Educational institutions are embarking on a fall semester like none other. Most have already developed plans for managing the risk of COVID-19 spread in schools, on campuses, in residences and in workplaces. This short note raises an important planning point for Ontario institutions that arises out of a peculiarity in the province’s current self-isolation guidance.
The significance of access control and provincial guidance
The most fundamental duty of an educational institution this fall is to control access to schools, campuses and workplaces. The object is to keep employees, students and visitors who may be contagious out of the environment and away from others, an objective most often accomplished by employing passive and active screening protocols.
Determining who is at great enough risk of being contagious to be excluded from study and work is a complex matter of medical science. Each province, though, has considered the science, weighed the risks and issued guidance. The guidance is not law (unless incorporated into an order), but should be followed as it can be presumed to be valid. In other words, it would be very hard to accuse an institution who follows provincial guidance of negligence or a failure of due diligence.
Provincial self-isolation rules address symptoms, travel and contact
In all provinces, individuals with symptoms and individuals returning from out-of-country travel are to self-isolate, and in some provinces those returning from inter-provincial travel are to self-isolate.
Most provinces only urge close contacts of those with symptoms to be cautious – to monitor themselves for symptoms while going about daily life. In these provinces, contacts are only required to self-isolate if the other individual’s case is “confirmed” via diagnoses. Institutions outside of Ontario with residences have therefore planned to move roommates out of the same living space as those who are sick while cautioning roommates to self-monitor pending any contact from public health.
The Ontario guidance is protective and strict
Ontario is different. Currently, Ontario’s self-assessment tool directs individuals who have been in “close physical contact” with symptomatic individuals to immediately self-isolate. Close physical contact means “being less than 2 metres away in the same room, workspace, or area” or “living in the same home.” The self-assessment tool also tells those with symptoms to advise their close physical contacts to self-isolate.
The Ontario guidance is protective and strict, particularly given the long list of COVID-19 symptoms. However, the province has been quite clear that housemates (and other close physical contacts) of those with symptoms should self-isolate, even before a case is confirmed. Ontario institutions should appreciate that they are taking a risk if they allow these individuals to attend class and other organized activities. There are also implications for managing students in residences.
The Ontario guidance invites an institutional response to suspected cases
The Ontario guidance invites contacts to self-isolate well before public health becomes involved in contact tracing, and pressures institutions to engage in active case management that resembles contact tracing. If, for example, an instructor who has recently been in a lab with students reports ill with COVID-19 symptoms, there is an immediate issue of potential exposure to consider. Given the provincial guidance, simply waiting for public health contact those who may have been exposed if and when there is a diagnosis is problematic.
Some Ontario institutions have failed to appreciate the idiosyncrasy pointed out in this publication. These institutions have screening protocols that are under-inclusive and have planned for greater reliance on public health contact tracing efforts than may be appropriate. Although there is a burden imposed by the Ontario guidance, it is one that all Ontario institutions should carefully consider.