5.A.150 Staff COVID-19 Rapid Testing

Safe Schools








Administrative Procedure: Staff COVID-19 Rapid Testing



October 2021
















Policy Reference



Legal Reference


Public Schools Act (Manitoba) 41(1)

Workplace Safety and Health Act (Manitoba) 4(1) & 4(2

Personal Health Information Act,






The Border Land School Division herein after referred to as “Division” is committed to upholding its statutory obligations to provide a safe environment to all pupils who attend our schools, all employees who work in our facilities, and all members of our community who volunteer or visit our schools (Public Schools Act 41(1); Workplace Safety and Health Act 4(1) & 4(2)).

On August 24, 2021, Manitoba Public Health announced its intention to introduce new Public Health Orders that would compel all employers providing services to vulnerable populations (including children) to observe the implementation of mandatory collection of proof of full vaccination or mandatory testing of all employees and school site visitors having direct contact with children. These Orders were published on September 24, 2021 and come into effect on October 18, 2021.  https://manitoba.ca/asset_library/en/proactive/20212022/orders-soe-vaccination-testing-designated-persons-09242021.pdf

On September 2, 2021, Manitoba Education published additional directives pertaining to “immunization and testing requirements” that serve to operationalize the mandatory collection of proof of full vaccination or mandatory testing of all employees and school site visitors having direct contact with children.

This procedure is one component of the Pandemic Response Plan that aims to:

  • ensure a successful return to in-school learning, uninterrupted by COVID-19 outbreaks;
  • reduce transmission of COVID-19 in the Division’s schools and facilities; and
  • mitigate the risk of severe COVID-19 outcomes among individuals in our schools, particularly those individuals who are unable to be vaccinated due to legitimate medical, personal or religious reasons or for whom vaccines are not currently approved, notably children.


In accordance with the September 2, 2021, directives published by Manitoba Education on “immunization and testing requirements” https://manitoba.ca/asset_library/en/proactive/20212022/orders-soe-08272021.pdf educational workers including teachers, educational support staff, school administration staff, custodial staff, bus drivers, child care staff working in school-based early learning and child care facilities, clinical and health care related occupations in schools; volunteers; and post-secondary practicum students, are required to provide proof of full vaccination or submit to testing “up to three times per week.”

To comply with these requirements the Division has developed this procedure, providing that all of its employees and/or volunteers who have direct contact with pupils in the Division must undergo testing up to three times per week or provide proof of full vaccination. Additionally, the Division mandates that all school trustees are required to submit proof of full vaccination or test prior to entry to school properties where children may be present.


For the purposes of this procedure, “fully vaccinated” shall mean individuals who have received both doses (any combination) of an approved two dose COVID-19 vaccine (AstraZeneca, Pfizer, Moderna), or a single dose of an approved single dose COVID-19 vaccine (Janssen/Johnson & Johnson) with more than 14 days having passed since the final vaccination was received, which definition shall be subject to ongoing amendment and compliance with the Manitoba Public Health definition of “full vaccination” which may exceed the current dosage definition.  




  1. All persons employed or engaged by the Division as of September 2, 2021 —including casual, term, and permanent employees—are asked to disclose and provide proof of full COVID-19 vaccination status by September 10, 2021, or when it becomes available, to the Human Resource Manager or Superintendent.


  2. Employees who are not fully vaccinated against COVID-19 or who do not disclose their COVID-19 vaccination status will be required to undergo COVID-19 testing up to three times per week until they have provided proof that they are fully vaccinated.


New Employees

  1. All persons offered casual, term, or permanent employment, or engagement as volunteers in the Division after September 2, 2021, will be required to disclose and provide proof of full COVID-19 vaccination status at the time of hire or engagement or undergo COVID-19 testing up to three times a week, until they have provided proof that they are fully vaccinated.




Notwithstanding the foregoing and consistent with its human rights obligations, the Division will duly accommodate employees who are legally entitled to accommodation to the point of undue hardship. All employees requesting accommodation must participate in the accommodation process and provide reasonable and necessary information requested by the Division related to the accommodation request.  Failure to do so, may result in the Division being unable to provide any accommodation.

Procedure Review

This procedure will be reviewed and will be revised or rescinded, as established requirements, Public Health Orders and/or conditions warrant.




  1. The Division will accept the digital or physical version of the Manitoba Immunization Card as proof of COVID-19 vaccination status.  Other forms of proof will be assessed by the Division. Staff can submit proof of vaccination in an ongoing way.
  2. Collection of personal health information will comply with the provisions of the Personal Health Information Act,
  3. Personnel responsible for hiring new employees or engaging new volunteers will verify the full vaccination status of applicants and advise of testing protocols if vaccination status is not revealed.
  4. Employees and volunteers required to submit COVID-19 test results up to three times per week, must do so according to the schedule determined by the Division, prior engaging in direct contact with a pupil.

    An employee who is not at work or not on site on a day that they are scheduled to provide their test result, must provide it the day of their return to work or to the facility, prior to entering a school facility and/or prior to entering into direct contact with a pupil.

    The Division will accept the results of a self-administered rapid test as defined by the Division.

    An employee receiving a positive test result following such a test must:


    1. attend a Province of Manitoba Testing Site for a confirmatory test;
    2. isolate and follow the advice of public health; and
    3. return to work upon the advice of public health.


