Ontario, Canada Exploring Possibility of Allowing Employer-Operated Onsite Vaccination Clinics in “Hot Spot” Communities

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On April 13, 2021, Ontario announced that in Phase 2 of its COVID-19 vaccine distribution plan it will provide vaccines to those 18 and over via mass immunization clinics, mobile teams, and pop-up clinics in highly impacted neighborhoods. These areas are referred to as “hot spots” and identified by postal code.  This will first occur in Peel and Toronto.

To supplement this strategy, Ontario is exploring the possibility of allowing employers in hot-spot communities to set up, operate and fund onsite vaccination clinics where employees 18 and over and members of local and neighbouring communities could be vaccinated. In order to set up such a clinic, the workplace must have had a COVID-19 outbreak or be at risk of an outbreak. The onsite clinic would vaccinate employees who cannot work at home.  Moreover, the employer would be required to obtain the support of local public health units and hospitals, to ensure consistency with local plans.

Employer-operated onsite vaccination clinics would not mandate employee vaccination.  Any employees vaccinated in such clinics would do so on a voluntary basis.  Employers considering operating an onsite vaccination clinic should ensure their strict compliance with public health guidelines.  

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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