Last updated: September 24, 2021 at 6:30 p.m.

The Government of Ontario announced that it will move the province into Step Three of its Roadmap to Reopen at 12:01 a.m. on Friday, July 16. This guidance will soon be updated with more information.

Since July 16, 2021, bathhouses and sex clubs have been permitted to open with conditions/restrictions in accordance with Step 3 regulations under the Reopening Ontario Act.

The purpose of this document is to assist bathhouse and sex club operators with information related to the Ontario Government’s reopening framework as well as Toronto Public Health requirements to reduce the spread of COVID-19. It is important to know that breaches of some of these directions will constitute offences under provincial regulations or other public health legal requirements.

While we aim to provide relevant and timely information, no guarantee can be given as to the accuracy or completeness of any information provided. This guidance is not intended to nor does it provide legal advice and should not be relied upon or treated as legal advice. Users seeking legal advice should consult with a qualified legal professional. The full Ontario re-opening regulations for Step 3 are available online.

General Guidance for Bathhouses and Sex Clubs

  • Encourage employees to get vaccinated.
  • Ensure that all patrons show proof of being fully vaccinated to access indoor areas of the bathhouse or sex club.
  • Along with HIV/STI/safer sex information, educate patrons about COVID-19 risk reduction in the context of sexual activity.
  • Develop strategies to minimize exposure to COVID-19.
  • Provide staff training on the required public health measures.
  • Limit the number of staff, clients and customers within the bathhouse or sex club premises to allow for physical distancing and to comply with capacity limits, as per provincial regulations.
  • Schedule frequent cleaning and disinfection of high-touch items, surfaces, and areas within the premises.
  • Inform staff and patrons about actions you are taking to keep everyone safe.
  • Visit our website at ca/COVID19 often, as information changes frequently.

Workplace Health and Safety

Safety Plan

Bathhouse and sex club operators must prepare and make available a safety plan. The plan must:

  • Describe measures/procedures that have been or will be implemented in the establishment to reduce COVID-19 spread.
  • Include measures for screening, physical distancing, masks, cleaning, disinfecting, PPE, as well as preventing and controlling crowding.
  • Be in writing and made available to any person for review, on request.
  • Be posted in a place which is visible to workers and patrons.
  • Use the COVID-19 Safety Plan Checklist to develop your safety plan.

Capacity Limits

  • Capacity limits for bathhouses and sex clubs must ensure that all persons on premises can maintain a two metre distance from others, and must not exceed: 25% capacity or 250 people (whichever is less). Not all premises will be able to hold 25% capacity and maintain physical distancing.
  • 25% capacity is determined by taking 25% of the maximum occupant load of the bathhouse or sex club as calculated in accordance with Ontario Regulation 213/07 (Fire Code), made under the Fire Protection and Prevention Act, 1997.
  • Operators must post a sign in a conspicuous location visible to the public that states the capacity limits under which it is permitted to operate. To avoid crowding in specific areas, such as locker rooms, movie rooms, and saunas, operators may post signs with the number of people allowed into each room/space.

Physical Distancing

  • Bathhouse and sex club operators are required to ensure that their employees keep a physical distance of at least two metres throughout the workplace and during eating and rest periods (e.g. lunchrooms, change rooms, washrooms).
  • Operators must ensure that patrons maintain two metres of physical distance from others, except when physical distancing cannot be maintained while participating in the activities for which patrons normally frequent bathhouses or sex clubs.
  • Masks and physical barriers provide added layers of protection, but are not substitutes for physical distancing.
  • Modify and manage the physical space to promote physical distancing. Where possible:
  • Install one-way walkways to reduce close physical interactions.
  • Remove surplus furniture/items from rooms and walkways to allow ease of movement while maintaining physical distancing.
  • Use visual markers (e.g. tape on the floor, pylons, signs) to remind people where to stand to keep two metre/six foot distance from others.
  • Implement physical barriers (e.g. plexiglass) in customer service areas when physical distancing is not possible. The height of the barrier should take into account the tallest user and should consider the user’s breathing zone, which generally extends 30 centimeters or 12 inches around (and above) the mid-point of a person’s face.
  • Move or tape off seating to encourage physical distancing.
  • Close off alternate lockers and showers.
  • Operators are required to ensure that patrons maintain two metres physical distance from other groups of persons while in line or congregating outside the bathhouse or sex club.
  • Post physical distancing signs at all entrances, employee rooms, and public areas (e.g. service counters).

