COVID-19 Vaccination Procedure

Purpose statement

The COVID-19 pandemic has been an evolving public health issue in Canada. The Town of Oakville (town) continues to monitor guidance from all applicable public health authorities and reserves the right to revise this procedure as determined to be necessary and appropriate.

The health and safety of employees is a priority, and as such the town is committed to taking every precaution reasonable under the circumstances to protect the health and safety of town workers from the hazard of COVID-19. Given the continuing spread of COVID-19 and its variants within Ontario, the compelling data demonstrating a higher incidence of COVID-19 among the unvaccinated population, and the increasing levels of contact between individuals as businesses, services and activities have reopened, it is important for town employees to be fully vaccinated in order to protect themselves against serious illness from COVID-19, as well as provide protection to others, including colleagues.

Vaccination is a key element in the protection of town employees against the hazard of COVID-19. The purpose of this procedure is to ensure that all current and future town employees are fully vaccinated against COVID-19 or provided an appropriate safe alternative accommodation based on individual circumstances.  Adherence to this procedure is mandatory and non-compliance may result in disciplinary measures up to and including termination of employment.

Scope

The procedure applies to all employees of the Town of Oakville, including but not limited to full-time, part-time, casual, students, temporary/contract and seasonal staff.

Procedure

Employees who have already received their vaccination are required to provide proof of their COVID-19 Vaccination Status by uploading their vaccination record/receipt provided by the Ministry of Health, pharmacy, doctor’s office, or other authorized provider into the self-serve portal by September 20, 2021.  Appropriate proof of vaccination includes providing a clean copy of the physical or electronic receipt to the town. If employees have a green health card, they are able to download an electronic PDF copy of their vaccine record by going to the Ontario Health website. If employees have a red and white health card, or do not have a health card, they may call the Provincial Vaccine Information Line at 1-888-999-6488. Should the Province of Ontario implement a proof-of-vaccination certification system (commonly known as a “vaccine passport”), the town may choose to utilize that system at a later date, if feasible.

For those town employees who are not yet fully vaccinated, they must be fully vaccinated against COVID-19 or have an approved accommodation plan in place by October 31, 2021. An individual is defined as fully vaccinated 14 days after receiving their second dose of a two-dose COVID-19 vaccine series (i.e. AstraZeneca, Pfizer, and Moderna, or a combination thereof), or their first dose of a one-dose COVID-19 vaccine series (i.e. Johnson & Johnson), that is approved by Health Canada. In the future, this may include any required booster shots.

In order to bridge the gap during the transition period between the implementation of this policy and the deadline to comply (October 31, 2021), the temporary measure of screening and Rapid Antigen Testing will be required. Rapid Antigen Testing will be required for staff who are not yet fully vaccinated to enter the workplace. This temporary testing measure will be paid for by the town. Staff undergoing testing during this transition time will be required to provide proof of their negative test results at regular intervals 2-3 times per week. Testing is to be done outside of working hours on staff time.

Privacy and Confidentiality

All employees are required to disclose and consent to providing proof of vaccination status. All medical information regarding vaccination status or accommodations will be treated with the highest confidentiality and will only be used for the purposes of the COVID-19 Vaccination Policy and Procedure.

The town will use COVID-19 vaccination status information to make operational and health and safety decisions to protect all those in the town against COVID-19.  This information will be used to verify an employee’s compliance with the town’s policy and procedure on mandatory COVID-19 vaccinations.  The information may also be used for tracking and reporting on aggregate data with respect to statistics around the vaccination status of employees at the town. The vaccination record will only be accessed by the Human Resources Department to administer this procedure and accompanying policy and will be stored in a secure system, safeguarded by restricted access, ensuring the privacy of this medical information.  This information will be destroyed if and when it is no longer required by the town.

Accommodations under the Ontario Human Rights Code:

The town will make reasonable efforts to accommodate employees who are unable to get vaccinated against COVID-19 for reasons protected under the Ontario Human Rights Code. Accommodation requests are administered in accordance with the town’s Accommodation procedure HR-MNG-008-003, are subject to substantiation, and require the cooperation and participation of the employee and their bargaining unit representative, if applicable.

Currently it is understood that the legitimate medical reasons for not being able to receive the COVID-19 vaccination are limited to the following:

  • A severe allergy to a component of the vaccine, confirmed by the employee’s medical doctor who is an allergist or immunologist, registered in good standing with the College of Physicians and Surgeons of Ontario.
  • Confirmation by the employee’s medical doctor who is registered in good standing with the College of Physicians and Surgeons of Ontario that the employee was diagnosed with developing myocarditis or pericarditis after a first dose of an mRNA vaccine.
  • These reasons may change in the future as medical science evolves.
  • The employee is responsible for providing the appropriate documentation as required by the town to support their request for accommodation, including the effective time period for the medical reason.  Employees requiring an accommodation under the Ontario Human Rights Code must make a request in writing by completing the Accommodation Request Form and providing supporting documentation.  An employee seeking an accommodation should make their request by September 20, 2021 in order to allow for sufficient time to review the request, the required documentation, and determine the accommodations required prior to October 31, 2021. Accommodation in the recruitment process will be in accordance with the town’s Accessible Employment procedure.
  • Accommodations will be determined on a case by case basis having regard to the individual circumstances of the employee and their job requirements.
  • If upon review there are no suitable accommodations available, the employee may be required to be placed on an unpaid leave of absence for the period they are unable to be vaccinated.
  • There is no requirement under the Ontario Human Rights Code to accommodate a refusal to be fully vaccinated for personal reasons or arising from a political belief and/or principles. Political belief, such as the objection to receiving the vaccination on a principled basis, is not a protected ground under the Code.

