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Framework for implementation of the policy on COVID-19 vaccination for the Canadian Food Inspection Agency

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The Policy on COVID-19 Vaccination for the Canadian Food Inspection Agency (Policy on Vaccination) became effective on November 8, 2021. This framework, intended to complement the Policy on Vaccination, is an evergreen document, and will evolve as science and public health guidance evolve.

Timeline for implementation and compliance

November 8, 2021 – effective date of the Policy on Vaccination

November 8 to November 22, 2021 – attestation period

November 22 to December 6, 2021

December 6, 2021 – full implementation date of the Policy on Vaccination, or 2 weeks following the "attestation deadline" as defined in Appendix A of the Policy on Vaccination

Key considerations

Vaccination attestation requirement


Required training session

Working abroad


When collecting personal information for the delivery of this program, institutions are reminded to ensure they respect the following legal and policy requirements:

Direct collection

Section 5 of the Privacy Act requires that wherever possible, personal information should be collected directly from the individual. As such, vaccination status of employees should be collected from the employees themselves and not via provincial or territorial authorities.

Safeguards for uses and disclosures

As per section 6.2.19 and 6.2.20 of the Directive on Privacy Practices, as referenced in the CFIA Privacy Management Framework (available on Government of Canada network only), institutions must identify which positions or functions in the program or activity have a valid reason to access and handle personal information and limit access to and use of, personal information by administrative, technical, and physical means. Measures should be taken for minimal intrusiveness, such as:

Retention schedules

As per section 4 of the Privacy Regulations, with some exceptions, personal information shall be retained for a period of at least 2 years following the last time it was used for an administrative purpose, such as determining access to the workplace.

Privacy notice statement

As per section 6.2.9 of the Directive on Privacy Practices, a privacy notice is required. It should include the purpose and legal authority of the collection; any uses or disclosures associated; the consequences for refusal; the right to access and correct any personal information collected; and the right to complain to the Privacy Commissioner regarding the handling of the information.

Duty to accommodate (for employees unable to be vaccinated)

Nothing in this framework supersedes the CFIA Workplace Accommodation Policy (available on Government of Canada network only). The Employer has a duty to accommodate individuals' needs when those needs relate to 1 or more of the prohibited grounds of discrimination under the Canadian Human Rights Act, up to the point of undue hardship. In the case of vaccines, this could include:

The President, CFIA is responsible for:

Deciding if the duty to accommodate applies

Step 1: Requesting accommodation when unable to be fully vaccinated

Step 2: Gathering relevant information

Supporting documentation:

Step 3: Making an informed decision

Implementing accommodation when warranted

When the delegated manager decides that the duty to accommodate applies, accommodation must be provided up to the point of undue hardship. Given the public health considerations, the choice of accommodation should also ensure the safety and security of the workplace, along with privacy obligations.

The following are recommended accommodation measures:

  1. Where operationally feasible, employees will perform regular duties or responsibilities through telework supported by a telework agreement as per the CFIA Telework Policy (available on Government of Canada network only).
  2. Employees will be assigned alternate duties or responsibilities that can be completed through telework supported by a telework agreement as per the CFIA Telework Policy.
  3. Employees will complete regular mandatory testing as per the CFIA Framework on Mandatory COVID-19 Testing based on guidance from the Health Canada Testing Secretariat, and:
    • follow all preventative practices implemented in the workplace and other preventative practices as recommended by Public Service Occupational Health Program and other organizational requirements
    • not perform duty travel, unless essential
  4. Other measures detailed in communication with the employees and documented in the accommodation decision.

Step 4: Implementation

Delegated managers must promptly advise employees of the decision, the rationale for the decision, the accommodation to be provided, if applicable, and the steps that must be taken to implement it. The employee's manager will then work with the employee to implement the accommodation measures following these steps:

Step 5: Recordkeeping

Partially vaccinated employees

The Policy on Vaccination and Framework will provide flexibility to employees demonstrating willingness to be vaccinated, and who have taken concrete steps to do so.

Employees unwilling to disclose their vaccination status or who choose not to be fully vaccinated

Timeline for Compliance

Effective date of the Policy on Vaccination: November 8, 2021.

Step 1: Advise employees of consequences of not meeting the vaccination requirement

Attestation Deadline (November 22, 2021, or 2 Weeks after the attestation deadline as defined in Appendix A of the Policy on Vaccination):

Step 2: Attestation period

Full Implementation Date of the Policy on Vaccination (December 6, 2021) or 2 weeks following the "attestation deadline" as defined in Appendix A of the Policy on Vaccination:

Step 3: Mandatory Testing for those unable to be vaccinated and who must report to work on-site

Step 4: Consequences begin

Employees are placed on leave without pay effective December 7, 2021 and the Employer stops assigning employees hours of work.



Related policy instruments

Additional information

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