Workplace COVID-19 Vaccine Policies

Mandatory vaccination directives and instructions have been revoked as of March 14 but will be replaced with operational guidance or recommendations from the CMOH and relevant ministry. You can find the technical briefing that speaks about these changes here. Although these Directives are revoked, individual organizations will continue to have the authority to keep requirements in place. Personal protective equipment and rapid antigen tests will also continue to be provided to support health and safety in these settings.

There are many benefits for all workplaces to have an organization specific COVID-19 vaccine policy. It can be part of a COVID-19 Workplace Safety Plan considering specific risks in the organization for COVID-19 transmission, provide an opportunity to provide education and awareness to all employees, and promote higher levels of vaccination in the workplace to increase the safety of employees and the public.

In workplaces, vaccination adds to, rather than replaces, other workplace safety measures. Employers are still required to provide a safe work environment for staff and this can continue to consider COVID-19 prevention measures for their particular workplace.

Workplace COVID-19 Vaccination

Promoting vaccination in the workplace is an important step in ensuring your staff understand the importance of being vaccinated and have an opportunity to receive credible information about vaccines. This will also help them show support for vaccination in the workplace.

Policy Development Information

Important Note: Each business/organization is responsible to implement their own workplace vaccine policy. The Health Unit can provide information about the elements of a policy, as above. The Health Unit cannot approve another business or organization’s workplace vaccination policy.

COVID-19 and mandatory vaccination: Ethical considerations and caveats (World Health Organization policy brief)

There are some elements that would be important to include in your policy:

1. Inform employees. Explain the purpose of the policy and provide clear and strong information on the virus, authorized vaccines, and the vaccination process.
2. Outline if vaccines are highly recommended or required, and for which employees, based on an assessment of the risk of being exposed to the virus, and the risk of transmitting the virus to others, in the workplace. Explain the rationale for this policy.
3. Discuss the Occupational Health and Safety Act, the general duty clause, and Ontario’s Internal Responsibility System, which set out employer, supervisor and worker duties for keeping the workplace safe in the context of a pandemic.
4. Outline what proof of vaccination looks like. For example, seeing a copy of the provincial vaccine clinic record or verbal attestation. From an employer privacy perspective, collect as little vaccine information as possible. Clarifying what it means to be up to date on their vaccinations. See the new guidance on staying up to date (fully vaccinated).
5. Discuss exemptions under the Human Rights Code. The code protects workers with disabilities from discrimination. For example, the risk of an allergic reaction to the vaccine would be considered a medical disability. Employers are required to accommodate exempted workers, on an individual basis, to the point of undue hardship. Identify how medical exemptions will be handled. COVID-19 Vaccination Policies and Human Rights Considerations.
6. Address privacy issues. Address these concerns by outlining why you are collecting the information – e.g., to keep all workers safe – describe how you will use it, how securely it will be stored, and the only purposes this information will be used for. It’s always a best practice to secure consent.

See this policy template and the Workplace Safety and Prevention Services website for this and more information and resources.