  5. An employee’s first rapid test will occur with a test supervisor, prior to any at home tests being implemented.


  6. Employees shall receive training videos, training booklets and safety data sheets prior to attending to their first verified test.  These materials are to be reviewed prior to coming to the employees first scheduled appointment.
  7. The Superintendent of Schools will:
    1. closely monitor the requirements and recommendations of the Manitoba Education, Manitoba Public Health and the Governments of Manitoba and of Canada,
    2. advise the Board of any changes in circumstance which may impact the need and/or application of this procedure, and recommend procedure revisions, including rescindment.
  8. Any breach of this procedure by a Divisional employee, including the provision of false and/or misleading information, may result in discipline, up to and including termination of employment or revocation of volunteer privileges.

 This Administrative Protocol outlines procedures related to COVID-19 testing of staff. These procedures apply in situations where an employee is required to submit COVID-19 test results under Admin Procedure 5.A.150

  1. Prior to the commencement of the workday and/or prior to entering into direct contact with a pupil, an employee that has not provided proof that they are fully vaccinated must self-administer a COVID-19 rapid test, or other test as specified by the Division, up to three times per week according to the schedule determined by the Division. At the discretion of the Division, employees may be provided all testing supplies.


  2. When rapid testing is specified by the Division as the testing method, three rapid tests must be self-administered each week for all persons who work on a full-time basis, of which a minimum of one rapid test must be self-administered on-site at Border Land School Division Offices in Altona or Dominion City with designated test supervision. The schedule of on-site self-administration will be determined by the Division. Sample schedules for employees working daily:


    1. On-site – Tuesday; at home – Thursday & Monday
    2. On-site – Wednesday; at home – Friday & Monday
    3. On-site – Thursday; at home – Monday & Wednesday
    4. On-site – two or more days per week.


    As per 2iv above, at the discretion of the Division, employees may be required to undergo supervised on-site self-administration on a more frequent basis.


  3. The period of time between the self-administration of tests will not exceed 48 hours during the week, and self-administration of tests will not exceed 48 hours prior to engaging in direct contact with pupils, whichever is applicable to every employee. 


  4. Should an employee fail to undergo rapid testing within 48 hours prior to engaging in direct contact with pupils, they must not attend the workplace or facility and, for all employees and volunteers, must immediately notify their principal/supervisor or other person designated by the Division.


  5. Appointments for on-site self-administered testing must be made in advance. Walk-ups are not permitted.


  6. Employees are to arrive at scheduled appointment times, not earlier. Employees will observe physical distancing while waiting, don a medical mask upon entering, perform hand hygiene upon entering, self-monitor for COVID-19 symptoms before attending the onsite supervision, and self-isolate when sick.


  7. An employee who is not at work, on a day that they are scheduled to self-administer the rapid test on-site, must cancel their appointment as far in advance as possible and notify the test supervisor via the [email protected] email. The employee is required to contact the test supervisor and to schedule another appointment on the day of their return to the school facility, prior to entering the school facility and/or prior to entering into direct contact with a pupil.


  8. Testing will not occur during periods of extended leave (one week duration or longer), but testing must resume no more than 48 hours prior to returning to the workplace and/or facility.


  9. The results of self-administered tests conducted at home may be subject to verification by the Division. Home test results must be recorded on the form provided: BLSD Attestation and this form must be brought to each supervised test appointment.


  10. The Division will designate test supervisors for supervision of self-administered on-site rapid testing of employees.


  11. At all times, on-site rapid testing is to be self-administered by those employees who are subject to mandatory testing requirements. Test supervisors will not administer tests.


  12. The test supervisor will:
    1. monitor on-site self-administration of rapid tests by employees;
    2. ensure that the sampling and testing procedures are completed effectively and in keeping with guidelines;
    3. verify and witness rapid test results;
    4. respect employee or volunteer privacy and confidentiality as required by the division and PHIA.


  13. Should a rapid test yield positive results—whether conducted at home or on site, the employee bears the responsibility to immediately self-isolate and should seek confirmation of test positivity by completing a Polymerase Chain Reaction (PCR) COVID-19 test at the nearest Provincial testing site, at the earliest possible time.


    To be clear, the Division is not responsible for reporting positive test results to Public Health, based on an at-home or on-site rapid test. If the employee’s or volunteer’s PCR test confirms positivity, public health notification and contact tracing measures will be operationalized.


  14. The Division will provide for secure retention, retrieval and destruction of all records, in compliance with privacy, confidentiality and all safeguards concerning the protection of personal health information as specified by the Personal Health Information Act. 
  1. provide direction to employees regarding the safe, on-site disposal of completed test units;
  2. receive training on and implement applicable workplace safety and health protocols, including those related to handling and disposal of hazardous and/or medical waste; and
  3. wear required personal protective equipment as provided by the Division (i.e., medical mask, protective eyewear and/or face shield, impermeable latex gloves, and medical gown).

Border Land School Division

Border Land School Division acknowledges that the communities and schools located within Border Land School Division sit on Treaty 1 and Treaty 3 land, the original lands of the Anishinaabe peoples and on the homeland of the Métis Nation.

Border Land School Division respects the treaties that were made on these treaty areas and we dedicate ourselves to moving forward in partnership with our Indigenous communities in a spirit of truth, reconciliation and collaboration.