Personal Protective Equipment (PPE)

The use of non-medical masks or face coverings is required in all indoor public spaces, under a City of Toronto by-law and O. Reg. 364/20. The City by-law requires businesses with indoor spaces that are open to the public to develop a policy on the wearing of masks. Use the Mask By-law Checklist and Sample Policy.

PPE for Employees

  • Bathhouse and sex club operators must ensure that staff wear appropriate PPE, including surgical/procedure mask and eye protection (goggles or face shield).
  • Additional PPE may be required for other roles within the workplace (e.g. providing first aid). Operators must determine when and what PPE is required, and ensure that it is worn by workers.
  • Operators must train employees on how to safely put on and take off PPE.
  • AIDS Service or Health Organizations that send employees and volunteers into bathhouses or sex clubs (e.g. counsellors, outreach and harm reduction workers) are required to ensure that their staff and volunteers wear the appropriate PPE, and are appropriately trained on how safely put on and take off PPE.

Masks for Patrons

  • Bathhouse and sex club operators must ensure that patrons wear a mask or face covering which covers their mouth, nose and chin during any period in which they come within two metres of another person, unless any of the following exceptions apply:
  • If a mask or face covering cannot be worn while participating in the activities for which patrons normally frequent bathhouses or sex clubs.
  • A patron is exempted from wearing a mask or face covering.

Health Screening

Bathhouse and sex club operators must comply with any advice, recommendations, and instructions issued by the Office of the Chief Medical Officer of Health on screening employees and patrons (O Reg 364/20). Note that temperature checks for staff and patrons are not required, nor recommended.

Screening Employees

  • Bathhouse and sex club staff must complete a health screening questionnaire before or when a worker enters the workplace at the beginning of their day or shift (active screening). The questions can be completed on paper, online or by asking staff directly:
  • In-person screening can be completed on paper using the staff screening questionnaire (also available in other languages).
  • Essential visitors, including employees and volunteers from AIDS Service or Health Organizations (e.g. counsellors, outreach and harm reduction workers), should be actively screened before entering the premises.
  • Workers who received a COVID-19 vaccination in the last 48 hours and are experiencing mild headache, fatigue, muscle ache and/or joint pain may be permitted to enter the workplace if:
  • They are not experiencing any other symptoms and pass all other screening questions; and,
  • They wear a surgical/procedure mask for their entire work shift. The mask may be removed only to eat or drink while keeping two metres distance from others.

Screening Patrons

  • Bathhouse and sex club operators must ensure that all patrons complete a health screening questionnaire (active screening) before they enter the premises.
  • Staff may screen patrons using the patron screening guide or ask patrons to complete and present the provincial screening tool for customers

Attendance Tracking

  • Bathhouse and sex club operators must maintain daily attendance records for all staff, workers and volunteers for 30 days.
  • Operators are required to record the name and contact information of every patron that enters the establishment and keep these records for 30 days to support public health contact tracing efforts (e.g. name, date, time, and contact information).
  • Patrons may be reluctant to provide their name and contact information due to concerns about privacy and stigma. Inform patrons that this information is mandatory for entry into the bathhouse or sex club. Also, reassure patrons that their information will be kept confidential and secure, and only shared with Toronto Public Health in case COVID-19 contract tracing is required.
  • Encourage staff and customers to download the COVID Alert app so they can be notified directly if they have been in close contact with someone who was contagious with COVID-19. However, the COVID Alert app is not a substitute for staff and patron attendance tracking.

Hand Hygiene and Respiratory Etiquette

  • Post Wash Your Hands, Cover Your Cough, and Protect Yourself signs in high traffic areas.
  • Ensure hand sanitizer (70-90% alcohol concentration) and hand-washing facilities are available throughout the bathhouse.
  • Ensure an adequate supply of liquid soap, paper towel, hand sanitizer, tissues, and waste receptacles throughout the premises, including public and employee areas.
  • Glove use is not a substitute for proper hand hygiene.
    • If employees use gloves it is important to change them every hour, or more often, as necessary (e.g. when changing tasks).
    • Hands should be washed and/or sanitized between changes.
    • When gloves are removed, new gloves must be used each time.
  • Educate staff on proper hand hygiene and respiratory etiquette.

