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Tips for employers as Toronto, Peel move into 28-day lockdown

November 23, 2020
By Sherrard Kuzz LLP

(Lorne/Adobe Stock)

The Government of Ontario has announced the City of Toronto and Region of Peel will move to the “Lockdown/Grey” stage of the COVID-19 Response Framework effective Monday, Nov. 23, 2020 at 12:01 a.m. for a minimum of 28 days.

General restrictions

The following general restrictions apply, as appropriate:

  • No indoor organized public events and social gatherings, except with members of the same household.
  • Limit of 10 people for any outdoor organized public event and social gathering, where physical distancing can be maintained.
  • Limit of 10 people (indoors or outdoors) for weddings, funerals and other religious services, rites or ceremonies where physical distancing can be maintained.
  • Virtual and drive-in gatherings, events services, rites or ceremonies are permitted.

Safety plan

Every businesses and organization in Lockdown/Grey, permitted to be open, must have a COVID-19 workplace safety plan

Businesses are not required to send this plan to the Ministry of Labour, Training and Skills Development for review or comment. However, during an inspection, a Ministry inspector could ask about the plan.


To assist employers, the Government has provided a template safety plan, which is more in the nature of a baseline checklist than it is a plan (see the prior link).

At minimum, a safety plan should address the following topics:

  1. How will you ensure all workers know how and are able to keep themselves safe from exposure to COVID-19?  That is, how will you stay current on the law, including health and safety requirements, and communicate this to workers and guests?
  2. How will you screen for COVID-19?
  3. How will you control the risk of transmission in your workplace?  That is, what are your practices and protocols, both physical and administrative?
  4. What will you do if there is a potential case, or suspected exposure to, COVID-19 at your workplace?
  5. How will you manage any new risks caused by changes to the way you operate your business?
  6. How will you ensure your plan is working? That is, how often will you review your plan? Who is responsible for evaluating how things are working and for adapting the plan? How will you communicate changes?

Business-specific restrictions

The Lockdown imposes significant restrictions (and in some cases, closure) on businesses listed below. A complete list of the restrictions can be found here.

The Government has also provided a Stop the Spread Business Information Line at 1-888-444-3659.

  • Restaurants, bars and food or drink establishments
  • Sports and recreational fitness facilities
  • Meeting and event spaces
  • Retail
  • Personal care services
  • Casinos, bingo halls and gaming establishments
  • Cinemas
  • Performing arts facilities
  • Amusement, waterparks
  • Bathhouses and sex clubs
  • Boarding kennels and stables
  • Campgrounds
  • Cannabis
  • Driving instruction
  • Horse racing
  • Hotels, motels
  • Libraries
  • Media industries
  • Marinas, boating clubs, golf courses and driving ranges
  • Motorsports
  • Museums and other cultural amenities
  • Nightclubs
  • Personal services
  • Photography studies and services
  • Real estate agencies
  • Short term rentals
  • Strip clubs
  • Tour guide services
  • Animal services
  • Zoos and aquariums

To learn more, and/or for assistance with any COVID-19 related issue, including how to comply with the Lockdown requirements, contact your Sherrard Kuzz LLP lawyer or, if you are not yet a client, contact us at info@sherrardkuzz.com with the re line: COVID-19.

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