Key changes in determination of high-risk exposures and self-isolation requirements
Several key changes related to high-risk exposures and self-isolation requirements.
The purpose of self-isolation after exposure is to prevent against potentially infecting others, whether you have symptoms or not. Self-isolation requirements after exposure are determined by local public health units based on the level of risk of the exposure.
Close contacts are individuals with high-risk exposures. In general, public health units will direct a worker to self-isolate if they have had a high-risk exposure to someone with COVID-19. This means the worker must stay at home except for medical emergencies and may not attend the workplace.
1. Length of time a close contact is required to self-isolate has been decreased to 10 days (previously it was 14 days). The self-isolation period is applied in the same way as before:
- Worker must self-isolate for the full 10 days even if they have a negative test during this time.
- If they have not developed symptoms or tested positive, the worker can return to the workplace after 10 days of self-isolation.
- Workers do not need a negative COVID-19 test to return to the workplace after self-isolating for the full 10-day period.
2. Fully vaccinated workers (must be at least 14 days after their second dose) are not normally required to self-isolate after a high-risk exposure and may be permitted by public health to leave the home including to attend the workplace.
- Applies only if the worker is asymptomatic.
- Worker is to:
- wear a mask and maintain physical distancing when outside of the home, including while at the workplace, even if this is not normally a requirement for their work
- self-monitor for symptoms for 10 days and self-isolate immediately if they develop symptoms
- report their exposure to their employer and follow any employer directions
- Applicable to previously positive workers (who tested positive within the past 90 days and have since been cleared by public health).
3. Exposure of a worker to an unmasked person with COVID-19 within two metres for more than a transient amount of time is considered high-risk exposure unless the worker was wearing personal protective equipment (PPE) including both mask and eye protection.
- This is a change from the previous MOH guidance where this same situation was considered a high-risk exposure even if the person with COVID-19 was wearing a mask during the contact.
- The MOH guidance on Management of Cases and Contacts of COVID-19 in Ontario (gov.on.ca) currently indicates that an exposure where there was consistent mask use (surgical/procedure or non-medical) by both case and contact may be considered a low-risk exposure (Table 4: Contact Management Based on Exposure Setting and Type).
Implications for Workplace Health and Safety
Under the Occupational Health and Safety Act (OHSA), employers must take every precaution reasonable in the circumstances to protect the health and safety of workers. This includes protecting workers from hazards posed by infectious diseases such as COVID-19.
During the height of the third wave of the pandemic, and based on MOH guidance on high-risk exposures at that time, MLTSD took the position that the use of personal protective equipment (PPE), including both mask and eye protection, was required for workers working within two metres of another person, regardless of whether that person was wearing a mask.
Given the above changes in the MOH guidance as well as higher rates of vaccination and lower rates of new COVID-19 cases, the current MLTSD position is that under OHSA:
- PPE may not be required for work within two metres of another person when everyone at the workplace is consistently wearing an appropriate mask that fits against the face without gaps and is covering their nose, mouth, and chin.
- Requirement for PPE (appropriate mask and eye protection) remains when working within two metres of an unmasked or improperly masked person without an impermeable barrier, whether indoors or outdoors.
- Minimum PPE requirements for indoor work (under the Reopening Ontario (A Flexible Response to COVID-19 Act, 2020 (ROA) are the same: mask and eye protection when working within two metres of an unmasked or improperly masked person without a barrier. Employers must ensure they are meeting their responsibilities under the OHSA in addition to what is required under the ROA.
Updates to MLTSD Guidance
MLTSD is updating online resources to reflect above information.
Published updates include:
- Guide to developing your COVID-19 workplace safety plan, to reflect the change in the self-isolation period after a high-risk exposure.
- Using masks in the workplace and the Construction site health and safety during COVID-19 guidance note, to reflect the current enforcement position on masking and PPE requirements.
In the process of being updated:
- Restaurant and food services health and safety during COVID-19 guidance note to reflect the masking and PPE requirements.
- COVID-19: self-isolation and return to work, to reflect the changes to the length of time and requirements for fully vaccinated workers for self-isolation after a high-risk exposure.
New post-vaccination occupational health and safety COVID-19 resources
- Fact sheet for employers (English / French) explains why they need to continue with workplace exposure controls after workers (and customers) are vaccinated, and with reminders of control measures to continue.
- Two infographics for workers – one to explain why there is a need to continue to take precautions at work after being vaccinated (English / French), and the other to provide reminders of what actions to continue (English / French).
Links to all MLSTD resources posted on COVID-19 vaccines and workplace health and safety webpage.
Information in this article is valid at date of publication, please check COVID-19 and workplace health and safety MLTSD webpage to ensure you have the most up to date information.