Understanding Facility COVID Contact Tracing Requirements

January 28, 2022

As recreation facilities across the province once again prepare to welcome back users (January 31, 2022), facility owners are diligently working behind the scenes to fully comprehend implications of the latest revision to the Province of Ontario's Returning to Our Plan to Safely Reopen Ontario.

The ORFA offers the following points of consideration to assist members in designing individual and site-specific operational procedures:

  • It is important that all stakeholders understand that the only interpretation of O. Reg. 364/20 Rules for Areas in Step 3 and at Roadmap Exit and O. Reg. 363/20 Steps of Reopening application that counts is the direction given by the facility.  This includes how a facility wishes to accept contact tracing information to meet the operational requirement.  In addition, each facility will need to confirm with local Public Health officials what, if any, exemptions for proof are acceptable.  Consider that not all facilities will have the necessary staffing levels and/or technology to immediately accomplish this requirement.
  • Users are asked to appreciate that every facility is its one ecosystem that must also balance all other workplace legislative responsibilities that include, but are not limited to, provincial and internal health and safety direction, Occupiers Liability Act for user safety and Labour/Management workplace agreements.
  • COVID Regulations continue to be fluid, with direction that is often left with local Public Health Inspectors to interpret and apply on a case by case basis.  Consider as an example that government generates Highway Traffic Regulations and local police authorities enforce as they deem fit – same concept

A further constant reminder that frontline facility staff DO NOT create government regulation. They are merely following direction from senior facility administration staff. Please be respectful - thank you!