Ontario's New Pre-Entry Screening Requirements
As of September 26, 2020 pre-entry screening of all staff and essential visitors came into effect for all Stage 3 Area workplaces in Ontario, as an amendment to the Ontario Regulation 264/20.
Stage 3 is the final phase of response to COVID in Ontario and is now in effect province wide.
The amendment, making pre-entry screening mandatory, reads as follows:
2(3) The person responsible for a business or organization that is open shall operate the business or organization in compliance with the advice, recommendations and instructions issued by the Office of the Chief Medical Officer of Health on screening individuals.
Normally recommendations would be considered best practice, however, as the regulation directs that businesses "shall" be operated in compliance with them effective immediately - these recommendations are mandatory.
Before we delve into the options for screening of employees and essential visitors let's define who those are:
Staff who work on site at the dealership - those working from their homes are not required to screen.
Essential visitors are individuals that enter the dealership for a different reason then a customer but are not dealership staff, such as providing a service (e.g. uniform services, maintenance contractors, etc.)
What should screening look like?
Although there is not a specific set of requirements for how screening must be implemented, providing a bit of flexibility to employers, there are important considerations for compliance:
How is the employer verifying that screening is taking place?
Are appropriate measures taken for staff and essential visitors that "screen out"?
How can the employer demonstrate the procedures for screening to a regulator if required?
What are the options for screening?
Dealers across the country have been engaging in a variety of processes and procedures for screening. They can include one or a combination of:
Establishing a screening point at the workplace
Having a monitored entrance for all staff and essential visitors for their shift start where they complete the screening tool prior to fully entering the building. The screening tool can be:
On a tablet or PC set up with the COVID 19 Self Assessment at the entrance; or
An assigned staff member collects screening either by documenting the employee's verbal answers or provides the individual a written form to complete. The staff member can also direct the employee to use hand sanitizer and ensure a mask is worn.
Establishing a self-screening process for employees and essential visitors
This would be similar to how you would implement a safe work procedure. You develop what steps employees MUST take and when, put it in documentation and educate employees on the new process. Supervisors are responsible for ensuring the procedure is followed by their staff
For example your process could be employees must conduct the self assessment tool at home prior to leaving for work and contact their supervisor immediately they answer YES to any of the screening questions.
For verification purposes the employer can have them share a screenshot of their completed self assessment tool showing they are not required to isolate by email, text or uploading it to their employee profile - if you have an HRIS like DealerPILOT.
Another option for verifying independent screening is a supervisor verbally verifies the employee completed their self assessment and is fit for duty, with the supervisor keeping a roll call style document every day confirming assessments are completed.
It is recommended that you in addition to a screening process that you post passive screening posters throughout your workplace. Click below to download an example of one:
What happens if...
Your process must also include what steps to take when a person answers "yes" to any screening questions.
What guidance do you provide the employee (e.g. contact public health, isolate at home)?
What criteria is required for the individual to return to the workplace safely?
Communication & Verification
Remember to communicate the screening process in a variety of formats in a regular manner to ensure all staff and essential visitors understand & comply. Use tools such as your electronic bulletin boards, policy acknowledgement systems, safety talks, staff meetings and one on one meetings with your staff.
Gather feedback from staff on how the new initiative is working for them and encourage questions and dialogue to engage staff in the process.
Verify that staff are following the directives by keeping records of completed documentation and observing staff for symptoms they may not report.
Which screening method should I use?
Remember the exact standard of implementation used by the dealership should depend on that specific workplace. One system used for one dealer in one region may not be reasonable for another. To decide which format most meets the needs of your dealership please consider:
How many staff and essential visitors enter your building on a daily basis?
What are the times of day staff and visitors arrive mostly?
What systems of communication and education do you currently use with your staff?
How do workers access the workplace? (e.g. which entrances, how many work remotely, etc).
It is unlikely that mass enforcement of this new requirement will occur immediately however if there is one thing that COVID has taught all of us is that things can change rapidly. Therefore it is in your best interest to start developing, implementing and monitoring your screening procedures.