As many congregations return to in person worship, and as the Province of Ontario and other jurisdictions implement various versions of proof of vaccine mandates, congregations are asking questions about what their duties, responsibilities and limits are in this matter.
At this time, in the Province of Ontario, churches are exempted from the requirement of proof of vaccination for those attending worship.
That said, there are clear protocols in place that churches must follow.
The first is that churches MUST comply with the regulations of their local and provincial health units. At the very least this means that all churches must take seriously mask mandates, social distancing and contact tracing.
So, if we use the City of Toronto as an example we see that:
- Masks are required indoors. This Toronto bylaw can be found here.
- Physical distancing protocols must be observed.
- Health screening (self-screening) must take place, as well as attendance records kept for contact tracing.
- Requirements for cleaning, signage, ventilation and the like must be followed.
- Gathering for fellowship after the service falls under different guidelines and is restricted to 25 indoors and 100 outdoors, with all persons wearing masks. This Toronto bylaw can be found here.
All of these things are designed to ensure that our churches remain a safe and healthy place.
(The City of Toronto document regarding reopening guidelines for businesses and organizations can be found here)
Proof of Vaccination Documentation
The only thing that is not mentioned in this policy is whether churches can require proof of vaccination from their employees, volunteers and those who enter the church building.
So can we?
Yes, we can, if we choose to do so, within our individual congregation’s safety policy.
The first and most important thing a church should do is have a congregational safety policy. Indeed, this is a request of the City of Toronto. According to the city a church’s policy may include vaccine requirements for various people.
In designing your church’s policy, the City of Toronto encourages people to use their safety plan checklist as a guide. This safety plan checklist can be found here. An additional planning document from the city can be found here.
For example, I recently received the policy of the Anglican Diocese of Toronto, found here. In this policy you will find that clergy, employees and volunteers are required to be vaccinated. Worship attendees are not required to be vaccinated. The Diocese of Toronto designed their policy regarding vaccination for various groups of people within their communities based on their evaluation of the risk and safety for all people who enter their building and interact with others. Each of our church sessions will need to do similarly.
The policy of the Diocese of Toronto might be more than the average session and congregation requires. Your policy can be significantly shorter, simply laying out local health regulations as well as any additional items your session has determined for your congregation. However, even if your congregation’s policy reflects no more than the policy of your local health unit, having such a document in place and circulated is useful in clearly stating expectations and preventing any misunderstandings.
Should you choose to require proof of vaccination within your policy, you will also need to include protocols for record keeping and confidentiality.
- All churches must comply with the regulations of their local health units.
- Employers have a duty to provide health and safety protection for workers.
- It is important that churches develop their own policies and plans as per local regulations. (see attached planning sheets for components of a policy)
- Existing safety protocols are effective in preventing the transmission of Covid.
- In terms of requiring vaccines, it is helpful to distinguish between staff (including volunteers) and worship attendees.
As we move forward this season, there are many questions and varying answers. Staying informed and staying flexible is key to responding with grace and faithfulness.
Please note: Any ministry to vulnerable populations such as hospital or care facility visitation are governed by the regulations of those facilities and not our churches. I would also note that the policy of the Diocese of Toronto also applies to renters and users of buildings.
Please note: This is not legal advice, rather it is a summary of what I have been able to discover through research.