Information contained in this publication is intended for informational purposes only and does not constitute legal advice or opinion, nor is it a substitute for the professional judgment of an attorney.
Updated: May 15, 2020
In Canada, the easing of restrictions due to the COVID-19 pandemic is determined by each individual province or territory. A number of provincial governments have announced how they plan to gradually ease restrictions with a view to eventually fully reopening their provinces. Below we describe the plans that have been announced to date. (All dates are 2020).
On April 23, Saskatchewan announced a five-phase plan called Re-Open Saskatchewan that will gradually reopen services in the province. Dates were provided for the implementation of only the first two phases.
Phase 1 will begin on May 4, when medical services (dentistry, optometry, physical therapy, optician services, podiatry, occupational therapy and chiropractic treatment), and low-risk recreational activities will reopen. Low-risk recreational activities will reopen in stages with fishing, boat launches, and online registrations for provincial parks reopening on May 4, golf reopening on May 15, and parks and campgrounds reopening on June 1. Restrictions on medical services will include the following precautionary measures: provider and client screening; use of gloves and face masks; a restriction on the number of persons in waiting rooms; a restriction on space between people; the screening of clients with visible symptoms of COVID-19; cleaning and disinfecting common areas and objects that are commonly touched. Gatherings will continue to be restricted to no more than 10 people.
Phase 2 will begin on May 19, when retail businesses (clothing stores, shoe stores, flower shops, sporting good/adventure stores, jewelry and accessory stores, toy stores, music and entertainment stores, pawn shops, and travel agencies) and select personal services (hairdressers/barbers, registered massage therapists, acupuncturists and acupressurists), will reopen. Providers are required to take the following precautionary measures: client screening; wearing masks and gloves; hand washing; intensive cleaning; and structuring stores to make physical distancing possible. Gatherings will continue to be restricted to no more than 10 people.
In Phase 3, the personal services not permitted to reopen in Phase 2 (including estheticians, tattoo artists, cosmetologists, electrologists, manicurists, pedicurists, sun tanning parlours, body piercing facilities, bone grafting or scarification services), will reopen, as will restaurant and food services, gyms, fitness facilities, licensed establishments, and childcare facilities. Gathering size will increase to no more than 15 people. However, restaurants, bars, food courts, cafeterias, cafes, bistros and similar facilities will be permitted up to 50% of their regular capacity.
Phase 4 will permit the reopening of indoor and outdoor recreation and entertainment facilities (including casinos, bingo halls, arenas, curling rinks, swimming pools, municipal parks and playgrounds, galleries, theaters, museums and similar facilities, seasonal programming, camps, and recreational and athletic services). Gathering size will increase to up to 30 people.
In Phase 5, the lifting of long-term restrictions will be considered.
Re-Open Saskatchewan recommends the maintenance of many COVID-19-related practices throughout all five phases, including physical distancing where possible, staying at home when sick, continued working from home if the work can be performed effectively, minimization of high-risk exposures for vulnerable populations, enhanced cleaning and disinfection in workplaces, public spaces, and recreational facilities, following recommended public health measures by businesses and workplaces, and requiring staff in long-term care facilities to work in only one facility.
On April 24, New Brunswick announcing its plan to reopen businesses, educational facilities, the health care system, recreational activities, and cultural events. It stated that the plan will be guided by the following four distinct public health alert levels: Red – the present phase aimed at flattening the curve and containing the virus as quickly as possible; Orange – aimed at balancing the reopening of social and economic settings while preventing a resurgence of transmission; Yellow – aimed at further increasing the reopening of social and economic settings after the ability to control transmission has been demonstrated; and Green – this phase will likely come after a vaccine is available or more is learned about how to protect people from the virus.
As a first step, it was announced that effective April 24, the following would be permitted: households may choose to spend time with one other household, if both households agree (household selections are not interchangeable); provided that all physical distancing and safety measures are in place, golf courses and driving ranges can open; the delay on spring season for recreational fishing and hunting is lifted; with physical distancing, people can enjoy the outdoors including parks and beaches; co-workers or neighbours can carpool if physical distancing measures are maintained by transporting the passenger in the backseat; post-secondary students requiring access to campus to fulfill their course requirements can have it; and, as an alternative to online worship, religious organizations can hold outdoor services if parishioners stay in their vehicles with two metres distance between vehicles. Large gatherings such as festivals and concerts will be prohibited through December 31, subject to change.
