On November 26, 2021, the World Health Organization ("WHO") designated the variant B.1.1.529 as a "variant of concern", named Omicron. Since then, the presence of Omicron has been noted in various jurisdictions around the globe, including at least a dozen confirmed cases in Ontario.
In response to this concern, on November 30, 2021, Ontario's Ministry of Health released interim guidance for targeted enhanced public health case and contact management as well as outbreak management in connection with the Omicron variant. Employers can find the full details of this interim guidance here. We have provided an overview below.
The Ministry of Health's interim guidance is designed to provide general information. In the event of a conflict between the interim guidance and any orders or directives issued by the Minister of Health or the Chief Medical Officer of Health, the order or direction will prevail.
Relevant Definitions
As used in the Ministry of Health's interim guidance:
- a "confirmed case of Omicron" means a lab-confirmed SARS-CoV-2 infection with whole-genome sequencing identifying the Omicron variant; and
- a "Person Under Investigation" or "PUI" for the Omicron variant means a confirmed or probable COVID-19 case with:
- a history of travel in the past 14 days outside of Canada and an absence of a test result that rules out the Omicron variant;
- high risk exposure to a returning traveler from outside of Canada in the 14 days before the symptom onset or a positive specimen is collected (if asymptomatic) and an absence of a test result that rules out the Omicron variant; or
- regardless of travel history, presence of test results that are suggestive of the Omicron variant.
Enhanced Management of Cases / PUIs and their Contacts
In accordance with the interim guidance, a confirmed case of Omicron or a PUI for Omicron variant should receive enhanced case management, including:
- more frequent follow up calls (daily, if possible) to ensure adherence to self-isolation; and
- enhanced support for effective isolation from household members (e.g., access to a voluntary isolation center, if needed).
Most importantly, the interim guidance identifies that there should be no test-based single negative PCR test clearance option to shorten the duration of self-isolation for asymptomatic fully vaccinated individuals with a positive test.
High Risk Contacts of Omicron Cases or PUIs
While the applicable threshold is not clearly set in the interim guidance, it is noted that the threshold for assessing exposure to the Omicron variant as "high risk" should be low. Further:
- isolation should be required for all high-risk contacts (regardless of vaccination status or previously positive status). In other words, there is to be no exemption to self-isolation for fully vaccinated or previously positive individuals;
- access to initial PCR testing and subsequent testing on day 7 or later should be emphasized and supported; and
- a negative follow-up PCR test on day 7 (or later) should be required prior to an individual exiting self-isolation. Notably, if an asymptomatic high-risk contact declines testing at day 7 (or after), the isolation period can be extended by an additional 10 days following the completion of the initial self-isolation period (or until the individual obtains a negative PCR test).
Enhanced Management of Household Members of Asymptomatic High-Risk Contacts of Omicron Cases or PUIs.
Public health units should also consider requiring household members of asymptomatic unvaccinated high-risk contacts to self-isolate (at a minimum, until the high-risk contact obtains a negative PCR test result). These household members should not attend work, school or childcare while self-isolating.
Notably, household members of fully vaccinated asymptomatic high-risk contacts are not required to self-isolate.
Next Steps for Employers
Ontario employers should consider the impact of the Omicron variant and the Ministry of Health's enhanced case management on their workforces, including any anticipated plans to return to the office / facility. In addition, based on the above recommendations, it would be prudent for employers to update their screening requirements to ensure these recommendations are adopted.
For the most up to date COVID-19 guidance in Ontario, employers should review the guidance provided by the local public health units as well as:
