Board Policies & Administrative Procedures

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AP 4 - 33: COVID – 19 Harm Reduction Procedure for Employees, Contractors and Volunteers - NEW

Related Policies:
Related Procedures:
Exhibits:
Initial Approval: 2021 November 10
Last Amended:
Last Reviewed: 

PURPOSE

Despite the numerous past, present and ongoing COVID-19 risk mitigation and health and safety measures in place, both in our Division and within our communities, the COVID-19 pandemic continues to put strain on our education and health care system as well as the entire community. COVID-19 presents a health risk for staff and students, and it is the responsibility of all school divisions to provide a safe working and learning environment for both staff and students.

Government and Health Officials have consistently advised that vaccination against COVID-19 is the most effective means to prevent the spread of COVID-19, prevent outbreaks and preserve in person learning.

In October 2021, the Division received a joint letter from the Ministers of Health and Education encouraging School Divisions to implement a proof of vaccination or negative test policy.

The Division recognizes its obligations pursuant to the Education Act, the Alberta Human Rights Act, the Occupational Health and Safety Act, Regulation and Code and orders issued by the Chief Medical Officer of Health and has established this Administrative Procedure in accordance with those obligations.

In response to the ongoing risk of COVID-19 transmission, the recommendations of government officials, and consideration of the Division’s responsibilities to those it serves and employs, including students under the age of 12 who are currently ineligible for vaccination, the Division has established this Administrative Procedure to enhance the safety in its schools for staff, students, volunteers, and families. 

SCOPE

This administrative procedure applies to all Division Employees, Contractors, Practicum Students and Volunteers.

DEFINITIONS

A. “Fully Vaccinated” means:

1. having received two doses of a vaccine considered valid by Health Canada in a two dose COVID-19 vaccine series, or one dose of a vaccine considered valid by Health Canada in a one dose COVID-19 vaccine series; and,

2. having fourteen days elapsed since the date upon which the person received the second dose of the COVID-19 vaccine considered valid by Health Canada of a two dose series, or one dose of the COVID-19 vaccine considered valid by Health Canada in a one dose vaccine series.

B. “Employee” means any individual employed by Chinook’s Edge School Division (the “Division”).

C. “Practicum Students” means any individual who engages in Division related activities and who has direct contact with Division employees and/or students within the role of:

1. any kind of educational placement or practicum provided through an agreement between the Division and a post-secondary educational institution (i.e. student teachers, educational assistants, nurses, psychologists, behavior therapists, speech language pathologists etc.); or,

2. any internship, co-op placement or apprenticeship program.

D. “Contractor” means any individual employed by another organization retained by the Division to provide services, or any individual with whom the Division has entered into a contractual relationship and who is identified therein as an independent contractor. 

E. “Volunteer” means an individual who is providing unpaid assistance to the Division staff on a recurring or one-time basis.

PROCEDURES

A. VACCINATION AND TESTING REQUIREMENTS- EMPLOYEES

1. As of January 10, 2022, all Division Employees will be required to either:
  
a. have submitted acceptable proof of Full Vaccination against COVID-19; or
b. submit acceptable proof of a negative COVID-19 test completed within the 72 hours prior to the                  commencement of each of the Employee’s “workdays” or “shifts” .

2. Any Employee that does not provide People Services with either acceptable proof of Full Vaccination or acceptable proof of a negative COVID-19 test pursuant to Section 1 above, shall be considered non-compliant with this Administrative Procedure. 


B. PROOF OF FULL VACCINATION

3. On or before November 26, 2021, Employees who have elected to submit proof of Full Vaccination to comply with this Administrative Procedure must provide People Services with a copy of their Alberta Health COVID-19 Immunization Record, or when available and verifiable by the Division, a QR code that verifies their COVID-19 vaccine record. 

4. Effective January 10, 2022, Contractors, Volunteers, and Practicum Students who have elected to submit proof of Full Vaccination to comply with this Administrative Procedure must provide the school or appropriate department with a copy of their Alberta Health COVID-19 Immunization Record, or when available and verifiable by the Division, a QR code that verifies their COVID-19 vaccine record.

5. An Alberta Health COVID-19 Vaccination record can be obtained at https://www.albertavaccinerecord.ca/#/. A QR code can be obtained at https://covidrecords.alberta.ca/home.