A guidance document of the public health measures during the recovery phases is being developed and will be available soon.
On April 27, Ontario released A Framework for Reopening Our Province, which contemplates the gradual reopening of the province in three stages, each of which will last for approximately two-to-four-weeks to permit close monitoring of any impacts or potential resurgences of cases. The Framework does not indicate a date on which any stage of the gradual reopening will begin.
In Stage 1, select businesses ordered to close or restrict operations will be permitted to immediately open their workplaces if they can meet or modify operations to meet public health guidance and occupational health and safety requirements (e.g., curbside pick-up or delivery); some outdoor spaces like parks will open and a greater number of individuals will be permitted to attend some events (e.g., funerals); hospitals will begin to offer some non-urgent and scheduled surgeries and other health care services; protections for vulnerable populations will continue as will physical distancing, hand washing, respiratory hygiene, and significant mitigation plans to limit health risks.
If the initial loosening of public health measures in Stage 1 is successful, in Stage 2 more workplaces will be opened based on risk assessments, and they may include some service industries, and additional office and retail workplaces. In addition, more outdoor spaces will be opened and some larger public gatherings will be permitted. Protections for vulnerable populations will continue as will physical distancing, hand washing and respiratory hygiene, and significant mitigation plans to limit health risks.
In Stage 3, all workplaces will open responsibly. Restrictions on public gatherings will be relaxed further, however large public gatherings such as concerts and sporting events will continue to be restricted in the foreseeable future. In addition, protections for vulnerable populations will continue as will physical distancing, hand washing and respiratory hygiene, and significant mitigation plans to limit health risks. Large gatherings (e.g., festivals and concerts) will be prohibited through December 31, subject to change.
The Framework indicates that the gradual assessment of public health measures will continue until a vaccine or treatment for COVID-19 is available. A guidance document of public health measures during the recovery phases is under development and will soon be available.
On May 1, Ontario announced that by following the proper health and safety guidelines, the following seasonal businesses and essential construction projects will be permitted to begin operations on May 4, at 12:01 a.m.:
- Garden centres and nurseries with curbside pick-up and delivery only;
- Lawn care and landscaping;
- Additional essential construction projects that include:
- shipping and logistics;
- broadband, telecommunications, and digital infrastructure;
- any other project that supports the improved delivery of goods and services;
- municipal projects;
- colleges and universities;
- child care centres;
- schools; and
- site preparation, excavation, and servicing for institutional, commercial, industrial and residential development;
- Automatic and self-serve car washes;
- Auto dealerships, open by appointment only;
- Golf courses may prepare their courses for the upcoming season, but not open to the public; and
- Marinas may also begin preparations for the recreational boating season by servicing boats and other watercraft and placing boats in the water, but they may not open to the public. Boats and watercraft must be secured to a dock in the marina until public access is allowed.
On May 14, Ontario announced that at 12:01 a.m. on Saturday, May 16:
- Golf courses will be able to open, with clubhouses open only for washrooms and restaurants open only for take-out.
- Marinas, boat clubs and public boat launches may open for recreational use.
- Private parks and campgrounds may open to enable preparation for the season and to allow access for trailers and recreational vehicles whose owners have a full season contract.
- Businesses that board animals, such as stables, may allow boarders to visit, care for, or ride their animal.
In addition, assuming trends in key public health indicators continue to improve, Ontario's first stage of reopening will begin on Tuesday, May 19 at 12:01 a.m. and it will include:
- Retail services not in shopping malls that have separate street-front entrances; physical distancing measures must be in place (e.g., limits on the number of customers in stores at any one time, booking appointments in advance or on the spot).
- Seasonal businesses and recreational activities for individual or single competitors, including training and sport competitions conducted by a recognized national or provincial sport organization, including indoor and outdoor non-team sport competitions that can be played while maintaining physical distancing and without spectators (e.g., tennis, track and field and horse racing).
- Pet care services (grooming and training).
- Regular veterinary appointments.
- Indoor and outdoor household services that can follow public health guidelines (e.g., housekeepers, cooks, cleaning and maintenance).
- Lifting essential workplace limits on construction.
- Allowing certain health and medical services to resume (e.g., in-person counselling and scheduled surgeries based on the ability to meet pre-specified conditions as outlined in A Measured Approach to Planning for Surgeries and Procedures).
