New measures implemented over the past two weeks by governments across Canada to respond to the COVID-19 outbreak continue to focus on reducing the spread of the outbreak and supporting frontline workers. Most provinces and territories are also in the early stages of re-opening certain areas of business and everyday life. This bulletin summarizes key recent legislative changes, government orders and other significant developments affecting health care providers and organizations across Canada during the past two weeks.
For additional information and insights visit the Fasken Coronavirus (COVID-19) Knowledge Centre. In addition, see our previous bulletins summarizing health sector updates across Canada in March 2020, up to April 5, 2020, up to April 12, 2020, up to April 19, 2020, up to April 26, 2020 and up to May 3, 2020.
On April 28, 2020 (posted on May 5, 2020), the Minister of Health issued two orders:
- an order (PDF) to expand the application of a previous order authorizing employees to be absent from work to comply with public health orders and preventing employers and contractors from terminating an employee or contracted services provider for such absences. In addition to covering employees and contracted service providers in auxiliary hospitals, nursing homes and supportive living accommodation, who are required to limit their work to one facility by CMOH Order 10-2020 (PDF), the new order will apply to residential addiction treatment service providers who are subject to CMOH Order 13-2020 (PDF); and
- an order recognizing that staff members affected by CMOH Order 10-2020 (PDF) may also work within the home care sector. The order provides that the Chief Medical Officer may require an individual or corporation that, under contract or sub-contract with a regional health authority, provides or arranges for home care services, to disclose information in respect of their staff members. The Chief Medical Officer may use the information to identify and develop options to address potential impacts to home care staffing.
On May 3, 2020, the Chief Medical Officer of Health issued an order (PDF) introducing Workplace Guidance for Community Health Care Settings for regulated members of colleges established under the Health Professions Act practising in the community as they begin to re-open. Each college is required to publish substantially similar guidelines, as well as any additional guidelines, which once prepared will apply to the college's members instead of the Workplace Guidance for Community Health Care Settings directly.
On May 4, 2020, the Province of Alberta announced that it had, through an April 24th order (PDF) of the Minister of Health, temporarily broadened the independent scope of practice of nurse practitioners, allowing them to act as primary care providers in nursing homes, admitting and assessing residents and offering follow-up care.
On May 4, 2020, the Minister of Health issued the following relevant orders:
- an order (PDF) amending the Communicable Diseases Regulation to allow additional health care practitioners to support medical officers of health and community health nurses under the Public Health Act - the Government of Alberta subsequently announced that chiropractors, paramedics, respiratory therapists, physiotherapists, psychiatric nurses, LPNs, pharmacists and dental hygienists will be allowed to perform contact tracing after completing training; and
- an order (PDF) to authorize Alberta Health to share whether an individual named by a police service has received a COVID-19 test in the last 14 days, and if so, what the results were.
Also on May 4, 2020, the Minister of Community and Social Services ("CSS") issued an order (PDF) extending the time limitations within various pieces of legislation to provide flexibility for CSS programs.
On May 10, 2020, the Government of Alberta announced a new online hub to coordinate community services for older Albertans and seniors.
On May 12, 2020 amendments to the Emergency Management Act received Royal Assent and came into force pursuant to Bill 13, the Emergency Management Amendment Act, 2020 (PDF). The amendments are intended to clarify the legislation, which was previously amended on March 20, 2020 to allow local and provincial states of emergency to exist at the same time. The government has also published a fact sheet (PDF) describing the amendments.
Also on May 12, 2020, the Government of Alberta announced that additional operating funding will be made available to front-line non-profit organizations (such as those supporting food security, shelter and housing, and addictions and mental health supports).
The first stage of Alberta's Relaunch Strategy began on May 14, 2020. Early steps were taken for the resumption of certain non-urgent surgeries and health services provided by a regulated member of a college under the Health Professions Act (see the May 3, 2020 order and attached Workplace Guidance for Community Health Care Settings described above). The Chief Medical Officer of Health issued an order (PDF) on May 14 to begin the strategy. A different order (PDF) is applicable to the cities of Calgary and Brooks. All workplaces must post their plan to reduce the risk of transmission among staff and customers in places of business or online within seven days of the public being able to attend the business. Services offered by allied health disciplines like acupuncture and massage therapy are not permitted during Stage 1, and visitors to health care facilities will continue to be limited (however, outdoor visits are allowed with a designated essential visitor and one other person).
