Where required to do so, many federally regulated employers in the marine, aviation and rail sectors were required to confirm the implementation of their mandatory vaccination policies to Transport Canada by November 15, 2021. This implementation is part of Transport Canada’s federal vaccine mandate for key federally regulated transportation sectors, save road transportation.
Going forward, employers who implement mandatory vaccination policies under orders issued by Transport Canada must comply with applicable requirements to collect, retain and report information with respect to the implementation of their vaccination policies. To assist employers navigate the new requirements under this federal vaccine mandate, Transport Canada recently released guidance with answers to general questions, which may be helpful.
Employers should take note that reporting frequency can depend on the scope of the their vaccination policies and industry. For example, in the marine sector, employers who have implemented a vaccination policy applicable to all their employees, including shore-side employees whose employment responsibilities do not require them to be on board the vessel or cruise ship, must report monthly. Marine employers who have implemented a policy that is only applicable to crews on their vessels or cruise ships, and persons who board them, must report weekly.
To facilitate reporting requirements, Transport Canada has implemented the Electronic Collection of All Transportation Statistics (ECATS) platform for digital reporting. A user guide on how to navigate the ECATS has been shared with a number of affected employers and industry stakeholders. For each reporting period, employers have been directed to use the ECATS platform to report the following information, where required to do so:
- The total number of employees subject to the company’s vaccination policy;
- The number of fully vaccinated employees;
- The number of partially vaccinated employees;
- The number of employees with a valid medical exemption;
- The number of employees with a valid religious exemption;
- The number of employees on leave as a result of not being fully vaccinated or partially vaccinated, or do not have a company approved exemption; and
- The number of employees unable to perform their duties as a result of COVID-19. For example, affected employers must report all employees, regardless of vaccination status, who have tested positive and are required to isolate or cannot report to work as per the company policy.
Employers must be sure to collect and retain any additionally prescribed information that cannot be reported in the ECATS platform, and be prepared to provide this information to Transport Canada. An example, again in the marine industry, of additional required information includes the name of the vessels and cruise ships that are the subject of the report.
Transport Canada had advised that it is currently working on addressing some technical difficulties with accessing the ECATS platform and has asked participants for their patience. Transport Canada has requested that all participants preserve the required information in the meantime.