6. Employees, Contractors, Volunteers, and Practicum Students must update their vaccination status with the Division, school or department if changes occur.

7. Where applicable, equivalent proof of vaccination documents from another Canadian Province or Territory or the Canadian Armed Forces may be accepted. Whether an equivalent proof of vaccination is satisfactory will be in the sole discretion of the Division.

C. PROOF OF A NEGATIVE COVID-19 TEST

8. Employees who have elected to comply with this Administrative Procedure by providing proof of a negative COVID-19 test completed within 72 hours prior to reporting to work must inform People Services of their intention to participate in testing on or before November 26, 2021.

9. CESD will provide access to rapid tests for Employees who have elected to provide proof of a negative COVID-19 test to comply with this Administrative Procedure at their work site that can be self administered under the supervision of a trained person until the end of the 2021-2022 school year at no cost to the employee. These tests will be administered outside of the employees work day on their own time.

10. Employees who have elected to provide proof of a negative COVID-19 test to comply with this Administrative Procedure, who choose not to take part in the work site testing option outlined in section 9 above, must provide People Services with a report demonstrating a negative result of a Health Canada approved:

a. rapid antigen screening test, 
b. rapid polymerase chain reaction (PCR) test; or
c. laboratory based PCR test

within 72 hours prior to the commencement of each of the Employee’s “workdays” or “shifts”. The tests shall be procured by the Employee at their own expense and on their own time. Self-produced documentation of a negative result from a test not administered by a pharmacy or laboratory is not sufficient and will not satisfy the requirements of this Administrative Procedure.

11. Contractors, Volunteers, and Practicum Students who have elected to provide proof of a negative COVID-19 test to comply with this Administrative Procedure must provide the school or appropriate department with a report demonstrating a negative result of a Health Canada approved:

a. rapid antigen screening test, 
b. rapid polymerase chain reaction (PCR) test; or
c. laboratory based PCR test

within 72 hours prior to the commencement of each of the Contractor, Volunteer, or Practicum Student’s “workdays” or “shifts” at their own expense. Self-produced documentation of a negative result from a test not administered by a pharmacy or laboratory is not sufficient and will not satisfy the requirements of this Administrative Procedure.

12. The COVID-19 test described in sections 10 and 11 above must have a  report that clearly states:

a. the type of test;
b. time of sample collection;
c. a clear indication of a negative result; and
d. the name and address of the laboratory or pharmacy that completed the test.

D. ADDITIONAL OBLIGATIONS FOR EMPLOYEES

13. The Division recommends that Employee testing normally occur on either Sundays or Mondays prior to the start of the workday or shift and on Wednesday to provide the Employee  the opportunity to work Monday through Wednesday based on a negative result of the Monday test, and Thursday and Friday based on a negative test result from the Wednesday test.

14. If an Employee’s test results come back positive, the Employee is required to book themselves absent (sick) and request a substitute, if required, in the sub booking system.

15. In the event that an Employee tests positive in response to a COVID-19 rapid antigen screening test, the Employee must:

a. submit to mandatory COVID-19 PCR testing as soon as possible following confirmation of the results of the rapid antigen screening test, and as directed by the Division;
b. inform the Division of the Employee’s positive test result through People Services;
c. isolate until the results of the COVID-19 PCR test are confirmed; 
d. comply with any requirements for isolation imposed by the Government of Alberta or local health authorities; and
e. provide proof of a negative COVID-19 PCR test prior to attending at any Division property if the results from the PCR test from section 15(a) above is negative.

E. VACCINATION AND TESTING REQUIREMENTS - NON-EMPLOYEES (VOLUNTEERS, PRACTICUM STUDENTS OR CONTRACTORS)

16. Unless a Division parent or guardian is acting in the capacity of a Volunteer, Division students, parents and guardians are not subject to this Administrative Procedure.

17. As of January 10, 2022, any Contractor, Practicum Student, or Volunteer for a Division activity who may have direct contact with Employees and/or Division students must be Fully Vaccinated or provide proof of a negative COVID-19 test completed no more than 72 hours prior to the time the Contractor, Practicum Student, or Volunteer will have contact with Employees or Division students in their capacity as a Volunteer, Practicum Student or Contractor. Proof of Full Vaccination or a negative COVID-19 test, will be required pursuant to the rules as outlined in Sections B and C above.

