ORFA Position Statement on Return to Play

August 26, 2021

The Ontario Recreation Facilities Association (ORFA) is excited for the trending shift towards reopening of many different types of recreation infrastructures. It is positive to see many of our organized stakeholders creating tools to guide their members as they return to play. However, some of this information is causing confusion between operations staff and users. To assist in better understanding the “chain of command” in the use of recreation venues, the ORFA offers the following suggested guidelines:

- It is important to note the General Compliance section 2. (1) of O. Reg. 364/20 which states that "the person responsible for a business or organization that is open shall ensure that the business or organization operates in accordance with all applicable laws, including the Occupational Health and Safety Act and the regulations made under it."

- In a municipal operation, the responsible person would be the most senior administrative staff member who takes direction from elected officials and directs all other staff. In a private operation, this may be the most senior staff who takes direction from a Board of Directors.

- Dressing rooms have been a specific challenge to determine acceptable use.  Current provincial direction is “each organization or facility may choose to operate under stricter conditions than the provincial regulations mandate, however, that is at their discretion. Based on community needs, some municipalities and local medical officers of health may exercise their authority to implement more restrictions or requirements. It is important that you are aware of public health practices in your areas of operation."

- Insurance risk advisors strongly recommend that all facility operators revisit current contractual use agreements to define what areas a user group is in care and control of as part of the signed agreement. Further, a recommendation that facility owners seek legal advice on how to enhance current “hold harmless” statements surrounding vaccination and/or other COVID-19 operational directives is recommended.

  • Not all recreation infrastructure is designed the same. Therefore, it is the local Public Health Unit that is considered the authority in ensuring that all recreation activities are in compliance with COVID Regulations specific to a region. Recreation facility users should not expect the same levels of service in each facility they visit across the province.
  • Recreation facilities are public areas that users are “invited” to enter as a guest. Facility COVID safety policies are considered the primary guiding documents that all users must adhere to at all times.
  • User groups may have created national, provincial or municipal return to play or safety guidance policies that may be in direct conflict with facility owner controls or directives and therefore have no authority within specific facilities. Communication is key between building owners and user groups to avoid this situation and should be flagged as part of a signed user rental agreement consultation.

The ORFA continues to conduct regular COVID Task Team meetings that brings together representation from all regions of the province. The Task Team provides guidance and acts as an advisory committee for the shifting challenges associated with returning to play. The ORFA invites any organized sporting group seeking guidance or clarification of industry best practices to contact our administration for assistance. To our members, the Task Team shares and requests that by combining regional efforts in a collective approach that aligns with local Public Health Unit direction will provide the most seamless approach in educating and building positive return to play relationships.