From May 11-18, 2020, up to 1,000 tests per day were made available, on a first-come, first-serve basis, in the Calgary zone for individuals without symptoms who are working outside of home. On May 5, 2020 the Government of Alberta announced increased investment in testing including in the purchase of new equipment and technology.
On May 15, 2020, the Government of Alberta published a tip sheet (PDF) with suggestions on how to celebrate, support, and keep seniors safe while respecting public health measures.
Alberta Health Services has issued a number of new resources for health professionals in the month of May.
On April 29, 2020, the Minister of Health issued an order (PDF), amending the Emergency Medical Assistants Regulation and the Health Professions General Regulation. The amendments allow the Provincial Health Officer to make emergency orders authorizing an Emergency Medical Assistant ("EMA") or a registrant of a regulated health profession to perform specified activities and services that they would otherwise not be permitted to perform. An emergency order may also confer discretion to specified persons and organizations, including, among others, a regulatory college, medical officer of health, or employer, as applicable and specified in the order, to determine whether a person is competent to perform an activity or provide a service, subject to conditions.
The BC Restart Plan was announced on May 6, 2020. Starting in mid-May, additional health services are being restored, including the re-scheduling of elective surgeries, and the opening of dentistry, physiotherapy, registered massage therapy, chiropractors, physical therapy and speech therapy services.
On May 7, 2020, the Provincial Health Officer issued an order (PDF) allowing licensed practical nurses to perform COVID-19 screening swabs.
On May 7, 2020, the province released a Surgical Renewal Plan (PDF) for surgeries that were postponed due to COVID-19, setting the goal of completing surgeries lost to COVID-19 within approximately 17-24 months. The Surgical Renewal Plan sets out five steps, as well as target timelines from May - August 2020. Patient outreach, pre-operative screening and implementation planning was planned for May 7-15. In June, new staff will be recruited and specialty surgical training will be scaled up and accelerated.
On May 8, 2020, an order (PDF) of the Minister of Health brought into force amendments made to the bylaws of the College of Pharmacists of British Columbia under the Pharmacy Operations and Drug Scheduling Act. The bylaws were amended in light of COVID-19 related drug shortages to temporarily allow return to inventory injectable drugs previously dispensed for the purpose of providing Medical Assistance in Dying. Additional details have been described by the College of Pharmacists of British Columbia.
On May 12, 2020, the Lieutenant Governor in Council ordered (PDF) that the declaration of a state of emergency be extended for a further period until the end of the day on May 26, 2020.
On May 14, 2020, the Provincial Health Officer issued an order (PDF) requiring employers to post a copy of their COVID-19 Safety Plan on their website.
British Columbia has launched a COVID-19 survey, available until May 31, 2020.
Phase one of Manitoba's Restoring Safe Services Plan began on May 4, 2020, including restoring non-urgent surgery and diagnostic procedures and therapeutic and health care services. Also on May 4, 2020, the Government of Manitoba announced that almost 1,700 residents had registered for an internet-based therapy program being funded by the province.
On May 5, 2020, the Minister of Health, Seniors and Active Living approved new orders (PDF) made by the Chief Public Health Officer on the same day under the Public Health Act. The orders allow additional businesses to open, subject to restrictions, as part of the province's re-opening plan. Health care professionals may practise their profession without restriction and when doing so may employ such staff as may be required to provide professional services to patients. Additionally, various health care businesses are listed among the businesses that may open.
On May 8, 2020, the Government of Manitoba announced that effective May 11, 2020, the one-month limit on prescription refills will be lifted for medication not affected by shortages. On the same day, the Central Services Minister announced the province will be purchasing up to one million made-in-Manitoba reusable N-95 masks.
On May 13, 2020, the Government of Manitoba issued an order (PDF) extending the Declaration of State of Emergency for a further period of 30 days, commencing on May 17, 2020.
On May 4, 2020, the Government of New Brunswick published (PDF) an updated guidance document for long-term care facilities.
