FAQ – Owners & Operators

Last reviewed/updated: 2:52 p.m., January 28, 2021

These Frequently Asked Question do not constitute legal advice. To ensure legal compliance with all applicable provincial regulations, individuals and businesses should consult the Orders currently in force under the Reopening Ontario (A Flexible Response to COVID-19) Act and/or obtain legal advice.


Questions & Answers

  1. I own/operate a business/organization, do I need to ensure that face coverings are worn by every patron who enters?
  2. Can a patron be exempt from wearing a face covering?
  3. Do I need to ask patrons for proof of exemption?
  4. Lots of patrons are coming into our business without a face covering. What can we do?
  5. Can a business deny entry if a patron does not wear a face covering?
  6. How will the provincial mandatory face covering requirements be enforced in Peterborough?
  7. Can a patron remove their face covering at any time?
  8. Are employees required to wear a face covering at all times?
  9. Are employees required to wear a face covering if they are separated from the public by a physical barrier?
  10. Are staff allowed to temporarily remove their face covering to communicate with people who have a hearing impairment?
  11. My staff are outside workers.  Are they required to wear a face covering?
  12. Can I ask my staff for proof of exemption?
  13. I have a staff member who is exempt from wearing a face covering. What should I do?
  14. A 3-layer face covering is recommended by the Public Health Agency of Canada, does this mean 2-layer face coverings cannot be used?
  15. Are face coverings required in a restaurant?
  16. Are face coverings required in places of worship?
  17. Are face coverings required in gyms or other fitness establishments?
  18. Are face coverings mandatory in common areas of condominiums or apartment buildings?
  19. Are face shields an appropriate face covering?
  20. Can I allow my staff to wear a clear plastic mouth shield a face covering?
  21. Are neck gaiters or buffs a safe face covering?
  22. Where can I get more information about face coverings?
  23. Where can I get signage or resources to train my staff?
  24. Where can I go if I have more questions?

1. I own/operate a business/organization, do I need to ensure that face coverings are worn by every patron who enters?

According to provincial Regulations, an owner/operator of a business or organization must ensure that any person in the indoor area of the premises, or in a vehicle that is operating as part of the business or organization, wear a mask or face covering in a manner that completely covers their mouth, nose, and chin during any period inside. To do this you must:

  • Post signage reminding patrons that face coverings are required upon entry.
  • Identify a process for reminding patrons in the indoor area of this requirement.
  • Train staff to ensure a consistent approach for issuing reminders to patrons, guests, and customer.
  • Consider having a supply of disposable face coverings on hand to provide to patrons who do not have one to wear.

If you have staff who deliver a service (e.g., server at a restaurant, hairdresser, esthetician, coach, trainer, etc.) and is required to come within 2 metres of patron who is not wearing a face covering and is not separated by an impermeable barrier, then the staff member must wear PPE, including a medical grade mask and eye protection (face shield, safety glasses, or goggles).  There are no exemptions for this requirement.

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2. Can a patron be exempt from wearing a face covering?

Yes. A patron may be exempt from wearing a face covering if they:

  • are a child who is younger than two years of age;
  • are attending a school or private school within the meaning of the Education Act that is operated in accordance with a return to school direction issued by the Ministry of Education and approved by the Office of the Chief Medical Officer of Health;
  • are attending a child care program at a place that is in compliance with the child care re-opening guidance issued by the Ministry of Education;
  • are receiving residential services and supports in a residence listed in the definition of “residential services and supports” in subsection 4 (2) of the Services and Supports to Promote the Social Inclusion of Persons with Developmental Disabilities Act, 2008;
  • are in a correctional institution or in a custody and detention program for young persons in conflict with the law;
  • are performing or rehearsing in a film or television production or in a concert, artistic event, theatrical performance or other performance;
  • have a medical condition that inhibits their ability to wear a mask or face covering;
  • are unable to put on or remove their mask or face covering without the assistance of another person;
  • need to temporarily remove their mask or face covering while in the indoor area,
    • to receive services that require the removal of their mask or face covering,
    • to engage in an athletic or fitness activity,
    • to consume food or drink, or
    • as may be necessary for the purposes of health and safety;
  • being accommodated in accordance with the Accessibility for Ontarians with Disabilities Act, 2005;
  • being reasonably accommodated in accordance with the Human Rights Code; or
  • perform work for the business or organization, is in an area that is not accessible to members of the public and is able to maintain a physical distance of at least two metres from every other person while in the indoor area.

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3. Do I need to ask patrons for proof of exemption?

No. As per provincial Regulations, patrons are not required to provide proof of their exemption. You are expected to ask the patron to put on a face covering. If they tell you they are exempt, you can ask for the nature of the exemption (e.g. medical), but no further action needs to be taken and proof of exemption is not required. If you can provide an alternate solution, such as a face shield, that would be beneficial. For staff, you must follow appropriate occupational health and safety laws and regulations.

