How to Perform Pre-Entry COVID-19 Health Check Verification

Simply screening workers for COVID is no longer enough in some jurisdictions.

Pre-entry screening for COVID is no longer enough. As COVID cases surge once more, the public health guidelines have changed. Several jurisdictions, including Ontario and BC, now require employers to not only perform COVID pre-entry screening but also verify that workers and visitors have done a daily health check on themselves. Failure to do so can result in significant fines and even business closure orders. Here are 7 FAQs explaining the requirements and how to comply with them.

Caveat: This analysis is based on the COVID-19 emergency orders and public health guidelines (which we’ll refer to collectively as ‘guidelines’) in effect as of February 15, 2021. It’s important to remember that guidelines vary by jurisdiction and are subject to change at any time. So, be sure to constantly check the guidelines of your own jurisdiction for as long as the pandemic lasts.

1. Are Daily Health Checks a Requirement or a Recommendation’

Answer: It depends on of your particular jurisdiction. Health checks are mandatory in BC and Ontario and within many municipalities, including with regard to high-risk operations like health care. Health checks are also highly advisable for employers even if they’re not currently required.

2. What’s the Difference Between COVID Pre-Entry Screening and Daily Health Checks’

Answer: Both things are designed to ensure that people with COVID symptoms or recent exposure to somebody with the virus don’t get into the workplace.

Screening is carried out by the employer at the entry point before people are allowed into the workplace via asking would-be entrants a series of YES/NO questions. While not required by current guidelines, screenings may also include a body temperature check.

Health checks are a form of self-monitoring in which employees basically screen themselves before deciding whether to come to the workplace each day.

3. What Must Workers Do’

Answer: Each day, workers must assess themselves for COVID risk and not come to the work site if any of the following things is true:

  • They’ve travelled outside Canada (or the province, depending on the guidelines of their particular jurisdiction) in the past 14 days;
  • A public health agency has asked them to self-isolate or identified them as a close contact of somebody with COVID; or
  • They exhibit any new or worsening of any COVID symptoms, which under current guidelines include:
    • Fever or chills;
    • Cough;
    • Loss of taste or smell;
    • Difficulty breathing;
    • Sore throat;
    • Loss of appetite;
    • Extreme fatigue;
    • Headache;
    • Body aches;
    • Nausea or vomiting; and
    • Diarrhea

4. What Must Employers Do’

Answer: First, employers should post an entry check poster listing the conditions noted in Question 3 above, including the most recent COVID symptoms, and warning people not to enter the workplace if any of them are present. But posting isn’t enough. Employers must also actively confirm, whether verbally or in writing, that each worker person seeking entry has actually done a daily health check. BC government guidelines list examples of acceptable methods employers can use, including:

  • A written health check declaration that workers complete before entry;
  • An online health check form for workers to complete before entry;
  • A verbal check in, done either virtually or by phone with every employee, confirming that the employee has completed their daily health check, and a record of receipt of such confirmation; and
  • Other forms of a supervised daily health check process based on the above.

5. For Whom Else Is Confirmation of Daily Health Checks Required’

Answer: In addition to workers employed by the company, daily health check verification is required for what Ontario calls ‘essential visitors,’ which include individuals providing a service at the site and who are not employees or customers of the establishment, such as delivery, maintenance and contract workers. Confirmation is not required for customers or first responders.

6. What Records Must Employers Keep’

Answer: Employers need records documenting that they confirmed daily health checks were done. They’re not only not required but also not allowed to collect any medical or other personal information from would-be entrants.

7. What Happens If Employers Can’t Confirm a Health Check Was Done’

Answer: If the worker or visitor refuses to provide confirmation, you’re not allowed to let them into the building. The same is true if they display any COVID symptoms. However, they don’t have to notify public health authorities.