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Sex clubs and bathhouses have officially reopened in Toronto and here are the rules

Ontario entering Step 3 marks a return to the closest form of "normal" any of us in Toronto has seen in well over a year — if not since before the pandemic first hit and threw us into lockdown mode.

Nightclubs, indoor restaurants and gyms are definitely hogging the spotlight right now as amenities allowed to reopen under Step 3, but so many other industries are similarly rebooting operations, including sex clubs and bathhouses.

Like any place where people gather in groups, these social venues must still follow strict health and safety protocols to operate as safely as possible amid (what we hope is) the tail end of the pandemic

Here, per the City of Toronto, are the (abridged) guidelines in place for staff and patrons of Toronto sex clubs and bathhouses under Step 3 of reopening in Ontario.

General Guidance for Bathhouses and Sex Clubs
  • Encourage employees to get vaccinated.
  • Promote vaccination among patrons by making vaccine resources available on the premises (e.g. factsheet, posters).
  • Along with HIV/STI/safer sex information, educate patrons about COVID-19 risk reduction in the context of sexual activity.
  • Develop strategies to minimize exposure to COVID-19.
  • Provide staff training on the required public health measures.
  • Limit the number of staff, clients and customers within the bathhouse or sex club premises to allow for physical distancing and to comply with capacity limits, as per provincial regulations.
  • Schedule frequent cleaning and disinfection of high-touch items, surfaces, and areas within the premises.
  • Inform staff and patrons about actions you are taking to keep everyone safe.
Safety Plan

Bathhouse and sex club operators must prepare and make available a safety plan. The plan must:

  • Describe measures/procedures that have been or will be implemented in the establishment to reduce COVID-19 spread.
  • Include measures for screening, physical distancing, masks, cleaning, disinfecting, PPE, as well as preventing and controlling crowding.
  • Be in writing and made available to any person for review, on request.
  • Be posted in a place that is visible to workers and patrons.
  • Use the COVID-19 Safety Plan Checklist to develop your safety plan. 
  • Capacity limits for bathhouses and sex clubs must ensure that all persons on the premises can maintain a two-metre distance from others, and must not exceed: 25 per cent capacity or 250 people (whichever is less). Not all premises will be able to hold 25 per cent capacity and maintain physical distancing.
  • 25 per cent capacity is determined by taking 25 per cent of the maximum occupant load of the bathhouse or sex club as calculated in accordance with Ontario Regulation 213/07 (Fire Code), made under the Fire Protection and Prevention Act, 1997.
  • Operators must post a sign in a conspicuous location visible to the public that states the capacity limits under which it is permitted to operate. To avoid crowding in specific areas, such as locker rooms, movie rooms, and saunas, operators may post signs with the number of people allowed into each room/space.
Physical Distancing 
  • Bathhouse and sex club operators are required to ensure that their employees keep a physical distance of at least two metres throughout the workplace and during eating and rest periods (e.g. lunchrooms, change rooms, washrooms).
  • Operators must ensure that patrons maintain two metres of physical distance from others, except when physical distancing cannot be maintained while participating in the activities for which patrons normally frequent bathhouses or sex clubs.
  • Masks and physical barriers provide added layers of protection, but are not substitutes for physical distancing.
  • Modify and manage the physical space to promote physical distancing.
  • Where possible, install one-way walkways to reduce close physical interactions
  • Remove surplus furniture/items from rooms and walkways to allow ease of movement while maintaining physical distancing
  • Use visual markers (e.g. tape on the floor, pylons, signs) to remind people where to stand to keep two-metre/six-foot distance from others.
  • Implement physical barriers (e.g. plexiglass) in customer service areas when physical distancing is not possible. The height of the barrier should take into account the tallest user and should consider the user's breathing zone, which generally extends 30 centimeters or 12 inches around (and above) the mid-point of a person's face.
  • Move or tape off seating to encourage physical distancing.
  • Close off alternate lockers and showers.
  • Operators are required to ensure that patrons maintain two metres physical distance from other groups of persons while in line or congregating outside the bathhouse or sex club.
  • Post physical distancing signs at all entrances, employee rooms, and public areas (e.g. service counters). 
PPE for Employees
  • Bathhouse and sex club operators must ensure that staff wear appropriate PPE, including surgical/procedure mask and eye protection (goggles or face shield).
  • Additional PPE may be required for other roles within the workplace (e.g. providing first aid). Operators must determine when and what PPE is required, and ensure that it is worn by workers.
  • Operators must train employees on how to safely put on and take off PPE.
  • AIDS Service or Health Organizations that send employees and volunteers into bathhouses or sex clubs (e.g. counsellors, outreach and harm reduction workers) are required to ensure that their staff and volunteers wear the appropriate PPE, and are appropriately trained on how safely put on and take off PPE.
Masks for Patrons
  • Bathhouse and sex club operators must ensure that patrons wear a mask or face covering which covers their mouth, nose and chin during any period in which they come within two metres of another person, unless any of the following exceptions apply:
    If a mask or face covering cannot be worn while participating in the activities for which patrons normally frequent bathhouses or sex clubs, or a patron is exempted from wearing a mask or face covering.
Health Screening
  • Bathhouse and sex club operators must comply with any advice, recommendations, and instructions issued by the Office of the Chief Medical Officer of Health on screening employees and patrons (O Reg 364/20).
  • Note that temperature checks for staff and patrons are not required, nor recommended.
  • Bathhouse and sex club staff must complete a health screening questionnaire before or when a worker enters the workplace at the beginning of their day or shift (active screening).
  • Bathhouse and sex club operators must ensure that all patrons complete a health screening questionnaire (active screening) before they enter the premises.
  • Staff may screen patrons using the patron screening guide or ask patrons to complete and present the provincial screening tool for customers online.
Attendance Tracking
  • Bathhouse and sex club operators must maintain daily attendance records for all staff, workers and volunteers for 30 days.
  • Operators are required to record the name and contact information of every patron that enters the establishment and keep these records for 30 days to support public health contact tracing efforts (e.g. name, date, time, and contact information).
  • Patrons may be reluctant to provide their name and contact information due to concerns about privacy and stigma. Inform patrons that this information is mandatory for entry into the bathhouse or sex club. Also, reassure patrons that their information will be kept confidential and secure, and only shared with Toronto Public Health in case contract tracing is required.
  • Encourage staff and customers to download the COVID Alert app so they can be notified directly if they have been in close contact with someone who was contagious with COVID-19. 
Hand Hygiene and Respiratory Etiquette 
  • Post Wash Your Hands, Cover Your Cough, and Protect Yourself signs in high traffic areas.
  • Ensure hand sanitizer (70-90 per cent alcohol concentration) and hand-washing facilities are available throughout the bathhouse.
  • Ensure an adequate supply of liquid soap, paper towel, hand sanitizer, tissues, and waste receptacles throughout the premises, including public and employee areas.
  • Glove use is not a substitute for proper hand hygiene.
  • If employees use gloves it is important to change them every hour, or more often, as necessary (e.g. when changing tasks).
  • Hands should be washed and/or sanitized between changes.
  • When gloves are removed, new gloves must be used each time.  Educate staff on proper hand hygiene and respiratory etiquette. 
Enhanced Cleaning and Disinfection
  • Implement rigorous and frequent environmental cleaning and disinfection of all frequently touched surfaces, at least twice a day or more frequently, as needed.
  • All bathhouse and sex club areas accessible to the public, including bar areas, washrooms, locker rooms, showers, saunas, hot tub areas, movie rooms, and fitness areas, must be cleaned and disinfected as frequently as is necessary to maintain a sanitary condition.
  • Equipment, tools and furniture that must be shared should be cleaned and disinfected regularly, including between users (e.g. computer stations, cashier stations, debit/credit terminals, cleaning carts, fitness equipment, patron locks/keys, slings, benches, sofas, beds, gloryholes).
  • Private sex rooms should be cleaned and disinfected after each use, including bed, locker, walls, door, handles. Ask patrons to leave linens (e.g. sheets, towels) in the room so to avoid transporting soiled materials to the cashier area.
  • All linens must be laundered and disinfected after patrons have finished using them.
Water Filtration and Disinfection
  • Bathhouses and sex clubs should review and implement guidance for Recreational Water Facilities in maintaining pools, hot tubs, and other water amenities.
  • Adequate water filtration and disinfection should remove or inactivate the virus that causes COVID-19.
  • Ensure the facility's water filtration and disinfection systems (i.e. with chlorine or bromine) are maintained and operating properly.
Food, Drink and Dance Facilities
  • Bathhouses and sex clubs that serve food/or and drink, as well as those with dance facilities, need to review the Guidance for Restaurants, Bars, and other Food Service Premises.



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