On May 8, 2020, the government announced that it has transitioned to the next phase of its recovery plan: Phase 2 (Orange level). Phase 2 includes the resumption of elective surgeries and the reopening of certain businesses and activities while working to prevent a resurgence of transmission.
On May 11, 2020, the Chief Medical Officer of Health announced new rules for visiting patients nearing the end of their lives in hospitals, nursing homes and hospices. Under the new rules, patients are permitted to designate two visitors to provide comfort and support. The two individuals will be the only visitors permitted and only one visitor is permitted at a time, with no substitutions. If a designated visitor, such as an elderly spouse or person with a disability, requires a second person to support them, this person would count as the second chosen visitor.
Effective May 14, 2020, the declaration of emergency (PDF) under the Emergency Measures Act was extended for an additional 14 days.
Newfoundland and Labrador
The Government of Newfoundland and Labrador has issued an order (PDF), effective May 17, 2020, extending the province's public health emergency for a further period of 14 days.
On May 6, 2020, the government assented to the Act to Amend the Pharmacy Act, 2012. Pursuant to the Act, where the Newfoundland and Labrador Pharmacy Board determines that there is an immediate need for pharmacist or pharmacy technician services due to an actual or potential threat to public safety, health or welfare, or where the minister appointed to administer the Pharmacy Act, 2012 or the federal Minister of Health makes a request, the Board may issue an emergency registration. The Act details the conditions that must be met for a person to be issued an emergency registration. In brief, the person must:
- be licensed or registered to practice as a pharmacist or pharmacy technician in another jurisdiction in Canada, have graduated from an educational program accredited by the Canadian Council for the Accreditation of Pharmacy Programs within the past 12 months, or have been previously registered to practice in the province;
- provide proof that their licence or registration has not been revoked, suspended or restricted;
- provide proof of identification as required by the Board; and
- satisfy any other requirements as the Board may determine are necessary and practicable in the circumstances.
The Government of Newfoundland and Labrador has implemented an "Alert Level System" that provides an overview of the steps that will be taken as public health measures are relaxed. On May 10, 2020, the province announced that is has proceeded from Alert Level 5 to Alert Level 4, which permits the gradual resumption of some activities and business operations, while maintaining certain public health measures.
The four regional health authorities in Newfoundland and Labrador will begin allowing some services to resume during Alert Level 4. Private health care clinics remain closed, except for urgent and emergent care. Virtual care options continue to be available for non-urgent care. Visitor restrictions for health care facilities remain in place. Public health orders related to long-term care homes, personal care homes, and assisted living facilities also remain in effect during Alert Level 4.
At Level 3, private health care clinics will reopen in accordance with guidelines. At Level 2, regional health authorities will continue to allow additional health care services to resume. However, visitor restrictions in health care facilities and orders for long term care, personal care homes, and assisted living facilities remain in place. Level 1 will be the "new normal" and lifting long-term public health measures will depend on future evaluation of the transmission patterns.
On May 12, 2020, the Government of the Northwest Territories announced the extension of the territory-wide Public Health Emergency and State of Emergency. Both extensions took effect as of May 13, 2020 and expire on May 26, 2020.
The Government of the Northwest Territories issued a public health order (PDF), effective May 15, 2020, authorizing the easing up of public health restrictions. Pursuant to the order, certain organizations will be allowed to open, including massage therapy clinics and chiropractors.
On May 7, 2020, the Government of Nova Scotia announced a new program to give health-care workers a bonus of up to $2,000. The Essential Health Care Workers Program will provide a top-up for front-line health care workers who did not initially qualify for the federal government's program. The program is available for eligible employees at the Nova Scotia Health Authority, IWK Health Centre and in long-term care, home care and in-home support and emergency health services. Employees who volunteered to be redeployed to work at a facility experiencing a COVID-19 outbreak will also receive the benefit.
On May 17, 2020, the government issued an order (PDF) renewing the provincial state of emergency until May 31, 2020.
The Minister of Health of Nunavut issued an order (PDF), effective May 13, 2020, extending the state of public health emergency until the end of May 28, 2020.
As an update to the prior news release issued by the government of Nunavut, and described in our last bulletin, the government announced that the test result showing a presumptive case of COVID-19 in Nunavut's Pond Inlet community was confirmed to be a false positive result after further testing. As a result, the government again reports zero confirmed or probable cases of COVID-19.
