COVID-19 Vaccination Policies for Housing Providers

Last week, following the City of Toronto’s announcement that it would be mandating vaccination for its employees, Toronto Public Health issued a recommendation that all employers in the City require proof of vaccination.

The government also filed a new Regulation (O. Reg. 577/21) which amends Section 2 of Schedule 1 to Ontario Regulation 364/20. The new regulation, which can be found here, provides that a business or organization shall operate in compliance with any advice, recommendations and instructions issued by the Office of the Chief Medical Officer or Health or by a medical officer of health requiring the business to establish, implement and ensure compliance with a COVID-19 vaccination policy or setting out the precautions and procedures that businesses must include in their COVID-19 vaccination policies.

Recently, the Toronto District School Board announced that it was mandating COVID-19 vaccines for its staff, trustees and visitors.

Many businesses, organizations, universities and colleges across Ontario have made similar announcements or have released their policies requiring all employees, contractors and visitors to be vaccinated. Universities and colleges have also implemented policies requiring proof of vaccination for students living in on-campus housing.

In strongly recommending that all employers have a vaccination policy, Toronto Public Health identified minimum requirements that should be part of any vaccination policy:

  • Workers to provide proof of vaccination series approved by Health Canada or the World Health Organization
  • Unvaccinated employees to provide written proof of a medical reason from a physician or nurse practitioner that includes whether the reason is permanent or temporary
  • Unvaccinated workers to complete a vaccination education course on the risks of being unvaccinated in the workplace

In addition to the above minimum requirements, it will be necessary for employers to consider what precautions or protections will be required for those who are unvaccinated in the workplace (PPE, submitting to regular COVID-19 testing, etc.).

These recent announcements and legislative directives have elevated the standard of care when it comes to employers’ obligations under health and safety legislation and are also important measures to facilitate the prompt and necessary vaccination against COVID-19 for all eligible Ontarians.

Our firm is working with a number of landlords and housing providers who are presently assessing the risks of transmission in their workplaces and we are developing COVID-19 vaccination policies in accordance with the recent recommendations of Toronto Public Health and the lead taken by a number of large employers like the City of Toronto and the Toronto District School Board.

If you require legal advice with respect to developing and implementing a COVID-19 Vaccination Policy for your workplace, contact Kristin Ley at Cohen Highley LLP.

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