Registrar’s Directive: BAO Grey-Lockdown restrictions revised

Effective March 15, 2021

The Bereavement Authority of Ontario has revised its colour chart of COVID-19 restrictions in the Grey-Lockdown zones – aligning with the Government of Ontario’s Friday afternoon announcement.

Effective Monday, funeral services in Grey-Lockdown zones will be permitted to allow up to 15 per cent of total occupancy in the entire facility with physical distancing for indoor funerals up to a maximum of 50 people.

Outdoor ceremonies may have a maximum of 50 people in attendance. Funeral services include all funerals and visitations regardless of where they occur.

The BAO reminds all licensees that the attendance number restrictions are the maximum allowed. Cemeteries and funeral establishments may set even lower attendance numbers on their premises.

All cleaning and disinfecting between services are still required.

Everyone must wear a mask and observe two metres of physical distancing between people. 

At the end of this Directive: Read also the Registrar’s article on why the BAO is limiting funeral attendances to 50.

Key links


Why is the BAO limiting funeral attendances to 50, when churches and other venues can hold more?

We recognize that funerals are high-risk events for the transmission of COVID-19. People gather to grieve and console each other. There is touching, hugging, kissing. There are tears, runny noses, and tissues – all can be associated with respiratory droplets. Physical distancing is difficult to enforce and maintain. People are in an enclosed environment and exposed to each other for an extended time. All of these circumstances are conducive to the spread of COVID-19.

The goals for our BAO pandemic response include:

  1. Keep families and bereavement staff safe.   
  2. Protect the community by preventing funeral homes from becoming vectors of transmission.
  3. Preserve the capacity of bereavement services to handle decedents.
  4. Support the health care system by moving the dead into the care of professionals trained to deal with them.

The government expects, and we have made assurances, that the funeral sector can handle surges in death numbers. The BAO has said repeatedly that this is possible as long as all funeral homes remain operational and not infected with COVID. The fact is, that some funeral homes have contracted COVID, but not from entering hospitals or long-term care (LTC) facilities or handling bodies. They have become infected by attendees at funerals and visitations.

Based on the latest modelling data[1], although vaccinations in long term care have paid off, progress otherwise has stalled. Declines in community cases and test positivity have levelled off. Cases are increasing in most Public Health Units as we see mobility rise. Variants of concern continue to spread across Ontario. Our ability to control the rate of spread will determine whether we return to normal or face a third wave of infection. The Government of Ontario continues to strongly urge people not to gather with individuals outside of their household.

There are places of worship that can hold upwards of a thousand people. No doubt some of them have robust procedures in place to prevent the spread of COVID-19. But the BAO must provide direction for funeral licensees that takes into account every possible type of venue and place of worship in every grey/lockdown zone in the province –  even beyond Toronto and Peel – such as Sudbury, Thunder Bay and Lambton/Sarnia.

As a result of the above factors, and in consultation with the statutory Funeral Services Advisory Committee, the BAO has established the maximum of 50 attendees as being an appropriate limit to the 15 per cent of capacity restriction.

What do I tell a family that insists on having a funeral in a place of worship that can accommodate more than 50 attendees?

Communication with the family and clergy while arrangements are being made is the key to avoiding problems. Explain that you are in a regulated profession and are obligated to keep your staff and the families you serve safe from infection.

Advise them that unfortunately, you will not be able to provide full services if more than 50 people are present at the venue. You can deliver and set-up the flowers, deliver the casket and return after the service to resume your duties, but otherwise cannot participate when more than 50 people are present.

The bereavement profession has risen to the challenges and limitations caused by the pandemic for more than a year now. You have continued to provide solace and service to the families under your care under extraordinary circumstances. Thank you for continued adherence to the difficult measures in place.

-Carey Smith 
Bereavement Authority of Ontario

[1] “Update on COVID-19 Projections” Science Advisory and Modelling Consensus Tables March 11, 2021.