On May 4, 2020, the Province of Ontario announced that it had significantly increased its testing and contact tracing capacity. Testing is being carried out in hospitals, long-term care homes, group homes, shelters, emergency child care centres and other congregate settings.
On May 5, 2020, the Government of Ontario issued an order (O. Reg. 199/20) pursuant to the Emergency Management and Civil Protection Act ("EMCPA"), amending O. Reg 106/20. The order extended the previously made orders and extended the revocation date to May 19, 2020. Further, On May 12, 2020, the province announced that it is extending the Declaration of Emergency under the EMCPA to June 2, 2020.
In addition, on May 5, 2020, the Ministry of Health provided details about temporary payment mechanisms to facilitate hospital and physician payments for medically necessary services for those not currently insured under OHIP or another provincial plan. Physicians who perform services for uninsured patients in a hospital setting will be remunerated by the hospital at existing rates listed in the Schedule of Benefits for Physician Services. Hospitals can now submit claims for these services to OHIP. For services performed outside the hospital setting, the Ministry of Health has introduced temporary fee codes for the provision of medically necessary physician services provided to uninsured patients in the community. These codes are for services rendered on or after March 21, 2020.
Also on May 5, 2020, the province announced that it is expanding access to virtual mental health services. The programs are in partnership with MindBeacon and Morneau Shepell, and will provide Internet-based Cognitive Behavioural Therapy at no cost. Frontline healthcare workers requiring intensive levels of care can also receive virtual face-to-face care, access to online peer discussion groups and access to confidential support.
On May 7, 2020, the province released a comprehensive framework to assist hospitals in their readiness to gradually resume scheduled surgeries and procedures. The framework, A Measured Approach to Planning for Surgeries and Procedures During the COVID-19 Pandemic (PDF), provides criteria that must be met before scheduled surgeries can resume, including:
- a stable number of COVID-19 cases;
- a stable supply of personal protective equipment;
- a stable supply of medications;
- an adequate capacity of inpatient and intensive care unit beds;
- an adequate capacity of health human resources; and
- availability of post-acute care outside the hospital to support patients after discharge.
The framework also assists hospitals in prioritizing surgeries by looking at factors such as: (i) a patient's condition; (ii) the type of procedure and non-operative alternatives; (iii) risks of delaying the surgery; and (iv) the resources required.
On May 12, 2020, the province issued an order (O. Reg. 210/20) under the EMCPA, pursuant to which a Director appointed under the Long-Term Care Homes Act, 2007 is authorized to issue a mandatory management order for long-term care homes with at least one positive COVID-19 test among its residents or staff. The Director's order may specify the name of the person who will temporarily manage or assist in managing the long-term care home. According to the government news release dated May 13, 2020, the interim manager could be any person, including a corporation or a hospital. According to the same news release, a long-term care home may require management assistance if it faces challenges such as a high number of cases among residents or staff, a high number of deaths, an outbreak that has not yet been resolved, significant staffing issues or outstanding requirements from infection prevention and control assessments. Decisions regarding when and where to assign additional support will be made on a case-by-case basis.
Additionally, the government introduced two regulations under the Ontario Drug Benefit Act ("ODBA"):
- Trillium Drug Program (TDP) households must incur an out-of-pocket deductible of approximately 4% of their annual income before they become eligible for public drug coverage through the Ontario Drug Benefit Program. To help reduce the cost impact to TDP households as a result of loss of income, the first regulation under the ODBA, O. Reg. 211/20, filed on May 13, 2020, amends O. Reg. 201/96 to extend the in-year deductible reassessment to include significant income changes that occur in the latter half of the TDP benefit year. This would allow households to use their 2020 income information for the determination of their deductible in the current 2019/20 benefit year.
- The second regulation, O. Reg. 212/20, filed on May 13, 2020, amends O. Reg. 201/96 and supports the Ministry of Health's recommendation that no more than a 30-day supply of medication be dispensed even though a greater supply may be prescribed and payable under the Ontario Drug Benefit (ODB) Program, to protect the drug supply chain and prevent drug shortages. O. Reg. 212/20 ensures that individuals are only paying one co-payment for a 30+ day-supply being dispensed in instalments by reducing the co-payment to $0 for the second and, if applicable, third dispensing event.