Ontario also announced that it has launched the Workplace PPE Supplier Directory, which provides up-to-date information about Ontario companies and business associations that can supply personal protective equipment (PPE) to businesses.
Prince Edward Island
On April 21, Prince Edward Island announced a phased-in approach to easing public health measures called Re-opening PEI, together. On April 28, the government released the plan, which will be implemented in four phases. The plan will progress gradually, and will be constantly evaluated; if there are concerns about progressing to the next phase, progress will be slowed, halted, or reversed.
In Phases 1 through 3, travelers will continue to be screened at points of entry to PEI with self-isolation for 14 days required, home-based learning options, with some limited activities will be permitted, and visitor restrictions in long-term care will remain in place.
Phase 1 will commence on May 1. Outdoor gatherings and non-contact outdoor recreational activities of no more than five people from different households, while social distancing, will be permitted (e.g., recreational fishing, golf courses, and current PEI residents going to their own seasonal properties). Select outdoor and construction services will also be permitted with physical distancing (e.g., landscaping, road construction, indoor construction projects, watershed clean-up, and outdoor photography). Priority non-urgent health care services will begin (elective surgeries, cardiac supports, cancer screening), and physiotherapists, optometrists, opticians, chiropractors, foot care providers, occupational therapy and naturopaths will begin to provide services. Other health care will continue virtually where possible and feasible. Priority public services will be provided.
Phase 2 will commence on May 22. Limited indoor gatherings of no more than five individuals from different households while social distancing will be permitted. The limit on outdoor gatherings will increase to no more than 10 individuals from different households, while social distancing. Non-contact indoor recreational activities will be permitted. Retail businesses will be permitted to open and select indoor services will be allowed. Unlicensed and licensed child care centres will be permitted to provide services, additional non-urgent health care services, and additional public services will be provided.
Phase 3 will commence on June 12. With the proviso that it is “potential”, the plan indicates that in Phase 3 the following will be allowed: gatherings of no more than 15 people indoor and 20 people outdoor, including religious gatherings, while social distancing; organized recreational activities, and the opening of recreational facilities and services, and public spaces; additional personal services, indoor dining and accommodations for PEI residents only; continued transition to increased non-urgent health services; and providing public services.
Phase 4 will involve further relaxation of measures as the situation permits.
On April 28, Quebec announced that the gradual reopening of various sectors and businesses will occur in phases according to areas of activity and geographic zones, and emphasized that it will be essential at all times that the public continue to observe health recommendations to limit the risk of COVID-19’s spread. The plan to reopen activities notes that until April 27, the sectors subject to reopening were added to the province’s list of priority services and activities.
The plan addresses three separate areas: economic activities (relating to the retail sector, the construction industry, and manufacturing); preschools, elementary schools and secondary schools; and educational childcare services.
Commencing on May 4, retail stores with direct exterior access can resume their activities, except those in Montreal, which may reopen on May 18. Businesses in the supply chain of retail stores can resume their activities on the same dates. Commencing on May 11, all construction industry worksites (residential, civil engineering and roads, institutional, commercial, and industrial) can resume activities. The industry’s supply chains will reopen simultaneously. Administrative staff in the sector must continue teleworking. Also commencing on May 11, manufacturing companies can resume activities, however at all times throughout the day they must limit staff per shift to a maximum of 50 workers and 50% of the employees exceeding the limit of 50 workers. Commencing on May 25, manufacturing companies throughout Quebec can resume their operations with no limitations on the number of employees present. Employees who can engage in teleworking must continue to do so. Businesses to be added in subsequent phases will be announced in the coming weeks.
Preschools, elementary schools and secondary schools
Schools and daycares were closed on March 13, although some daycares were kept open for the children of parents working in essential services. In accordance with the plan, commencing May 11, preschools and elementary schools will be progressively reopened to students in Quebec, but not in Montreal. Commencing on May 19, preschools and elementary schools will reopen in Montreal if the situation allows. Secondary schools will remain closed until September, however distance learning will continue with improved pedagogical support.
Educational childcare services
Commencing on May 11, all childcare services, including non-subsidized daycares and recognized and non-recognized family daycare centres, will be progressively reopened throughout Quebec, with the exception of Montreal. All children whose parents are working in an economic sector that will be reopening as announced will return to the daycare they attended before its closure on March 13. Commencing on May 19, childcare services in Montreal will reopen if the situation allows.
