Staff Report #3
September 29, 2021
To All Commissioners
Re: COVID-19 Pandemic Response Update
The report be NOTED and FILED.
In response to the pandemic declaration in March of 2020, and subsequent to an extended period of responding to issues as they arose, administration developed a Pandemic Response Plan in an effort to navigate the organization through not only the pandemic period, but also the period following. The Plan is intended to guide the organization through the crisis and forward beyond the crisis to the new state of normal. The Plan breaks down the path to recovery into three primary phases:
- Resolve – assess issues as they arise in an effort to maintain services;
- Resiliency – reassess decisions made in the Resolve phase and implement practices and policies that will ensure resiliency going forward as the pandemic situation continues to evolve; and
- Rebuild – establish a transit system that has responded to the challenges created by the pandemic and its lasting effects including shifts in ridership patterns, levels and expectations; public health expectations relating to the safety of employees and riders; availability of funding from all levels of government; and community priorities.
Currently, the organization is considered to be working in both the Resiliency and Rebuild phases of the Plan, reviewing past decisions and practices for effectiveness and applicability for implementation during the fourth wave while at the same time, looking at measures that can be put in place to regain the ridership that was lost during the pandemic period.
The highest organizational priority throughout the pandemic has been ensuring the health and safety of London Transit employees and riders to the greatest extent possible. Some of the measures initially put in place have been replaced with updated safety equipment and/or alternate measures that are more applicable to the current situation. By way of example, the installation of Operator safety barriers provided for the ability to return to front-door boarding and the resumption of fare collection. The majority of safety measures that were established early in the pandemic remain in place, but some have been modified and others added. Measures currently in place include the following:
- On-board sanitizer for use of Operators to clean Operator area prior to shift change
- PPE Operator Safety Barriers installed on all buses to protect Operators from direct contact with passengers boarding at the front door
- Masks required to be worn by riders on-board buses at all times (subject to Provincial exemptions)
- Masks required to be worn by Operators on-board buses at all times (subject to Provincial exemptions)
- PPE hand sanitizer provided to all Operators/Inspectors for mandatory use any time they come into contact with a member of the public (i.e. tying down a mobility device)
- Eye protection provided to all Operators/Inspectors for use when interacting with a member of the public who is not wearing a mask
- Yellow line on buses that riders must remain behind in an effort to provide physical distance between Operators and riders
- All high-touch points on all buses are subject to a nightly cleaning/disinfection process
- Modified procedures for Community bus service to limit contact with riders
- External announcements at every stop reminding riders of mandatory mask use
- Internal announcements reminding passengers to exit via the rear door to maintain a one-way flow
- Installation of Active Air Purification System on-board the LTC conventional transit fleet, scheduled to be completed by the end of October 2021
- Employee and visitor screening in place prior to attending the workplace or accessing services at an LTC facility
- Mask use is mandatory in all facilities (with limited exceptions)
- All visitors or service providers are required to wear a mask in all LTC facilities at all times
- All high-touch points in facilities are cleaned/disinfected regularly and subject to monthly audit
- Protocols in place for cleaning of shared workstations prior to and end of shift, and/or a change in user
- Foot pulls have been installed on doors where applicable
- Common-use doors propped open where applicable
- Partitions and plexiglass barriers have been installed where applicable
- All LTC facilities, Garage and Office areas have been re-configured to ensure physical distancing between workspaces
- Hand sanitizer available throughout facilities
- Capacity limits and cleaning protocols in place for all meeting rooms and common areas
- Where warranted, additional time allocated to employees at end of shift to conduct cleaning of any shared tools
- Where warranted, modified shift start/end times to limit crowding in change rooms and time clock areas
- Encouraged use of phone meetings vs in-person where possible
While the list above does not include all measures in place, it provides a good overview of the number and nature of measures that have been established to protect the health and safety of LTC employees and customers. Consistent with the Pandemic Response Plan, these measures will continue to be revisited and assessed going forward.
With the Provincial announcement that proof of vaccination will be required in several higher risk indoor settings beginning September 22, 2021, coupled with the local guidance provided by the Chief Medical Officer of Health strongly encouraging workplaces to implement mandatory workplace COVID-19 vaccination policies with similar requirements, the need to develop and implement a policy for LTC employees has been prioritized.