Vaccination Information

Supply of COVID-19 vaccines and vaccination appointments are readily available through public health units, pharmacies, health clinics, and physician offices across Ontario. Employees are encouraged to get vaccinated as soon as possible, and may do so during work hours if securing an appointment outside of work hours is not possible. Once a vaccination appointment has been booked, employees are encouraged to provide as much advance notice as possible to their supervisor, so that continuity of service can be maintained.

In order to ensure that employees subject to this procedure are adequately educated about COVID-19 and the efficacy of COVID-19 vaccines, employees are encouraged to speak with their physician around the benefits of vaccination.  Furthermore, employees who may be vaccine-hesitant are encouraged to undertake self-directed learning to inform themselves using legitimate, credible resources.  There are several resources available to employees in this regard through Halton Region Public Health and Public Health Ontario as detailed below:

Halton Region Public Health resources:

Public Health Ontario resources:

New Employees

Full COVID-19 vaccination will be a condition of employment for all new hires at the town. During the interview process, potential new hires will be advised of the town’s mandatory vaccination policy and will be advised that any offers of employment will be conditional on being fully vaccinated by their start date and providing a copy of their vaccination record. Accommodation requests under the Ontario Human Rights Code will continue to apply to new hires.

Continued Compliance with all Health and Safety Precautions

Unless a legislated or regulatory exemption applies, all Town of Oakville employees are expected and required to continue to comply with applicable health and safety measures to reduce the hazard of COVID-19. The town will continue to closely monitor its COVID-19 risk mitigation planning and ensure it continues to optimally protect the health and safety of employees. The town will continue to assess other available workplace risk mitigation measures available and may amend this procedure as necessary.

Consequences of Non-Compliance with Policy

Employees who have chosen not to get vaccinated, who do not provide proof of vaccination, or whose accommodation requests are not substantiated by October 31, 2021 will be considered to be unvaccinated and non-compliant with the Vaccination Policy and Procedure. Employees who are unvaccinated after October 31, 2021 will be placed on an unpaid leave of absence, and may subsequently be subject to termination of employment.

Definitions

Accommodation: As defined in HR-MNG-008-003 – Accommodation Procedure

COVID-19: A virus belonging to a large family called coronavirus which includes the virus that causes the common cold and more severe disease such as Severe Acute Respiratory Syndrome (SARs) and Middle East Respiratory Syndrome (MERS-COV). The virus that causes COVID-19 is a novel coronavirus, named SARS-CoV-2.

COVID-19 Vaccination Status: Identifies if a person is fully vaccinated, partially vaccinated, or unvaccinated for COVID-19.

Fully Vaccinated Having received the required number of doses of a COVID-19 vaccine approved by Health Canada (e.g., both doses of a two-dose vaccine series, or one dose of a single-dose vaccine series); and having  received a final dose of vaccine at least 14 days ago.

If the person received their second dose within the last 14 days, they are considered partially vaccinated until day 14.

In the future, this may include any required booster shots.

Partially Vaccinated: Having received at least one dose of a COVID-19 vaccine approved by Health Canada, but is not yet Fully Vaccinated.

Proof of COVID-19 Vaccination:Documentation issued by the Ontario Ministry of Health, other Province or Territory, or international equivalent indicating vaccination status against the COVID-19 virus. Copies can be obtained by logging into the provincial vaccine portal.

Unvaccinated: Not having received any COVID-19 vaccine approved by Health Canada; Or is not willing to share their COVID-19 vaccination status with the town; OR has accommodation.

Responsibilities

Employees

Responsible for obtaining and submitting their individual proof of COVID-19 vaccination as per the town’s procedure by September 20, 2021.

If additional booster doses of the COVID-19 vaccine are required, ensure subsequent doses are also received.
Responsible for notifying Human Resources by September 20, 2021 that they are requesting an accommodation from the requirement to be fully vaccinated for reasons related to the Human Rights Code.

Continue to follow health and safety protocols to ensure personal safety and prevent the spread of COVID-19 before and after vaccination.

Work in a manner that is respectful to all, respecting employees’ privacy under the town’s respectful workplace policy and procedures.

Identify opportunities to obtain a COVID-19 vaccination through community clinics.

Human Resources

Ensure any records of COVID-19 vaccination held by the town are stored and used in compliance with privacy legislation and corporate policies. 

Ensure employees have submitted proof of their vaccination status or an approved exemption.

Assist management in working with employees in substantiating accommodation requests related to this procedure, and in appropriate cases, assisting in providing safe and suitable accommodations where possible.

Provide information and guidance regarding this procedure and the accompanying policy on mandatory COVID-19 vaccinations. 

Supervisor, Managers and Senior Management

Ensure employees attending work are fully vaccinated against COVID-19.

Be aware of the potential for workplace conflict or issues related to individuals COVID-19 vaccination status.

Responsible for assisting in the accommodation process when required and maintain confidentiality with respect to this process.

Ensure that employees are aware of the importance of getting vaccinated against COVID-19.

Where feasible, support time off from regular duties for staff to attend vaccination clinics.

Continue to enforce workplace precautions that limit the spread of COVID-19 virus.

Provide information and guidance regarding this procedure and the accompanying policy on mandatory COVID-19 vaccinations.

References

HR-MNG-008-003 – Accommodation Procedure
Appendix A Accommodation Request Form
Ontario Human Rights Code
MS-ACC-001-003 Accessible Employment Procedure
Ontarians with Disabilities Act, 2001
Accessibility for Ontarians with Disabilities Act, 2005
HR-MNG-008-001 RZone Procedure
HR-MNG-008-002 Respectful Conduct Procedure
Any other relevant town policies

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