unless you create some (we recommend you do; more on that in Step 6).

Step 1 — Audit every washroom on your premises

Before you order anything, walk the building with a clipboard. For each washroom, write down:

How many toilets / stalls it has
The gender designation (women's, men's, universal, accessible)
Whether it already has a covered disposal bin near each toilet
Whether there's wall space for a dispenser at roughly waist height

Two things people get wrong on this step:

They forget the men's washrooms. The regulation does not limit free products to women's washrooms. Trans and non-binary employees menstruate. So do some men. Stocking only the women's washrooms is not compliant and not inclusive.

They forget the rarely-used washrooms. The shop floor washroom that gets used twice a week still counts. The basement washroom near the boiler room still counts. If an employee can use it, it needs to be stocked.

Step 2 — Choose between dispensers, baskets, or open shelves

The regulation does not specify a delivery mechanism. You have three real options:

Wall-mounted dispensers ($20–$300 upfront, per unit). Cleanest path to compliance. Keeps inventory off countertops. Easiest to audit at a glance: it's full or it's empty.
Open baskets on the counter. Zero upfront cost. Works for very small workplaces. Tends to look messy and runs empty fast because people take handfuls.
Stocked shelves or drawers. A middle ground. Works if your washrooms have built-in storage. Less obvious to employees, which can mean lower uptake.

For most workplaces above 25 employees, the dispenser pays back its cost in a few months — cleaner washrooms, less waste, and almost zero "is this still stocked?" questions to HR.

Step 3 — Set your restock cadence (treat it like toilet paper)

The most useful mental model for restock planning: treat menstrual products like toilet paper. They're consumable. They have a predictable burn rate. Running out is unacceptable.

A rough planning number Canadian employers use: about 22 units (pads + tampons combined) per menstruating employee per year — roughly 2 units per period × 11 cycles.³ Plan for buffer in shared bathrooms (visitors, contractors, the occasional spike).

Then assign ownership. Pick one of three models:

Facilities / cleaning contractor — they restock during the regular cleaning round. Lowest friction. Make sure to add it to their scope of work in writing.
HR ops — works only if HR is on-site daily. Don't pick this for a multi-site employer.
An external supplier on subscription — delivers a tested SKU mix monthly or quarterly. Best for employers above 50 staff who don't want to manage inventory.

Step 4 — Install covered disposal near every toilet

This is the step most employers miss. The regulation is about access to free products, but it operates inside the broader Workplace Safety and Health Regulation, which expects sanitary disposal in any washroom where menstruation products are used.

Practical translation: a small covered bin within arm's reach of every toilet. Not under the sink across the room. Not at the end of the row. Beside the toilet, behind the door, lid that closes.

If a washroom is currently used by men only and has no disposal bins, that needs to change before September 1. Same with universal and accessible washrooms.

Step 5 — Communicate the change to your team (without making it weird)

The single biggest cause of employee complaints in workplaces that have rolled out free period products: nobody told employees the products are free. People see a basket, assume it's for emergencies only, and don't take what they actually need.

A short, matter-of-fact internal announcement works best. Something like:

Starting September 1, 2026, free pads and tampons are available in every washroom on the premises. This is in line with Manitoba's new workplace safety regulation. They're for anyone who needs them — take what you need, when you need it. Facilities will restock weekly. If you find a dispenser empty, ping [name] in [system].

Make sure cleaning and facilities staff get a short, separate brief. Their job description just expanded by one task, and they need to know the restock schedule and where to report supply issues.

Step 6 — Document compliance for Workplace Safety and Health inspectors

Manitoba Workplace Safety and Health Branch inspectors enforce the regulation through their regular inspection cycle. They are not announcing themselves in advance. When they show up, you'll want to be able to demonstrate that you have:

A written policy or procedure stating products are provided in every workplace washroom
A restock log (date, washroom, who restocked) — even a shared spreadsheet works
A named owner of the restock cadence (the facilities lead or contractor)
Proof of the employee communication you sent in Step 5

None of this is technically required by the regulation as written. All of it is the difference between a five-minute inspection and a long one.

A 30-day countdown for procrastinators

If you're reading this in August and you're not ready yet, here's the minimum-viable rollout:

Days 1–3: Walk the building. List every washroom. Count toilets per washroom.
Days 4–7: Order dispensers and a first-month supply (or order open baskets and an initial supply if you're going minimalist).
Days 8–14: Install dispensers. Install or relocate disposal bins.
Days 15–20: Brief facilities / cleaning staff. Set the restock log.
Days 21–25: Send the employee announcement.
Days 26–30: Inspect everything one more time. Adjust if any washroom is harder to keep stocked than you expected.

It's doable in a month. It's much easier in two.

Frequently asked questions

Do I have to put pads and tampons in men's washrooms in Manitoba?

Yes. The regulation requires access in workplace washrooms — it does not exclude men's washrooms, and trans and non-binary employees who use men's washrooms menstruate. The same goes for universal and accessible washrooms.

How much does it actually cost?

Federal benchmarks put it at roughly $10–$25 per menstruating employee per year, plus a one-time $20–$300 for dispensers and disposal setup.⁴ A 50-person workplace with about 25 menstruating employees is looking at roughly $625 / year in products and a one-time $400–$1,200 in setup for a couple of dispensers and disposal bins.

What happens if my workplace isn't ready by September 1, 2026?

An inspection finding for a Workplace Safety and Health Regulation violation can result in an order to comply with a deadline. Repeated non-compliance can escalate. Beyond the legal side, the bigger cost is usually the employee-relations one: word travels.

Do small businesses in Manitoba have to provide free menstrual products?

Yes. There is no size exemption. A two-person workplace with one shared washroom is required to provide free pads and tampons in that washroom.

Can I use a basket instead of a dispenser?

Yes. The regulation doesn't specify the delivery mechanism — products just need to be free and accessible. Baskets work for small workplaces. They tend to look messy and run empty fast in higher-traffic washrooms.

What kind of disposal bins are required?

The regulation requires sanitary disposal in any washroom where menstruation products are used. In practice: a covered bin within arm's reach of every toilet, including in men's and universal washrooms.