BUILDING WELL-ROUNDED VACCINATION POLICIES Legal advice for multi-residential apartment owners by Kristin Ley & Laura Gurr Mandatory vaccination policies have been top-of-mind among business owners recently, including within the multi-residential housing sector. For landlords, it is highly recommended that two distinct sets of policies are put in place to protect residents and properties: 1) policies for employees, and 2) policies relating to the use of non-essential indoor amenities.
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art of a well-rounded risk management strategy, these two separate vaccination policies will help landlords better protect occupants and employees from the spread of COVID-19, while also lowering their liability risk. Workplace policies Many businesses, organizations, universities and colleges across Ontario have made similar announcements or have released their policies requiring all employees, contractors and visitors to be vaccinated. Universities and colleges have also implemented policies 14 | Canadian Apartment | Part of the REMI Network |
requiring proof of vaccination for students living in on-campus housing. Any vaccination policy applying to employees must comply with the Occupational Health and Safety Act, the Ontario Human Rights Code and privacy laws. In strongly recommending that all employers have a vaccination policy, Toronto Public Health identified minimum requirements that should be part of any vaccination policy: • Workers to provide proof of vaccination series approved by Health Canada or the World Health Organization
• Unvaccinated employees to provide written proof of a medical reason from a physician or nurse practitioner that includes whether the reason is permanent or temporary • Unvaccinated workers to complete a vaccination education course on the risks of being unvaccinated in the workplace In addition to the above minimum requirements, it will be necessary for employers to consider what precautions or protections will be required for those who are unvaccinated in the workplace