4. Lots of patrons are coming into our business without a face covering. What can we do?

  1. Post signage at all entrances reminding everyone that enters that a face covering is required.
  2. Kindly remind all individuals who enter your businesses or organization that a face covering is required. If anyone provides a valid exemption, you are not required to ask for proof. Consider offering alternate service delivery for those who cannot wear a face covering (e.g. curbside pickup, do the shopping for the individual, provide a face shield, etc.)
  3. Keep a log of this information to demonstrate your due diligence for ensuring compliance with the legislation.

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5. Can a business deny entry if a patron does not wear a face covering?

Owners and operators of businesses or organizations are encouraged to look for alternatives for those that are exempt from wearing a mask to still be able to receive their goods and services, such as making appointments, having special hours for shopping, or offering curbside pick-up. As an owner and operator, you have rights under the Trespass to Property Act. While you may be able to deny entry or service, Peterborough Public Health recommends that any business wishing to refuse service to customers without face coverings seek independent legal advice about their rights and obligations before taking any action.

6. How will the provincial mandatory face covering requirements be enforced in Peterborough?

Public Health Inspectors from Peterborough Public Health, as well as municipal by-law officers, local police officers, and the Ministry of Labour, Training & Skills Development can enforce these requirements and will be actively following up on any complaint received about non-compliance.  Any charges laid can be given to the individual, as well as to the business or organization where the non-compliance occurred.

7. Can a patron remove their face covering at any time?

Individuals are permitted the temporary removal of a face covering:

  • when necessary to receive services offered by the establishment/organization (including eating or drinking where dine-in services are allowed)
  • while actively engaging in an athletic or fitness activity including water-based activities
  • as is necessary for the purpose of health and safety

Please ensure you wash your hands using soap and water or an alcohol-based hand sanitizer before and after removing your face covering.

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8. Are employees required to wear a face covering at all times?

Yes. Employees in any space where members of the public are permitted entry must wear a face covering at all times. However, if an employee is in a staff only area (completely inaccessible by members of the public) AND can maintain 2 metres distance from other staff at all times, then face coverings can be temporarily removed, but must be put back on when the employee moves about the office or other shared space.

If you have an employee that is required to come within 2 metres of someone who is not wearing a mask or face covering and is not separated by an impermeable barrier, this staff member must wear Personal Protective Equipment (medical grade mask and eye protection). If the individual is unable to wear their PPE, then modifications to job duties must be implemented to ensure that the person remains two metres from others at all times or that a physical barrier is present.

As an owner/operator/employer, you are reminded of your requirements under the Orders currently in force under the Reopening Ontario (A Flexible Response to COVID-19) Act, as well as the Occupational Health and Safety Act to take every reasonable precaution to protect the health and safety of workers. This includes protecting workers from hazards posed by infectious diseases.

9. Are employees required to wear a face covering if they are separated from the public by a physical barrier?

Yes. Employees must wear a face covering, even if a plexiglass barrier is present, in any instance where 2 metres physical distancing from another staff member or member of the public cannot be maintained. This requirement is in line with the Ontario COVID-19 Workplace Safety Guidance that recommends multiple controls for workplaces, including engineering controls (i.e., barriers) AND administrative controls (i.e., face coverings).

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10. Are staff allowed to temporarily remove their face covering to communicate with people who have a hearing impairment?

Some people who are deaf or hard of hearing rely on lip reading to help understand verbal messages, and face coverings may create a barrier. Employees should keep an open mind when communicating with a person who is deaf or hard of hearing, particularly when wearing a face covering, and let the person suggest their preferred way of communicating.

There may be situations where someone who is deaf or hard of hearing may require an employee to remove their face covering to speak to the customer. We remind anyone removing their mask or face covering to follow safe handling procedures and to keep a distance of 2 metres (6 feet) away from others, and keep the interaction as short as possible.

11. My staff are outside workers.  Are they required to wear a face covering?

Maybe. The answer depends on the scenario:

  • If your staff member works outdoors and is alone, they do not need a face covering.
  • If any staff member who works outdoors AND comes within 2 metres of another person (whether a patron or another staff member) must wear a face covering.
  • If your staff member comes within 2 metres of another person (whether a patron or another staff member) and this person is not wearing a face covering, your staff member is required to wear Personal Protective Equipment (medical grade mask and eye protection).

It should be noted that as an employer, you are required to take every reasonable precaution to protect the health and safety of employees whether a workplace is indoors or outdoors.

12. Can I ask my staff for proof of exemption?

Employers may ask staff for proof of exemption if necessary, in accordance with workplace policies. Members of the public do not have to provide proof, but employees may need to if required by the employer.

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13. I have a staff member who is exempt from wearing a face covering. What should I do?

If a staff member is exempt from wearing a face covering, you are required to accommodate this staff member. Accommodation will look different for each workplace, but you are encouraged to consider the following:

  • Provide a face shield that wraps around the sides of the face and goes well below the chin. NOTE: The Public Health Agency of Canada has indicated that face shields alone do not provide suitable source control or personal protection and should only be used if a mask cannot be worn, in conjunction with other precautions, including physical distancing.
  • Ensure that the employee works behind a physical barrier and maintains two metres of separation between colleagues and members of the public at all times
  • Provide alternate shift times or duties that are not public-facing and do not require that worker to be within two metres of employees

14. A 3-layer face covering is recommended by the Public Health Agency of Canada, does this mean 2-layer face coverings cannot be used?