Enhanced Cleaning and Disinfection

  • Implement rigorous and frequent environmental cleaning and disinfection of all frequently touched surfaces, at least twice a day or more frequently, as needed.
  • All bathhouse and sex club areas accessible to the public, including bar areas, washrooms, locker rooms, showers, saunas, hot tub areas, movie rooms, and fitness areas, must be cleaned and disinfected as frequently as is necessary to maintain a sanitary condition.
  • Equipment, tools and furniture that must be shared should be cleaned and disinfected regularly, including between users (e.g. computer stations, cashier stations, debit/credit terminals, cleaning carts, fitness equipment, patron locks/keys, slings, benches, sofas, beds, gloryholes).
  • Private sex rooms should be cleaned and disinfected after each use, including bed, locker, walls, door, handles. Ask patrons to leave linens (e.g. sheets, towels) in the room so to avoid transporting soiled materials to the cashier area.
  • All linens must be laundered and disinfected after patrons have finished using them.
  • Choosing cleaners and disinfectants:
  • Cleaners break down grease and other organic material from surfaces. Most regular household cleaning products are effective at reducing the amount of germs on surfaces.
  • Disinfectants kill germs that remain on surfaces even after cleaning.
  • Look for cleaning and disinfectant products with an 8-digit Drug Identification Number (DIN) to confirm it is approved for use in Canada.
  • Refer to Health Canada’s list of hard surface disinfectants for use against COVID-19.
  • Cleaning/disinfection wipes should only be used for surfaces.
  • Check the expiry dates of products and always follow manufacturer’s instructions.
  • Ensure adequate ventilation when using products (e.g. open windows, doors, or use fans).
  • Thoroughly wash hands with soap and water immediately after cleaning the setting.
  • Review Public Health Ontario’s Cleaning and Disinfection for Public Settings fact sheet.
  • Educate staff on how to maintain a clean workplace during COVID-19, including:
    • Proper use of cleaning agents and disinfectants, including required amount of time that the product needs to remain wet on a surface to work effectively.
    • Safety precautions and requirements for use of mask and gloves.

Heating, Ventilation and Air Conditioning (HVAC) Systems

  • Conduct or have the property owner/landlord conduct a regular review of HVAC systems to ensure it is operating properly.
  • Consider consulting an HVAC specialist to determine if the HVAC system is suitable for a bathhouse setting.
  • Increase the introduction and circulation of outdoor air by maximizing the outdoor air ratio of the HVAC system settings, or by opening windows and doors, where possible. Avoid recirculating air.
  • Use the highest efficiency filters that are compatible with the HVAC system.
  • Keep areas near HVAC inlets and outlets clear.
    • Seating should be arranged away from areas with high airflow (i.e. not in front of air vents).
  • If ceiling fans are used ensure an upward airflow rotation.
  • If portable fans are used, limit the blowing of air across people and surfaces by positioning them to provide an upward movement of air.
  • Portable air purifiers/cleaners equipped with a HEPA filter could potentially reduce exposure to COVID-19. If used, follow the manufacturer’s directions (and possibly the advice of a service professional) to decide where best to place the device. Follow the manufacturer’s instructions on maintenance. Portable air cleaners are not a substitute for proper ventilation and other preventive measures.
  • Review the COVID-19: Transmission, Aerosols and Ventilation fact sheet for more information.

Water Filtration and Disinfection

  • Bathhouses and sex clubs should review and implement guidance for Recreational Water Facilities in maintaining pools, hot tubs, and other water amenities.
  • Adequate water filtration and disinfection should remove or inactivate the virus that causes COVID-19.
  • Ensure the facility’s water filtration and disinfection systems (i.e. with chlorine or bromine) are maintained and operating properly.

Fitness Facilities

Food, Drink and Dance Facilities


  • Encourage staff and patrons to get vaccinated for COVID-19. Read and share information about the vaccine and where to get vaccinated.
  • Consider developing workplace policies that encourage vaccination and make it easier to get a vaccine, such as allowing staff time to go for vaccine appointments.
  • Post signs and share COVID-19 vaccine resources, available in multiple languages, with staff, workers and patrons.

Provincial Proof of Vaccination Policy

  • Beginning September 22, 2021, patrons are required to show proof of being fully vaccinated to access indoor areas of some businesses and settings, including bathhouses, sex clubs, restaurants, bars, cinemas, and facilities used for recreational fitness activities. Learn more at Proof of COVID-19 Vaccination.

Learn more about how COVID-19 vaccines help make your workplace safer.

Other Resources

More Information

Provincial orders under the Reopening Ontario Act. Please visit regularly for updates or call us at 416-338-7600.

Download this information as a PDF.