18. Costs of all testing for Contractors, Practicum Students or Volunteers shall be paid by the individual required to produce the test results. For further clarity, the Division shall not be responsible in any way for the costs of testing.

F. EXEMPTIONS

19. The Division recognizes its responsibilities and duties pursuant to the Alberta Human Rights Act. If an Employee is unable to be vaccinated due to a protected ground as defined by the Act, the Division will consider requests for exemption and reasonable accommodation to the point of undue hardship.

20. Any employee seeking an exemption from compliance with this Administrative Procedure due to a protected ground under the Alberta Human Rights Act should notify People Services as soon as possible. People Services will advise any Employee requesting an exemption of the information the Division will require to evaluate the Employee’s request. Appropriate reasonable accommodations for Employees with legitimate exemptions that are accepted by the Division will be determined on a case by case basis.  

21. The Division may determine that an Employee who has been granted an exemption may be reasonably accommodated by being required to submit proof of a negative test for COVID-19 completed within 72 hours of the Employee reporting for work. In these instances, the cost of testing shall be at the Division’s expense.

G. NON-COMPLIANCE

22. Compliance with this Administrative Procedure is mandatory. The Division will review each instance of non-compliance considering the context and circumstances, including any requests for accommodation due to a protected ground under the Alberta Human Rights Act

23. Any failure to comply with this Administrative Procedure by an Employee, including the refusal or failure to provide proof of Full Vaccination or negative COVID-19 test results, or the provision of false or misleading information in any regard, shall be considered non-compliance.  The Division shall, at its discretion, determine which available option(s) will be appropriate to address the Employee’s non-compliance including, but not limited to, leave of absence without pay and benefits.

24. Any Contractors, Volunteers or Practicum Students to which this Administrative Procedure is applicable, who fail to comply with any part of this Administrative Procedure, including being found to have falsified proof of Full Vaccination or negative test results, will be considered to be in non-compliance with this Administrative Procedure and must  immediately leave Division property and cease performance of all duties as a Contractor, Volunteer, or Practicum Student. With respect to any Practicum Students, any event of non-compliance may result in reporting the event of non-compliance to the appropriate post-secondary institution.

H. CONTINUED COMPLIANCE WITH ALL HEALTH AND SAFETY PRECAUTIONS

25. All Employees are expected and required to continue to comply with all applicable health and safety measures to reduce the hazard of COVID-19, including but not limited to compliance with screening protocols, wearing a mask or face covering, using provided PPE, maintaining appropriate physical distancing and self-monitoring for potential COVID-19 symptoms daily prior to attending the workplace.

I. PROTECTION OF PRIVACY

26. The Division will only collect, use, and disclose any personal information regarding any individual subject to this Administrative Procedure in accordance with the Freedom of Information and Protection of Privacy Act (“FOIP”).

27. Information regarding any individual’s vaccination status, including but not limited to any individual’s Alberta Health COVID-19 Immunization Record is collected pursuant to Section 33(c) of FOIP, will  be kept confidential, stored in a secure location, and access and disclosure limited to that permissible by FOIP.

28. Information disclosed by a Contractor, Volunteer, or Practicum Student pursuant to this Administrative Procedure will be held by the Division for the minimum amount of time necessary to confirm their compliance with this Administrative Procedure.

J. PREVENTION OF HARASSMENT, BULLYING OR DISCRIMINATION

29. Harassment, bullying or discrimination of any type against individuals based on their vaccination status, compliance with this Administrative Procedure or any other reason will not be tolerated. Employees experiencing harassment, bullying or discrimination are encouraged to review Administrative Procedure AP 4-32: Respect in the Workplace.

K. ADMINISTRATIVE PROCEDURE REVIEW

30. Pursuant to the current background and context set out at the beginning of this Administrative Procedure, this Administrative Procedure is considered temporary due to the evolving and dynamic nature of this public health matter, and ongoing direction, recommendations, and advice from public health officials and Alberta Education. As a result, this Administrative Procedure will be periodically reviewed (at least every 6 months) and updated/amended as deemed necessary.

 

REFERENCE AND LINKS

HISTORY