You can continue to wear your well-fitting two-layer face covering made of tightly woven materials as these are effective at providing source control and work almost as well as three-layer face covering, especially to block your own respiratory droplets from others in the event you had COVID-19. However, as you replace or add to your face coverings, look for 3-layered options. In addition, many two-layer face coverings have the option to add a middle filtration layer.

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15. Are face coverings required in a restaurant?

Yes. Patrons AND employees are both required to wear face coverings in a restaurant. Patrons can temporarily remove their face covering when eating or drinking, but must keep them on until they are seated at a table and moving through a shared space (to/from table, restroom, etc.).

Staff at dining establishments (servers and bartenders) who come within 2 metres of someone who is not wearing a mask or face covering and is not separated by an impermeable barrier must wear PPE to protect their eyes (i.e. safety glasses, goggles or a face shield) along with a medical-grade or surgical mask. This is an enhanced public health measure under the Reopening Ontario Act and associated regulations that is specific to employees for an increased level of protection against the acquisition and transmission of COVID-19.

16. Are face coverings required in places of worship?

Yes. Everyone attending a place of worship, must wear a face covering the entire time that they are indoors – this includes the people leading the service, ceremony or rite.

The person leading service, ceremony or rite may remove their face covering if:

  1. They are in an area not accessible by the public (delineated and/or posted as such), AND
  2. They are physically distanced by at least 2m from everyone else, AND
  3. A face covering is put back on if they cannot maintain #1 or #2

Face coverings must be worn by people participating in ceremonies, rites, and services (i.e. bride and groom, bridal party, God parents, etc.).

17. Are face coverings required in gyms or other fitness establishments?

Yes. Patrons AND employees must wear a face covering in the indoor portions of gyms and fitness establishments. If an activity or exertion level does not allow for a face covering, members of the public are permitted to remove their face covering temporarily, but should put it on again when the strenuous activity is complete (for example: when stretching, travelling through shared space).

Staff at gyms or fitness establishments (trainers and coaches) who come within 2 metres of someone who is not wearing a mask or face covering and is not separated by an impermeable barrier must wear PPE to protect their eyes (i.e. safety glasses, goggles or a face shield) along with a medical-grade or surgical mask. This is an enhanced public health measure under the Reopening Ontario Act and associated regulations that is specific to employees for an increased level of protection against the acquisition and transmission of COVID-19.

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18. Are face coverings mandatory in common areas of condominiums or apartment buildings?

Yes. Anyone in the common area of a multi-unit dwelling (condominiums and/or apartment buildings) must wear a face covering. This includes: laundry room, mail room, parking garages, stairwells, hallways, elevators, and other similar spaces. Face coverings in these spaces are required by tenants, staff, custodians, contractors, and caretakers.

19. Are face shields an appropriate face covering?

A face shield is not a substitute form of face covering. When you wear a plastic shield, you do not have a snug fit around your nose, chin, and mouth. A face shield may provide extra precaution for the wearer against droplets from another person, but serves as a form of eye protection, rather than a face covering. Droplets can still be inhaled around the shield. Respiratory droplets from the wearer can also escape around the sides of the face shield, which provides less protection to others. If you choose to wear a face shield, you should do it in combination with a cloth face covering. NOTE: For anyone exempt from wearing a face covering, the Public Health Agency of Canada has indicated that face shields alone do not provide suitable source control or personal protection and should only be used if a mask cannot be worn, but would need to worn in conjunction with other precautions, including physical distancing.

20. Can I allow my staff to wear a clear plastic mouth shield a face covering?

No. Clear plastic mouth shields are not a suitable form of face covering. Clear plastic mouth shields that rest on the chin and wrap around the sides of the face have significant gaps, particularly around the nose and at the top of the shield. They do not fit closely to the face which means that respiratory droplets can escape. Additionally, these shields cannot be cleaned and disinfected properly between uses.

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21. Are neck gaiters or buffs a safe face covering?

No. Neck gaiters or buffs are not a safe type of face coverings as they do not allow the wearer to safely put one on and take one off. Additionally, the type of fabric/material used to produce the neck gaiter may render it to be ineffective as a face covering. A proper face covering should have 3 or more layers of breathable fabric (one layer should be a filter layer) and have a snug fit around your mouth, nose, and chin with no gaps.

22. Where can I get more information about face coverings?

There is lots of great information and resources on our Information for the Public: Mandatory Face Covering page.

23. Where can I get signage or resources to train my staff?

There is lots of great information, signage, and resources on our Information for Owners/Operators/Employers: Mandatory Face Covering page.

24. Where can I go if I have more questions?

If you have additional questions or concerns, you can contact Peterborough Public Health at 705-743-1000 or email covid19@peterboroughpublichealth.ca for more information.

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