Ontario Makes COVID-19 Workplace Screening Mandatory

What the new rules require and the 3 things you should do to comply.

Since the reopening process began, regulatory authorities across Canada have made it clear that employers may implement screening measure to prevent COVID-19 infections in the workplace. Some agencies have even recommended screening as a health and safety measure. On September 26, Ontario became the first province to actually require workplace screening. Here are 6 FAQs explaining the new law and what it does and doesn’t require.

1. Is Screening a Requirement or a Recommendation?
Answer: It’s required. We’ve received questions from a number of OHSI users who aren’t sure whether screening is required or just recommended. The reason for the confusion is that the actual workplace screening guidelines issued by the Ontario Ministry of Health on Sept. 25 are described as “recommendations” and say that employers “should,” rather than “must” or “shall” implement screening. However, that same day, Ontario published new Stage 3 reopening regulations (Regulation 364/20) saying that businesses must follow the MOH screening recommendations. The actual language comes from Section 2(3) of the Regulation: “The person responsible for a business or organization that is open shall operate the business or organization in compliance with the advice, recommendations and instructions issued by the Office of the Chief Medical Officer of Health on screening individuals” (emphasis added).

2. Which Businesses or Organizations Do the Screening Rules?
Answer: The MOH screening rules apply to all businesses in Stage 3 reopening other than healthcare and other essential operations that are subject to a different set of more stringent screening rules.

3. Are Outdoor Workplaces Exempt?
Answer: No. The MOH says screening should be done at not only indoor but also “outdoor or partially outdoor workplaces.”

4. Who Needs to Be Screened?
Answer: The MOH calls for screening of 2 groups before letting them enter your workplace:

• Workers, which include employees, contractors and volunteers that conduct business or related activities at the site; and
• Essential visitors, which include individuals providing a service at the site and who are not employees or customers of the establishment, such as delivery, maintenance and contract workers.

You don’t have to screen customers or first responders or other workers seeking entrance for an emergency.

5. What Does Screening Consist Of?
Answer: Screening involves asking 3 YES/NO questions:

• Are you experiencing any of the “new or worsening” symptoms (as opposed to symptoms associated with previous chronic or known conditions):
  • Fever and chills;
  • Sore throat or trouble swallowing;
  • Runny nose, stuffy nose or nasal congestion;
  • Difficulty breathing or shortness of breath;
  • Decrease or loss of smell or taste;
  • Nausea, vomiting, diarrhea, abdominal pain; and
  • Not feeling well, extreme tiredness, muscle soreness;
• Have you been outside Canada within the past 2 weeks; and
• Have you had close contact, i.e., within 6 feet/2 meters, of a confirmed or probable COVID-19 case?

Note that the MOH does NOT recommend taking a person’s body temperature or requiring them to be tested for COVID-19.

6. What Happens If a Person Answers “Yes”?
Answer: To pass screening, the person must answer NO to all of the questions. According to the MOH, if the person gives even a single YES answer, they shouldn’t enter the workplace and you should advise them ) to go home to self-isolate immediately and contact their healthcare provider or Telehealth Ontario (1 866-797-0000)to find out if they need to be tested for COVID-19. Exception: You shouldn’t deny entry to an essential worker solely because he/she traveled outside Canada if the trip was for a business purpose and the worker has no COVID-19 symptoms.

The 3 Things You Must Do to Comply
You’ll need 3 things to comply, all of which you can find on the OHSI website:

1. Instructions on how to create a legally sound screening policy;
2. A screening policy template you can adapt for your own workplace; and
3. A screening form you can use to actually perform and document your COVID-19 screenings.