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Vaccination Policy Now Mandatory for Toronto Employers


*This blog was updated on December 10, 2021.

If you don’t already have one in place, now may be a good time to create a vaccination policy for your workplace.

Toronto’s Medical Officer of Health has strongly recommended that city employers develop a vaccination policy to protect their staff and the public. According to Regulation 557/2, issued by the Ontario government, all businesses must comply with any advice, recommendations and instructions issued by the Chief Medical Officer of Health or by a regional/municipal medical officer of health.

So, if you have a business in Toronto, you must also have a vaccination policy in place.

On December 9, 2021, the Ontario COVID-19 Science Advisory Table issued a recommendation that health officials conduct weekly voluntary rapid testing in schools and workplaces in areas that report 50 new COVID-19 cases per million per day. If a health unit or area’s new daily cases approach 250 per million people per day, the recommendation is to test unvaccinated and partially vaccinated people two to three times per week.

Vaccines are critical in reducing the spread of COVID-19 and protecting us from serious illness. Several provinces, including Ontario, have mandated proof of vaccination to access certain non-essential services and businesses.

A workplace vaccination policy will help you encourage your employees to get vaccinated. It’ll help make your workplace COVID-secure.

What do the Toronto Public Health guidelines say about a workplace vaccination policy?

The Toronto Public Health guidelines strongly recommend that a vaccination policy include:

  • A requirement for proof of vaccination from employees. The vaccines taken should be the ones approved by Health Canada or the World Health Organization. Employees without vaccination records will be considered unvaccinated.
  • If an employee is unvaccinated due to a medical exemption, they must clarify whether the exemption is temporary or permanent. The exemption should be issued by a licensed doctor or nurse practitioner. It doesn’t need to state the reason for the exemption.
  • Unvaccinated staff must take a vaccination education course. They should also sign a declaration affirming they understand the risks of COVID-19 and the benefits of the vaccine.
  • Employers are advised to set a reasonable deadline for employees to comply with the policy.
  • The policy should remind workers of the provision of paid time off to get vaccinated. Employees are also entitled to up to three paid sick days if they experience side effects from the vaccine.
  • The vaccination status information of employees should be gathered and stored as per the privacy law. Employers should identify ways to protect personal health information of staff.
  • Information collected should be limited to name of employee and date of vaccination for each dose.
  • Vaccination information should be stored securely and separately from the employee’s personnel file.
  • The policy should provide alternatives (regular COVID-19 testing, modified or remote work) for employees who either refuse to get vaccinated for reasons protected by the Human Rights Act or are medical exemptions.
  • If alternative options aren’t viable, unvaccinated staff may be asked to use their vacation or unpaid leave till it’s safe for them to come into work.

Toronto Public Health has also invited employers to apply to host a vaccination clinic onsite.

Other recommended precautions include:

  • Following public health measures and guidance (physical distancing, PPE) even after getting vaccinated.
  • Continuing daily screening of employees, including those fully vaccinated, using COVID-19 symptoms questionnaire. While vaccines prevent serious illness, vaccinated people can still transmit the virus.
  • If a fully vaccinated employee comes into contact with someone who tests positive, they don’t have to self-isolate if they show no symptoms. But if symptoms appear, they must self-isolate at once and get tested.

You can view the complete list of recommendations issued by the Toronto Medical Officer of Health here.

Do you need further support in creating a vaccination policy for your workplace?

Peninsula’s experts can help you create a comprehensive vaccination policy. We also offer digital tools that’ll make tracking the progress of vaccinations in your workplace quick and easy.

Whether you need help creating company policies or any other health and safety, HR, or employment advice, our specialists are here for you. To learn more, call us today at 1 (833) 247-3652.