On May 13, Quebec announced a plan to gradually resume certain outdoor sports and leisure activities throughout Quebec, provided the guidelines issued by the public health authorities, especially physical distancing rules, are followed. Beginning on May 20, recreational sports, leisure and outdoor activities carried out individually or in pairs, without physical contact, will be permitted.
On April 29, Manitoba released its plan to ease restrictions put in place in response to the COVID-19 pandemic, and to restore services. The plan, Restoring Safe Services Together: Manitoba’s Phased Approach, states that each phase will be observed for a minimum of three to four weeks, to determine acceptable next steps or new restrictions implemented, and that as information becomes available and data on the current situation is analyzed, some measures may be introduced or new restrictions implemented.
Phase One will begin on May 4, and will involve restoring non-urgent surgery, diagnostic procedures, and therapeutic and health care services; reopening retail businesses; restoring restaurants (patio walk-up services only); and reopening hairstylists and barbers, museums, galleries and libraries, and outdoor recreation and campgrounds.
Phase Two will begin no earlier than June 1, and may include expanding public gatherings; restoring restaurant dine-in services; reopening film productions; and restoring children’s non-contact sports.
In future phases, public health measures and travel restrictions may be further eased based on public health data and surveillance. Specific consideration will be given to performing arts venues, other non-essential businesses, and large gatherings/events.
On April 30, Alberta published Opening Soon: Alberta’s relaunch strategy. Unlike other provinces, Alberta never halted the operation of construction, manufacturing and energy.
The following early actions were announced. Commencing on May 1, vehicle access to parking lots and staging areas on public land and parks, and access to boat launches will open. Commencing on May 2, golf courses can open with restrictions, including keeping clubhouses and pro shops closed (they will open consistent with other businesses that will open in stage one). Commencing on May 4, Alberta Health Services will resume some scheduled non-urgent surgeries, and dental and other regulated health care workers will be allowed to resume services (e.g., physiotherapists, speech language pathologists, respiratory therapists, audiologists, social workers, occupational therapists, dieticians, chiropractors, optometry and more), provided they follow approved guidelines set by their professional Colleges. Commencing on May 14, the Alberta Parks’ online campground reservation system will open for bookings at select campgrounds beginning June 1 onward.
In addition, the relaunch will comprise the following three stages.
In Stage 1, which will begin as early as May 14, some businesses and facilities will be allowed to reopen and resume operations with two-metre physical distancing requirements and other public health guidance in place. These businesses and facilities include: the continued delivery of courses by post-secondary institutions (whether they are delivered online, in-person, or with a blend, will depend on the restrictions still in place at each relaunch phase); retail businesses (e.g., clothing, furniture, and bookstores); some personal services (e.g., hairstyling and barber shops); museums and art galleries; more scheduled surgeries and dental procedures; daycares with limits on occupancy; summer camps with limits on occupancy (this could include summer school); cafés, restaurants with no bar service, with public seating at 50% capacity; and some additional outdoor recreation. There will be rules and guidance for the use of masks in crowded spaces, especially on mass transit. Visitors to patients at health-care facilities will continue to be limited. Public attendance at businesses, facilities and events that have close physical contact will not be permitted, including arts and culture festivals, major sporting events, and concerts. Movie theatres, pools, recreation centres, arenas, spas, gyms, and nightclubs will remain closed. Remote working is advised where possible. Vulnerable Albertans not based in facilities will be encouraged to stay at home as much as possible.
The timing of Stage 2 will be determined based on the success of Stage 1, the capacity of the health care system, continued limiting and/or reduction of the infection rate, hospitalizations, and ICU cases. In Stage 2, additional businesses and services will reopen and resume operations with two-metre physical distancing requirements and other public health guidance in place. These businesses and services include: (“potential”) Kindergarten to Grade 12 schools, with restrictions; libraries; more scheduled surgeries, including backlog elimination; personal services (e.g., artificial tanning, esthetics, cosmetic skin and body treatments, manicures, pedicures, waxing, facial treatments, massage and reflexology); restaurants, cafés, lounges and bars continuing to operate at reduced capacity); larger gatherings in some situations (the number of people to be determined as more is learned about levels of risk for different activities); and movie theatres and theatres opening with some restrictions. Visitors to patients at health-care facilities will continue to be limited. Nightclubs, gyms, pools, recreation centres and arenas will remain closed. Arts and culture festivals, concerts and major sporting events will still not be permitted. Non-essential travel is not recommended.