On May 14, 2020, the government announced the businesses and services permitted to expand their services beginning on May 19, 2020. Among the services allowed to resume are in-person counselling; in-person services delivered by health professionals; and scheduled surgeries, all based on the ability to meet pre-specified conditions as outlined in the framework, A Measured Approach to Planning for Surgeries and Procedures During the COVID-19 Pandemic (PDF), described above.
On May 19, 2020, the government announced the launch of an independent commission into Ontario's long-term care system, beginning in September 2020, in response to the impact of COVID-19 in the province's long-term care homes. Over the next several months, the government will be finalizing the details of the commission, including with respect to terms of reference, membership, leadership of the commission and reporting timelines. This announcement will be discussed in further detail in a future bulletin.
On May 5, 2020, the Premier of Quebec announced that residents in private seniors' residences without confirmed cases of COVID-19 can take unaccompanied walks and have outdoor gatherings with family, with physical distancing. Additionally, the prohibition on visits to the palliative care units in residential and long-term care homes, private seniors' residences, and intermediate and family-type resources has been lifted.
On May 6, 2020, the Government of Quebec issued an order (PDF) renewing the public health emergency until May 13, 2020 and on May 13, 2020, an order (PDF) renewing the public health emergency until May 20, 2020. Other orders were extended for the same periods.
Also on May 6, 2020, the Commission on Standards, Fairness, Health and Safety at Work announced (French only) the launch of a mobile application to support employers and workers in the compliance with public health guidelines.
On May 9, 2020, the Minister of Health and Social Services issued an order (PDF) that allows additional health professionals to take samples for COVID-19 screening, including, among others, audiologists, dentists and physiotherapists.
On May 10, 2020, the Minister of Health and Social Services issued an order (PDF) providing bonuses to reward and encourage full time work in residential and long-term care homes and other designated facilities.
Starting May 11, 2020, the Government of Quebec has announced that subject to certain restrictions and requirements, informal caregivers who were present on a regular basis before the pandemic can again offer support to a person in an intermediate and family-type resource, or a private seniors' residences (this was already in place in residential and long-term care centres). This is reflected in the May 9th order (PDF), noted above, which also restricts repair work and deliveries to private seniors' homes.
On May 12, 2020, the Government of Quebec announced (French only) additional funding for scientific and research projects related to the pandemic.
On May 13, 2020, the Minister of Health and Social Services announced (in French only) measures granting additional powers for specialized nurse practitioners, including allowing specialized nurse practitioners to complete the formalities necessary for various preventive withdrawals from workplaces. The intention of the amendments is to increase the capacity of physicians.
On May 14, 2020, the Minister of Health and Social Services issued an order (PDF):
- extending the duration of the privileges granted to a physician or a dentist to a period equivalent to that of the public health emergency;
- authorizing respiratory therapists to perform COVID-19 screening test, without a prescription; and
- providing that a midwife who considers that the working conditions of a pregnant or breastfeeding worker involve occupational health and safety risks be authorized to complete the formalities relating to the protective reassignment under the Act respecting occupational health and safety, and that a midwife be authorized to fulfill the obligations and complete the formalities entrusted to a physician or specialized nurse practitioner under the Regulation respecting the preventive withdrawal of certain home childcare providers.
On May 15, 2020, the Minister of Health and Social Services announced a plan for the reopening of medically-assisted procreation services. The plan starts on May 18, 2020 by allowing diagnostic tests. Also on May 15, 2020, the Minister of Health and Social Services issued an order (PDF) respecting the work conditions and salaries of certain service providers, including nurses and nursing assistants. The order restricts a service provider who has provided services to persons suspected of having COVID-19, waiting for a COVID-19 test result or who have received a positive test result from working in a setting in the health and social services sector where no patient or resident is suspected of having COVID-19, is waiting for a COVID-19 test result or has received a positive test result. Service providers are required by the order to provide information about where they have worked to the bodies they are scheduled to work with. The order also fixes rates of pay for prescribed service providers and places restrictions on hiring certain service providers.
