FAQ for Employers Regarding COVID-19 Screening in the Workplace

On October 2, 2020, the Government of Ontario issued Regulation 364/20: Rules for Areas in Stage 3  under the Reopening Ontario (A Flexible Response to COVID-19) Act, 2020, which states: “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.”

To help employers comply with this directive, we have prepared answers to the following Frequently Asked Questions (note that while the group “employees” is referred to throughout this document, the directive also applies to “essential visitors” which includes individuals who are providing a service in the workplace, such as delivery and maintenance personnel, contract workers, etc.).   

When should employees be screened for COVID-19?

Employees can be screened remotely (i.e. perform a self-assessment or use an app/website from home to confirm that they are allowed in the workplace), or they can be screened at the entrance of the workplace at the beginning of the day or shift. 

Note: employers who choose to screen employees in person should have a screening area configured in a manner that allows employees to safely and comfortably maintain a social distance of two meters. 

Who can conduct employee screening?

Any individual(s) authorized by the employer can conduct employee screening. These individual(s) should be properly trained. They should also have an established process in place to contact a supervisor or manager in the event of an escalated issue, or any other unexpected situation that requires additional support.   

How should employees be told about the screening process?

Employers should inform employees of the screening process through all appropriate channels, including email, employee website (intranet), phone, or in-person. Clear signage with the screening questions should be posted at all entrances.  

What screening questions should employees answer?

The Government of Ontario has published a COVID-19 self-assessment tool that outlines three mandatory questions that employees must answer (download the tool here in PDF format). These questions are:

1. Do you have any of the following new or worsening symptoms or signs? 

• fever or chills
• difficulty breathing or shortness of breath
• cough; sore throat or trouble swallowing
• runny nose, stuffy nose or nasal congestion
• decrease or loss of taste or smell
• nausea, vomiting, diarrhea, abdominal pain
• not feeling well, extreme tiredness, sore muscles 

2. Have you travelled outside of Canada in the past 14 days?

3. Have you had close contact with a confirmed or probable case of COVID-19?

If an employee answers “no” to ALL questions, they have passed and can enter the workplace. However, employees should be advised to immediately report any symptoms. 

If an employee answers “yes” to ANY question, they have not passed and cannot enter any part of the workplace (including any outdoor/partially outdoor areas). They should be told to go home directly (i.e. do not stop at the grocery store, the coffee shop, etc.) to self-isolate, and immediately and contact their health care provider or Telehealth Ontario at 866-797-0000 to find out if they need a COVID-19 test. 

In addition, employees who are sent home because they did not pass the screening should be provided (if not immediately, then as soon as possible) with information regarding any applicable alternative work arrangements, statutory and/or contractual entitlements, and benefits. 

Can employers add screening questions?

Yes, screening questions can be added to meet the specific needs of the workplace environment.  

Can employers oblige employees to have their temperature taken as part of the screening process?

At this time, it is not mandatory for employers to take the temperature of employees as part of the screening process. However, employers can add this if they deem it necessary. 

Do employees working remotely need to be screened?

No. Only employees who are attempting to access the workplace need to be screened. However, it is prudent for employers to provide all employees (including remote workers) with information to help them conduct a self-assessment on a regular basis and monitor for symptoms.  

Do customers need to be screened before being allowed into the workplace (e.g. restaurant, grocery store, etc.)?

At this time, there is no obligation for organizations to screen customers for COVID-19. However, many organizations have implemented a screening process for customers that is similar to their screening process for employees, in an effort to help protect the health and safety of workers and others. 

What records are employees required to collect?

 At this time, there is no formal guidance from the government regarding what screening data employers are required to collect and secure. However, employers should put established policies and processes in place, so that they can demonstrate compliance if necessary. They should also treat all information as private and confidential.  

Do these screening rules replace an employer’s obligation under the Occupational Health and Safety Act?

No. Employers are still obligated to comply with the Occupational Health and Safety Act, which may require additional precautions depending on the scenario. 

As with everything else related to COVID-19 and the workplace, this situation is constantly changing. Employers are advised to consult the Government of Ontario’s website for the latest directives, advisories and news.