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What you need to know about vaccination passport and policy requirements

The province's recent announcement that it would introduce a COVID-19 vaccination passport system for customers entering certain businesses creates an issue of another sort for workplaces: what about their employees?

Trevor Beauchamp, WSPS' Director of Field Operations, has been asked more than once, "Why are workers exempt from the passport system?"

The province's Enhanced COVID-19 Vaccine Certificate system, which came into effect on September 22, requires customers entering certain businesses to show proof of full vaccination and personal identification.*

To help businesses implement the system, the government published Guidance for Businesses and Organizations under the Reopening Ontario Act. Among other things, the document lists the types of businesses affected, identifies the steps workplaces must take to verify information presented by customers, and indicates who is exempt from the passport system requirements, including workers and contractors.

"Some people are confused about why workers are being exempted," says Trevor. "The answer is simple. Workers are governed by other legislation - the Occupational Health & Safety Act, which requires businesses to take every reasonable precaution to protect workers against workplace hazards, COVID-19 included, and the Re-Opening Ontario Act, which requires all operating businesses to have a COVID-19 safety plan." Workplace requirements under the plan include physical distancing, masks, eye protection, barriers, ventilation, cleaning and sanitizing, screening, and more.

Some workplaces are addressing their legal obligations under these acts by developing voluntary or mandatory workplace vaccination policies. In fact, under O.Reg. 577/21 a policy may be a legal requirement if decreed by the medical officer of health for your local health unit.

Here's an example of the City of Toronto's mandatory vaccination policy.

If you are considering implementing a vaccination policy, seek legal advice. A vaccination policy should consider legal issues involving health and safety, human rights, privacy, employment, and labour relations.

What to include in your policy

For businesses considering a voluntary vaccination policy, here are some possible components:

  • steps you are taking to reduce workplace transmission (your COVID-19 safety plan and the controls you have in place), and any new steps you are planning, such as rapid antigen testing. Explain why controls, like screening, will continue even after vaccination.

  • why you are implementing this policy.

  • who the policy applies to - workers, contractors, customers, etc.

  • the benefits of vaccination, vaccine safety, risks of not being vaccinated, and possible side effects of vaccination. Provide links to facts about the virus and the vaccine from public health sources.

  • how you will help workers get vaccinated. Will you host an onsite clinic? If not, provide a list of nearby clinics. Remind employees they are entitled to up to three days of paid leave to be vaccinated, recover from side effects, and more.

  • whether you will track vaccination status. If so, how will you do this? Advise employees on how to obtain a vaccination receipt. Get legal advice regarding privacy implications for keeping personal information confidential and secure. Discuss human rights and health exemptions.

  • who to contact in your workplace for more information or questions.


Visit WSPS'

for a wide range of resources, including sample safety plans, articles, guidelines, and more.


* On October 22, Ontario will introduce an enhanced digital vaccine receipt featuring a QR code - a safe, secure digital vaccine receipt that can be kept on a smart phone. The province also plans to launch a new app that would make it easier and more convenient for businesses and organizations to read and verify the validity of a digital vaccine receipt, while protecting receipt holders' privacy.

The information in this article is accurate as of its publication date.


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