The timing of Stage 3, is to be determined based on health indicators with gradual implementation. It will involve fully reopening all businesses and services, with limited restrictions, and permitting larger gatherings (the number of people at such gatherings is to be determined). Arts and culture festivals, concerts and major sporting events will be permitted with enhanced protection controls in place. Nightclubs, gyms, pools, recreation centres and arenas will reopen with enhanced protection controls in place. Physical distancing restrictions will be maintained. Industry conferences will be resumed with restrictions, and non-essential travel will no longer be discouraged.
Key public health measures will be in place in all stages. In Stages 1 through 3: maintaining physical distancing of two metres will be required.
In Stages 1 and 2, the wearing of masks in public will be encouraged where physical distancing is not possible; non-essential travel will not be recommended; visitor, staff and operational restrictions will be in place for vulnerable Albertans based in facilities; non-essential travel will not be recommended; and 14 days of isolation and quarantine will be required for cases, close contacts, and returning travelers, and 10 days of isolation and quarantine will be required for those who are symptomatic but don’t fit into the previously listed categories.
In Stages 2 and 3, the size of permitted gatherings will increase; and vulnerable Albertans living outside of facilities may resume normal activities and interactions.
In Stage 3, the wearing of masks in public where physical distancing is not possible, will be unnecessary; and the following will be lifted: restrictions relating to visitors, staff and operations for vulnerable Albertans based in facilities; the recommendation against non-essential travel; and rules relating to isolation and quarantine.
Finally, Alberta announced that more information on a new blueprint for economic recovery will be provided in the coming days and weeks.
On May 13, Alberta announced that Stage 1 of Alberta’s relaunch strategy will begin on May 14 for all areas in Alberta except for Calgary and Brooks. Residents of Calgary and Brooks are encouraged to wait for local services to reopen rather than travelling for services. Businesses on the approved list for Stage 1 are advised that they can determine for themselves if they are ready to open. Mask use is strongly recommended in crowded public spaces, like mass transit, that do not allow for physical distancing of 2 metres apart. Gatherings of more than 15 people are not permitted, unless otherwise identified in public health orders or guidance. Gatherings of 15 people or fewer must follow physical distancing and other public health guidelines. Travel outside Alberta is not recommended. Remote working is advised where possible. And finally, it is recommended that Albertans download the AB Together mobile contact tracing app and use it when in public.
Newfoundland and Labrador
On April 30, Newfoundland and Labrador announced its plan for gradually relaxing public health restrictions, A Foundation for Living with COVID-19. The Plan includes five alert levels and the relaxation of restrictions will depend on the province’s alert level, as determined by its Chief Medical Officer of Health (CMOH).
Effective April 30, households were permitted to spend time with one other “household bubble,” and were cautioned to take care regarding who is in their bubble to avoid increasing the risk to a vulnerable individual.
On April 30, when the plan was released, the province was in Alert Level 5. The pace at which the public health restrictions will be relaxed or strengthened will depend on the speed of community transmission, and the effectiveness of contact tracing.
At Alert Level 4, which will commence on May 11, gatherings will be expanded to 10 people, provided physical distancing is maintained; gatherings at funerals, burials and weddings will be restricted to a maximum of 10 people, including the officiant; low-risk outdoor recreational activities can resume (e.g., recreational angling and hunting; walking, bike riding, and hiking, provided physical distancing is maintained and self-isolation is not required). Municipal parks will open but playground equipment in the parks may not be used. In addition, childcare services will be expanded on a limited basis; professional services (accounting firms, law firms, and financial services) can be offered in person, although work from home policies are encouraged where possible; in-person worker and workplace safety training will be permitted; gardening centres will be permitted to open for in-person sales and services, and landscape and lawn series can operate; animal daycares can resume operations; some healthcare services will be permitted to resume by regional health authorities; private health care clinics can open for urgent and emergent care, with virtual care for non-urgent care.
At Alert Level 3, private health care clinics can resume operations, medium risk businesses can open, childcare services can be expanded further, restaurants can re-open at reduced occupancy, and medium-risk recreational activities can resume.
At Alert Level 2, small gatherings will be permitted, higher risk businesses can open, subject to conditions, and medium-risk recreational facilities can open, subject to conditions.
