Phase Four of Manitoba’s Reopening Plan

Manitoba entered phase four of its multi-phased reopening plan on Saturday, July 25.

The Government of Manitoba announced its finalized plan on July 23, after consultation with public health officials, members of the public and industry.

Update: The four phases of the province’s Restoring Safe Services: Manitoba’s Pandemic and Economic Roadmap for Recovery are reflected in the public health orders issued on August 24 (the “Reopening Orders”), which terminate and replace the public health orders issued on August 13. The Reopening Orders issued on August 24, apply to all areas of Manitoba, except for the areas that are located within the boundaries of the Prairie Mountain Health Region. The orders can be accessed here and here. We encourage employers, businesses and organizations to review the new Reopening Orders to ensure compliance with the sector-specific restrictions impacting their workplace. Notably, the province has not increased group sizes, eased travel restrictions or introduced other measures that it had originally deferred after public consultation in July.

The province continues to caution that if the public health indicators and results or guidelines demand it, certain measures may be further eased, restricted or re-introduced.

The following sections outline the changes implemented during phase four, effective July 25, which are in addition to the existing measures introduced in previous phases, as well as proposals that have been deferred in response to public feedback.

New Measures

Subject to the Reopening Orders, the following measures can be implemented during phase four:

Stage Performances & Movie Theatres

Stage performances may resume and movie theatres may reopen, at 30% site capacity or 500 people, whichever is lower. There is no sub-group or cohort requirement.

The site must address and implement physical distancing measures in common spaces where patrons may congregate.


Casinos may reopen at 30 per cent of the site’s capacity (including staff) so long as adequate physical distancing can be maintained between patrons.

Faith-Based Gatherings, Powwows and Other Cultural and Spiritual Indoor Gatherings

Gathering sizes for faith-based services and powwows may increase to 30 per cent site capacity or 500 people, whichever is lower, so long as adequate physical distancing can be maintained between members of the public. There is no longer a sub-group or cohort requirement.

Personal Services

Personal services businesses (e.g., therapeutic services, hair, and nail salons) that install non-permeable physical barriers between all chairs and other workstations may operate where patrons and employees on site are less than two metres apart.

The province has also eased certain restrictions on both indoor and outdoor visits of personal care and long-term care settings.

Deferred Proposals

In response to the feedback from Manitobans and guidance of public health officials, a number of proposals outlined in the phase four draft plan were deferred to an unspecified date.

Public Gatherings

The proposed changes to indoor and outdoor public gathering sizes, which included increasing gathering sizes to 75 people indoors and 250 people outdoors, were deferred. Accordingly, the phase three public health guidance continues to be in effect. This guidance provides that  public gathering sizes can total up to 50 people for indoor gatherings and 100 people for outdoor gatherings, subject to individuals maintaining separation of at least two metres except for brief exchanges. These gathering sizes continue to apply to social gatherings,  weddings, funerals and other organized gatherings or events. Organizers and attendees must follow the public health guidelines for the venue in which a gathering is being held.

Larger groups are permitted for social gatherings, weddings, funerals, and other organized gatherings or events, where distinct groups of 50 or 100 persons can be separated from other sub-groups. Sub-groups must be divided into groups of 50 or fewer people for indoor gatherings, and 100 or fewer people for outdoor gatherings. In both cases, the maximum group size cannot exceed 30 per cent of the site’s normal capacity. While some outdoor venues may have defined capacity, others may require the use of a “reasonableness” standard or 30 per cent of prior capacity at an event. Sub-groups must maintain adequate physical distancing from other sub-groups at all times and must be able to arrive, depart and participate in gatherings without co-mingling with other sub-groups.

Note that during phase four, such cohorts are not required for faith-based services, powwows, stage performances and movie theatres.

Self-Isolation Requirements

The proposed changes to travel restrictions outlined in the phase four draft plan were deferred. The province did not lift the 14-day self-isolation requirement for persons travelling into Manitoba from regions in Ontario east of Terrace Bay, Quebec and Atlantic Canada.

For more information relating to the current state of travel restrictions in the province, see our blog here.

Bars, Beverage Rooms, Brew Pubs, Microbreweries and Distilleries

The province deferred allowing counter walk-up service for bars, beverage rooms, brew pubs, microbreweries and distilleries. Accordingly, phase three public health guidance continues to be in effect.

Geographic Application – Prairie Mountain Health Region

In response to the cluster of COVID-19 cases in the Prairie Mountain Health Region, the Government of Manitoba issued the Prairie Mountain Health Region COVID-19 Prevention Order (the “Prairie Mountain Order”). This order applies strictly to the Prairie Mountain Health Region. Below are the New Measures implemented by the Prairie Mountain Order.

Public Gatherings

The Prairie Mountain Order restricts public gatherings to ten persons at any indoor or outdoor place or premises, including weddings, funerals, banquets, receptions and professional sporting activities.

Use of Face Masks

Individuals must wear a face mask that covers their mouth, nose and chin without gapping, at any outdoor public gathering of four or more persons or when entering or remaining in an indoor public place.

Face mask requirements do not apply to children under the age of five, persons with medical conditions unrelated to COVID-19, a person who is unable to put on or remove a mask without the assistance of another person, or a person who need to temporarily remove their mask while in the indoor public place for reason established in the Prairie Mountain Order.

An employee or agent of the operator of an indoor public place does not need to wear a face mask if they are in a place not accessible by members of the public, or are behind a non-permeable physical barrier.

For further information on phase three guidelines, see our “Phase Three of Manitoba’s Reopening Plan blog.

Individuals and corporations who violate emergency and public health orders may face fines of up to $50,000 or $500,000, and/or six months or up to a year in prison. Tickets can also be issued in the amount of $486 for individuals and $2,542 for businesses.

In addition, pursuant to a new public health order published on August 28 all persons who have been notified by public health officials that they have tested positive for COVID-19 or have been exposed to COVID-19 through a close contact must self-isolate for 14 days. Failure to self-isolate in accordance with the order could subject individuals to fines for non-compliance.

More details on the province’s phase four plan can be accessed here. More details respecting the province’s future phases and its multi-phased reopening plan can be found in our blog, “Manitoba’s Plan for Reopening Businesses”.

MLT Aikins will continue to monitor the situation and keep employers appraised of any further details. Employers considering the impact of the province’s plan and how it applies to their business should contact a member of our labour and employment team in Winnipeg.