On April 27, 2020, the Ontario government announced a “Framework for Reopening our Province,” a document setting out the public health principles behind its decision-making respecting the gradual reopening of the economy in the wake of COVID-19.
The document outlines a three-stage reopening process with progress from one stage to the next based on whether the criteria in the preceding stage are met. Although there is no timeline for the commencement of the first stage, it will involve opening “select workplaces that can meet public health guidelines.”
On April 30, 2020, the Ontario government published resources for employers on its website, including sector-specific workplace safety guidelines and posters. At present, guidelines and posters have been published for the construction, food processing, restaurant and food services, agriculture, manufacturing, and long-term care sectors, suggesting that these will be the first “select workplaces” permitted to reopen.
As new sectors of the economy begin to reopen, additional COVID-19 workplace safety resources will be added to the government website.
As indicated in the provincial announcement, the new sector-specific guidelines feature recommended actions employers can begin to plan for as they prepare to adapt to the new reality during COVID-19, including:
- Ways to ensure appropriate physical distancing, like eliminating pay-at-the-door options, holding team meetings outdoors, staggering shift times and using ground markings and barriers to manage traffic flow.
- Changes to the workplace, like installing plexiglass barriers, increasing the air intake on building heating, ventilation, and air conditioning (HVAC) systems to increase air flow, and using boot sanitizing trays.
- Promoting proper workplace sanitation, providing personal protective equipment, substituting dry dusting with vacuuming, ensuring customer-facing staff are given hand sanitizer, providing a place to dispose of sanitizing wipes, and enforcing handwashing before and after breaks.
The guidelines are not particularly stringent and contain basic, common-sense measures most employers in the selected sectors already have in place. As such, the guidelines appear to be the minimum requirements employers need to implement to meet the reopening eligibility criteria, but most employers will need to implement much more robust and stringent health and safety procedures to meet their obligations under the Occupational Health and Safety Act (OHSA), which requires employers to, among other things, take all reasonable precautions to protect workers from illness and injury in the workplace.
In preparing their return-to-work plans, prudent employers will consider all sector specific guidelines published by industry associations as well as those published by Ontario’s heath and safety associations (available here).