At Alert Level 1, consideration will be given to the lifting of long-term public health measures dependent on an evaluation of transmission patterns of COVID-19, the availability of an effective vaccine or treatment, and a strong public health system that can identify cases and trace contacts.
On May 6, 2020, British Columbia released its Restart Plan.
Phase 1 is the province’s current state, which permits only the operation of essential services.
Phase 2 will begin in mid-May (a specific date was not indicated), and under enhanced protocols it will permit: re-scheduling elective surgery; providing medically related services, including dentistry, physiotherapy, registered massage therapy, chiropractors, physical therapy, speech therapy, and similar services; the reopening of the retail sector, hair salons, barbers, and other personal service establishments, in-person counselling, restaurants cafes, and pubs (with sufficient distancing methods), museums, art galleries, and libraries, office-based worksites, recreation and sports, parks, beaches and outdoor spaces, and child care.
Provided transmission rates remain low or in decline, Phase 3 will span June through September under enhanced protocols. In June, hotels and resorts will reopen, and parks will reopen more broadly, including some overnight camps. In June/July, the film industry will restart beginning with domestic productions. In July, movies and symphonies will restart, but large concerts will not. In September, post-secondary education will open with a mix of online and in-class classes, and kindergarten through grade 12 education will also open; there will be only a partial return this school year.
The timing of Phase 4 is to be determined, and will be conditional on at least one of the following: wide vaccination; “community” immunity; and broad successful treatments. In this phase, the following will be permitted: activities requiring large gatherings, such as conventions, live audience professional sports, and concerts; and international tourism. Noting that the timing of a safe restart of night clubs, casinos and bars is a more complicated consideration, the Restart Plan indicates industry associations will be expected to develop safe operation plans that are in keeping with Public Health and Safety Guidelines and WorkSafeBC.
The Restart Plan indicates further that: BC parks, recreation sites and trails that can accommodate physical distancing will reopen for day use only beginning on May 14; camping at provincial parks and recreation sites will reopen June 1, with some exceptions.
With regard to the re-opening of schools, the Restart Plan indicates that an announcement on a phased approach to resuming in-class instruction will be made in the coming weeks, but it emphasizes that this will not be a return to normal. Although British Columbia is exploring ways to get children back to school before the summer, the Restart Plan acknowledges that with weeks left in the school year, many children will not return to the classroom until September.
British Columbia’s Restart Plan emphasizes that everyone in the province must continue to do their part at home, in the community, and at work. This includes: staying at home and keeping a safe distance from family when one has cold or flu symptoms, including coughing, sneezing, runny nose, sore throat, and fatigue; not shaking hands or hugging outside of family; practicing good hygiene, including regular hand washing, avoiding touching one’s face, covering coughs and sneezes, and disinfecting frequently touched surfaces; physical distancing as much as possible when in the community and where not possible, considering the use of a non-medical mask or face covering. The Restart Plan also emphasizes that in personal settings, when people see friends and family who do not live with them, this should occur in small groups of between 2 to 6 people, and if someone has cold or flu symptoms they should stay home and away from others.
In addition, the Restart Plan indicates that employers are required: under the Workers Compensation Act, to ensure the safety of their employees at work; to review the new Health and Safety Guidelines, best practices and other resources from WorkSafeBC, and adapt them into appropriate COVID-19 Safe Plans for their workplaces. In addition, sectors that operated during the pandemic may need to update their COVID-Safe Plans to “fit with” the updated Health and Safety Guidelines, best practices and resources. And finally, different organizational sectors will be asked to develop enhanced protocols aligned with the Public Health and Safety Guidelines.
Bottom Line for Employers
Governments in jurisdictions not listed above have yet to release plans for how they will ease restrictions. Employers with operations in those jurisdictions should remain alert for the release of such plans. We will be following developments closely and will provide timely and detailed updates of any new plans released.
Employers in Canada that have operations in a single jurisdiction should be able to follow the rules relating to the easing of restrictions in that jurisdiction with relative ease, however employers must be careful to ensure that their execution is in accordance with the jurisdiction’s requirements. The process will be more complex for employers that have operations in multiple Canadian jurisdictions because each jurisdiction is determining its own plan, and they are not identical. It is important that employers properly manage the unique rules relating to the easing of restrictions in each jurisdiction in which they operate. To ensure that they proceed as required, employers are encouraged to consult counsel during this process.