September 13, 2021 | Circular No. 11315

Dear Member,

As reported in CL 11311, Transport Canada announced last month that all federally regulated workers in the transportation sector (marine, air, rail) will be subject to a mandatory Covid-19 vaccination requirement by the end of October 2021.

The Department is now working to define the mechanism(s) through which this requirement will be implemented, how prescriptive / enforceable it will be, and the specific employee groups to whom it will apply.  We have had several discussions with TC on these issues, with particular focus on the extent to which the requirement will apply to employees of shipping companies and marine agencies working in an office setting.

In order to help inform TC’s thinking in this respect, we would ask members to respond to the questions below, which are designed to provide Transport with greater insight into the structure and operations of our member companies, as well as the vaccination practices and policies they may already have in place.  As always, we will consolidate any responses we receive and provide them to TC in aggregate form only.  We will also share aggregated results of the survey with members overall.

Questions for Members

  • Is your company federally or provincially regulated?
  • Do the majority of your company’s employees work mainly in an office setting, or do they also work off-site (travelling to and from ships, visiting other offices, etc.)?
  • Does your company currently have a vaccination policy in place?
  • If yes, would you agree to provide us with an overview of the policy?  We will not identify any company in our dealings with TC.
  • If your company does NOT have a vaccination policy in place, can you advise why this is the case and/or whether there any specific reasons for same?
  • Aside from vaccination requirements, what other Covid-19 mitigation measures does your company have in place? What (if any) challenges have you encountered in enforcing these measures?
  • If your company does NOT currently have a vaccination policy in place, would a strong mandate from Transport Canada be helpful in implementing such a policy?

Given that Transport Canada’s vaccination policy is slated to come into effect by the end of October, we would ask members to respond to the above questions at their earliest convenience, and by the end of this week at the latest.  Please send all responses, as well as any additional questions or concerns, to the undersigned.


Karen Kancens
Vice President