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Middlesex-London Health Unit

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Primer for Preventive Measures in the Workplace, Including Mandatory COVID-19 Vaccination Policies

Vaccines are a safe and effective way to protect individuals from COVID-19

The current landscape of the COVID-19 pandemic continues to evolve; as of March 2022, COVID-19 transmission rates are high but moving in a downward trajectory. The Ministry of Health has responded to this evolution by implementing policy changes, including the removal of mandatory proof of vaccination for patrons in non-essential service settings effective March 1, 2022, and the lifting of mandatory masking in most settings effective March 21, 2022.

Employers and business owners continue to have an obligation to maintain a safe work environment for their staff and patrons. COVID-19 screening upon entry at facility, physical distancing, masking, hand hygiene, and good ventilation are important public health measures that can help to reduce the risk of COVID-19 transmission. In addition to these preventive measures, a workplace COVID-19 vaccination policy is a critical tool that employers should implement to help protect their workers, reduce absenteeism due to COVID-19 related illness, and maintain continuity of their operations.

COVID-19 vaccines continue to be a safe and effective way to help stop the spread of COVID-19, reduce the risk of outbreaks and protect against serious illness. Vaccination is the single most effective public heath measure to reduce the spread of COVID-19. Promoting vaccine uptake through mandatory vaccination policies can help to establish safe and supportive environments for staff and patrons.

The Middlesex-London Health Unit continues to strongly recommend that all local employers and business operators require or strongly recommend all employees, contractors, or visitors who are involved in any in-person activity to be up-to-date with regards to their COVID-19 vaccination status, with the rare exception of those individuals who cannot be vaccinated due to permitted exemptions (medical and other protected grounds under the Ontario Human Rights Code).

Workplace vaccination policies can be updated as the COVID-19 pandemic evolves and should reflect the workplace risk of transmission and risk of severe illness.

This primer provides guidance on steps that can be taken to establish a mandatory COVID-19 vaccination policy and examples of relevant polices and procedures.

Please see the guidance below to assist in the development of your workplace policies.

Applicable Legislation

The policy should adhere to the Occupational Health and Safety Act, the Ontario Human Rights Code and applicable privacy laws.

The information provided in this primer is for general information purposes. It does not contain legal advice and should not be relied on or treated as legal advice. Those persons, businesses or organizations for whom these recommendations are intended are encouraged to seek their own legal advice with respect to their own specific workplaces, organizations, and circumstances.

Key Components of a Mandatory COVID-19 Vaccination Policy

1) Identify the scope and purpose

  • Explain the purpose of the policy including the risks of COVID-19 and to whom the policy applies (e.g., employees, contractors, students, volunteers and/or customers/patrons).
  • Highlight the benefits of having a high COVID-19 vaccination rate in the workplace, including reduced risk of infection and outbreak, reduced absenteeism, and enhanced staff and customer confidence in returning to the business.

2) Promote and enable COVID-19 vaccination in the workplace

  • Strongly encourage employees to get vaccinated and create policies to enable this.
  • Provide information about COVID-19 vaccines from credible sources such as the Ministry of Health and the Middlesex-London Health Unit.
  • Provide the link to the MLHU website about where to get vaccinated in the Middlesex-London region.
  • Where possible, provide paid leave and/or transportation to staff to get vaccinated.
  • Offer flexible hours or paid sick days if staff have side effects after getting vaccinated.

3) Continue to promote and enable all other COVID-19 prevention measures

  • It is strongly recommended that individuals continue to comply with COVID-19 prevention measures, including screening for COVID-19 risk factors, wearing a mask or face covering when indoors, hand hygiene, and monitoring for symptoms of COVID-19.

4) Ensure open and transparent communication

  • Have a clear communication plan for staff and patrons to introduce the policy.
  • Establish continuous dialogue with staff and patrons to provide education as necessary, and to manage understanding and expectations related to the mandatory vaccine policy and COVID-19 prevention measures.

*Implement additional requirements for higher risk workplaces

Higher risk workplaces are those that serve clients at risk of severe outcome from a COVID-19 infection and include health care settings and congregate living settings (e.g., long-term care homes, retirement homes, group homes, shelters, correctional facilities, etc.).

It is strongly advised that higher risk workplaces create mandatory COVID-19 vaccination policies that include the following requirements:

I. List action steps employees must take

Workplace policies should require workers to provide one of the following:

  • Proof of up-to-date vaccination status:
    • An up-to-date vaccination status means having received a full primary series of a COVID-19 vaccine or combination of COVID-19 vaccines authorized by Health Canada (e.g., two doses of a two-dose vaccine series, or one dose of a single-dose vaccine series); and any relevant booster dose.
    • As of March 2022, individuals aged 12 and up are eligible to receive a primary series plus a booster dose.
    • Methods of providing such proof could include a vaccination receipt (printed or electronic – i.e. from the Government of Ontario's website), or a government-led proof-of-vaccination system.
  • Written proof of a medical reason (APPENDIX C – Sample COVID-19 Vaccination Medical Exemption Form), provided by a licensed physician or nurse practitioner that sets out:
    • A documented medical reason for not completing a primary series of COVID-19 vaccines, AND
    • the effective time-period for the medical reason;
  • A signed written declaration from a person who is not able to obtain COVID-19 vaccine for a reason related to a protected ground under the Ontario Human Rights Code, including a description of the need for protection and accommodation (APPENDIX D – Sample Form for Request of COVID-19 Vaccination Exemption Due to a Relevant Human Rights Protected Ground).

II. Set deadlines for individuals to complete these steps

  • Specify a reasonable date for individuals to demonstrate compliance with the policy.

III. Establish provisions for unvaccinated individuals

  • Alternative options should be available for individuals unable to complete their vaccination series for medical reasons and those who decline the vaccine for medical exemptions and/or reasons protected by Ontario Human Rights Code.
  • Alternative options should reflect the workplace risk of transmission and risk of severe illness.
  • List alternative options in which an individual could continue to report to work without being vaccinated.
  • Options may include staff reassignment, relocation, modified work, or use of additional personal protective equipment.
  • At times of high community incidence of COVID-19, rapid testing protocols can also be considered (APPENDIX E – Sample COVID-19 Rapid Antigen Testing Procedure). It is important to note that these protocols are not preventative and are not a replacement for immunization and should be used only in instances where vaccination is not possible.

    If relocation or reassignment is not possible, consider if unvaccinated workers may use vacation or unpaid leave until some later time when it is safe for them to return to the workplace. Learn more about Rapid Antigen Testing.

 IV. Establish consequences for non-compliance

  • Outline consequences for staff and patrons who do not fulfil the requirements of the policy.
  • Staff who do not comply with the policy may be subject to discipline.

V. Address privacy considerations

  • The policy should protect a worker’s privacy as much as possible and specify how individual vaccination status of workers will be used, shared and disposed of 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 workers, their families, and the general public.
  • When collecting, sharing, storing and disposing of 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.
    • Individuals should be instructed to use the least intrusive mechanism to disclose vaccination status. Limit information collected to what is necessary.
    • Ensure personal health/vaccination information is stored securely and protected in accordance with privacy legislation.

VI. Designate staff contact

  • Identify who staff should contact for questions about the policy and to whom individuals should disclose proof of vaccination.

COVID-19 and Ontario’s Human Rights Code

Questions and Answers
The Ontario Human Rights Commission has developed a series of questions and answers for understanding your human rights and obligations during the COVID-19 pandemic. Read the Q&A here →

Date of creation: September 3, 2021
Last modified on: March 23, 2022