On August 20, 2021, Toronto’s Medical Officer of Health, Dr. Eileen de Villa, strongly recommended that local employers institute a workplace vaccination policy to protect employees and the public from COVID-19.

Toronto Public Health is introducing a workplace toolkit including guidance on developing a workplace vaccination policy. The policy should explain its purpose, specific actions workers must take including providing proof of vaccination or a medical exemption, and timelines.

Dr. de Villa and Toronto Public Health strongly recommend that, at a minimum, workplace vaccination policies require:

• workers to provide proof of their vaccination status 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 time-limited; and
• unvaccinated workers to complete a vaccination education course on the risks of being unvaccinated in the workplace.

Employers should also identify how workers’ vaccination status information will be collected and protected in accordance with applicable privacy legislation and explain the level of risk posed by COVID-19 in each unique workplace setting.

Employers can find more information and may apply to host an on-site vaccination clinic through the City’s COVID-19: Vaccine Information for Employers webpage.

This recommendation follows the City of Toronto’s announcement that all City of Toronto employees must be fully vaccinated by October 30.  

Employers are encouraged to reach out to a Mathews Dinsdale lawyer for assistance in drafting a workplace vaccination policy to ensure legal compliance and that the policy is tailored to the needs of the particular workplace.

We will continue to update our clients with information as soon as it becomes available. If you have any questions about this topic, other COVID-19 related questions, or would like assistance with developing and/or reviewing pandemic plans, please do not hesitate to contact a Mathews Dinsdale lawyer, or refer to the Firm’s COVID-19 website resources.