At the August 25, 2021 Commission meeting, a verbal update was provided which indicated that at COVID-19 Vaccination Policy for London Transit employees was in the process of being developed. Subsequent to the August meeting, administration completed the COVID-19 Vaccination Policy, which has also been unanimously supported by the Joint Occupational Health & Safety Committee. The policy is set out in Enclosure I, dated September 29, 2021. The following provides an overview of the Policy requirements.
The first piece of the COVID-19 Vaccination Policy requires LTC employees to provide confirmation of vaccination status to the employer by no later than October 8, 2021. By this date, employees must confirm their status as one of the following:
- Fully vaccinated
- Not vaccinated due to Medical exemption
- Not vaccinated due to Human Rights exemption
- Not vaccinated
The second piece of the Policy requires that all employees be fully vaccinated or provide confirmation they meet one of the exemptions below no later than November 12, 2021. In order to be exempted from being fully vaccinated, an employee must:
- Provide proof of a medical reason from a licensed physician as to why they cannot be vaccinated against COVID-19 consistent with recognized medical exemptions as set out by the Ontario College of Physicians and Surgeons, and undertake regular testing as determined and required by London Transit; or
- Provide a proof of a non-medical reason protected by the Ontario Human Rights Code for not being fully vaccinated against COVID-19 and undertake regular testing as determined and required by London Transit.
Employees failing to meet one of the three criteria by November 12, 2021 will result in corrective and/or disciplinary action.
The COVID-19 Vaccination Policy also applies to contractors and consultants working for or on behalf of London Transit. In these cases, contractors/consultants will have until November 12, 2021 to provide an attestation that all employees working on behalf of London Transit (eg. specialized service contractor), or any employee working for London Transit that will be required to attend an LTC facility (eg. office cleaning contractor) meet one of the established criteria set out in the policy. Failure to meet the established criteria will result in the removal of contractor/consultant from LTC premises, and/or the cancellation of the contract.
The procedures related to the regular testing that may be required for those employees who fall into either of the exemption categories are still being developed. As the policy indicates, the requirement for, and frequency of testing is determined by London Transit, and it is anticipated that local case counts, outbreaks, and advice from local public health will all be considered when making such determinations. Until such time as there is a better understanding of the number of employees that would fall into these categories, it is difficult to estimate the costs associated with this undertaking; however, administration is confident that the costs can be accommodated within the current operating budget.
The prevalence of COVID-19 Vaccination policies external to LTC have the potential to impact washroom access for LTC Operators, noting both Western University and Fanshawe College policies will require that LTC Operators be able to demonstrate they are fully vaccinated in order to get off of their bus or attend washroom facilities on the respective campuses. With the Provincial Vaccine Passport system taking effect September 22, 2021, LTC Operators may face the same requirements for washroom locations that are located in restaurants/fast food locations. Administration is continuing to work with community partners that provide access to their washrooms for LTC Operators, and hope that the implementation of the LTC COVID-19 Vaccination Policy will result in agreements with these partners to make it easier for Operators to access washroom facilities.
Administration will continue to work on the implementation of the COVID-19 Vaccination Policy as well as any other policies that are deemed appropriate in response to the COVID-19 pandemic and updates will be provided to the Commission as warranted.
Policy for Commissioners
As set out in Communication #2, dated September 29, 2021, administration has been requested by a member of the Commission to draft a COVID-19 Vaccination Policy that would apply to members of the Commission. The Policy set out in Enclosure I is considered an administrative policy that applies only to LTC employees as well as consultants and contractors working on LTC’s behalf and/or attending LTC facilities.
Given the role of the Commission does not require regular visits to LTC workplaces (with the exception of monthly meetings should they return to in-person), or regular in-person interaction with LTC employees, the Commission may want to consider limiting the requirement for vaccination to those Commission members who plan to attend the LTC facilities or work in-person with LTC employees. Subsequent to feedback and formal direction from the Commission with respect to the need for and what should be included in a policy specific to Commission members, Administration will take the required next steps.
Joanne Galloway, Director of Human Resources
Concurred in by:
Kelly S. Paleczny, General Manager