To help reduce the risk of COVID-19 transmission, public health authorities across Ontario are recommending employers establish a vaccination policy. See information on establishing a vaccination policy for your workplace.

Employers have an obligation to maintain a safe work environment for their workers. To help reduce the risk of COVID-19 transmission, a workplace vaccination policy is an important measure employers should implement to protect their workers and the public. Information included on this web page has been adapted from Toronto Public Health.

Assess your workplace risk of transmission by considering the following:

• Does your workforce have a high vaccination rate?
• Can workers keep at least two metres apart while performing their work?
• Are workers required to be in close contact with others? How long and how often are workers in close contact with other workers or patrons?
• Does your workplace have physical barriers when workers cannot keep distance from each other, good ventilation and personal protective equipment (PPE) to protect workers?
• Do you have workers who may be at risk for severe illness from COVID-19? Some people may have reduced immunity due to age, pre-existing health conditions or medical treatments.
• Is your workplace able to offer alternative work for people who require accommodation, for example remote work?

The workplace policy should adhere to the Occupational Health and Safety Act, the Ontario Human Rights Code, and privacy laws. Please note: the information provided on this web page does not contain legal advice and should not be relied on or treated as legal advice; those for whom these recommendations are intended may seek their own legal advice for their specific circumstance.

Key Components in a Vaccination Policy

1. Identify the scope and purpose.

• Explain purpose of the policy including the risks of COVID-19.
• Vaccination against COVID-19 is one of the best ways to protect workers. The Delta variant of the coronavirus is more contagious, with greater risk for severe illness and hospitalization.
• Explain who the policy applies to. Will the policy apply to all workers, contractors, and/or agency staff? Is there a separate policy for customers?
• Have a clear communication plan to inform workers about the policy.

2. List action steps workers must take. When necessary to prevent the spread of COVID-19, workplace policies should require workers to provide proof of vaccination, with vaccines approved by Health Canada or the World Health Organization. Alternatively, workers may need to:

• Indicate that they have a medical exemption, including if the reasons are temporary or permanent. The medical exemption should be written by a licenced doctor or nurse practitioner and does not need to include the reason for the exemption.
• Complete a vaccination education course, with a signed declaration stating that they understand the risks of COVID-19 and the benefits of vaccination. The vaccination education course should include information on: How the COVID-19 vaccines work; Vaccine safety related to the development of the COVID-19 vaccines; The benefits of vaccination against COVID-19; Risks of not being vaccinated against COVID-19; and Possible side effects of COVID-19 vaccination.

3. Set deadlines for when the actions must be taken. Specify a reasonable date when workers must demonstrate compliance with the workplace policy.

4. List available supports for vaccination. Demonstrate your commitment to supporting workers to get vaccinated. Ways to support workers to get vaccinated include:

• Providing vaccine information from credible sources or translated resources
• Supporting vaccine champions to initiate conversations with their peers Providing paid leave to get vaccinated
• Reminding workers that they are entitled to up to three paid sick days, if they have side effects from the vaccine Offering incentives such as gift cards, prizes or company swag
• Hosting an on-site vaccination clinic

5. Provisions for Unvaccinated Workers Your policy should list alternative options for workers who decline to get vaccinated for reasons protected by the Human Rights Act, or who are unable to complete their vaccination series for medical reasons. Some options to consider include:

• Use of additional PPE, frequent COVID-19 testing, worker relocation, and modified work or reassignments.
• In the event of a COVID-19 outbreak, unvaccinated and partially vaccinated workers (who have only received one dose of a two-dose COVID-19 vaccine series) are not be permitted to work in the outbreak area. Workers without vaccination records should be assumed to be unvaccinated.
• If reassignment is not possible, consider if unvaccinated workers may use vacation or unpaid leave until it is safe for them to return to the workplace.

6. Non-Compliance Outline the potential consequences for workers who do not fulfill the requirements of the policy.

7. Privacy considerations The policy should specify how individual vaccination status of employees will be used by employers to mitigate the health-related risks of COVID-19. Information about workers’ vaccination information must be protected in accordance with applicable privacy legislation. Knowing your workers’ vaccination status may be important to help you take appropriate action quickly, in the event of COVID-19 cases in your workplace, to protect employees, their families, and the general public. When collecting information about a worker’s vaccination status:

• Identify ways to safeguard workers’ personal health information.
• Limit information collected to the worker’s name and date of vaccination for each dose.
• Keep worker vaccination information separate from their personnel file.
• Ensure personal health/vaccination information is kept in a secure manner and only used when required.

8. Staff contact

• Identify who at your organization staff should contact with questions about the policy, to request accommodation, or for more information how to comply with the policy. The policy should also indicate the person to whom workers should provide proof of vaccination.

Resources:

• Key Components of a Workplace Vaccination Policy
• COVID-19 and Ontario’s Human right Code Questions and Answers (Ontario Human Rights Commission)
• COVID-19 vaccines and workplace health and safety (Government of Ontario) 

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