COVID-19 Vaccination Policies for Housing Providers – Indoor Amenities
The government has advised that, as of September 22, 2021, Ontarians will need to be fully vaccinated (i.e. two doses plus 14 days post-second vaccine) and will need to provide their proof of vaccination along with photo ID in order to access certain public settings and facilities. Though the text of the proposed Regulation has not yet been published, the government has confirmed to industry associations that apartment buildings and condominiums will not be considered public settings or facilities for the purposes of the government’s vaccination requirement.
Having said that, apartment buildings and condominium corporations may still want to implement their own vaccination rules and policies with respect to the safe use of their non-essential amenities. Multi-residential landlords and condominium Boards will need to consider a number of factors in deciding whether to implement rules, and the form of those rules, including: liability for failing to take steps; financial considerations; how the rule will be implemented (e.g. self-reporting, controlled access system, etc.); and the physical aspects of their particular buildings. We recommend landlords and condominium boards consult with their legal counsel in deciding whether to implement a policy or rule and to discuss what the contents of any rules will be.
The lawyers at Cohen Highley have been assisting housing providers with the development of various COVID-19-related policies and procedures, including most recently the implementation of vaccination policies for their workplaces, and would be pleased to assist in the consideration and implementation of vaccination policies for non-essential amenity spaces in their communities.
If you have any questions or require services in relation to the above, please contact us.