On May 16, 2020, the Ministry of Health and Social Services announced (French only) an initiative through which front line workers can send confidential emails to the government about what they are experiencing.
Saskatchewan's re-opening plan began on May 4, 2020, with the first phase including various health service providers such as dentists, optometrists and chiropractors. On May 3, 2020, the Chief Medical Health Officer issued an order (PDF) to align with the re-opening plan, including allowing access to previously restricted medical services. The Chief Medical Officer of Health also restated an order requiring that each staff member in a special-care and personal care home work in only one facility and requirements for health screenings and other protective measures in special-care, personal care and affiliate care homes and certain agencies operated by the Saskatchewan Cancer Agency. The order also imposed a requirement for temperature checks, effective May 15, 2020, in personal care homes.
Phase 2 of the re-opening plan (including registered massage therapists and acupuncturists) began on May 19, 2020.
Announced on May 5, 2020 and beginning on May 19, 2020, the Saskatchewan Health Authority initiated a phased resumption of health care services (PDF). Phase 1 includes an expansion of surgeries, increased diagnostic imaging, routine immunizations and increased public health inspections in long-term care homes, among other measures.
On May 6, 2020, the Chief Medical Health Officer issued an order (PDF) updating the previously ordered travel restrictions for Northern Saskatchewan, with exceptions for the delivery and receipt of certain medical services and treatment.
On May 13, 2020, the Government of Saskatchewan announced that the Provincial State of Emergency has been extended for a further period of two weeks.
On May 14, 2020, the Government of Saskatchewan provided an update about testing, including that COVID-19 testing will soon be available to any Saskatchewan resident working outside the home, and that certain at-risk populations, including patients admitted to acute care hospitals for a stay longer than 24 hours and health staff working with immunocompromised patients, will be proactively tested.
On May 15, 2020, the Government of Saskatchewan announced that the application process for a temporary wage supplement has opened for eligible workers at essential care facilities including senior care homes and working in home-care for seniors.
The Government of Saskatchewan is now posting information about outbreaks within certain health facilities, including hospitals and long-term care homes. It has also developed a new webpage with detailed data on cases and testing, and has a number of new resources and information documents for health care providers, including with respect to testing and laboratories.
On May 14, 2020, the Government of Yukon announced temporary changes for pharmacists during the COVID-19 pandemic. These include changes to the pharmacists' standards of practice and the Pharmacists Regulation to ensure Yukoners can continue to safely access needed prescriptions. The new rules include:
- changes to how pharmacists can extend and initiate prescriptions;
- changes to support Health Canada's temporary exemption to the Controlled Drugs and Substances Act; and
- changes to some licensing requirements.
Pharmacists will use their professional discretion in deciding when to use the new options available to them, guided by the need to ensure both public and patient safety.
The government has released A path forward: Yukon's plan for lifting COVID-19 restrictions, which presents a gradual and phased approach to lifting COVID-19 restrictions, with a focus on protecting communities and vulnerable residents, and on preventing the re-introduction and spread of COVID-19 in Yukon. Phase I commenced on May 15, 2020, following the easing of certain restrictions already announced during the previous "response phase" of the plan.
On May 3, 2020, the Canadian government announced that $240.5 million would be invested in virtual care and mental health tools to support Canadians. The Canadian government will work with provinces and territories to, among other things, create digital platforms and applications.
On May 6, 2020, the Department of Finance announced tariff relief to certain importers of medical goods, including personal protective equipment. Also on May 6, 2020, the Competition Bureau announced measures to address deceptive marketing claims about COVID-19 prevention or treatment.
On May 7, 2020, the Canadian Government announced that all provinces and territories have confirmed, or are in the process of confirming, plans to cost share wage top-ups for their essential workers.
On May 12, 2020, Health Canada announced that it had authorized the first COVID-19 serological test for use in Canada, to detect antibodies specific to COVID-19.
On May 12, 2020, the Canadian government announced measures to help seniors.
On May 15, 2020, the Canadian government announced $450 million in funding for academic research, to provide wage supports to universities and health research institutes and to maintain essential research-related activities.
 This bulletin addresses updates published up to 5:00 pm (EST) on May 17, 2020, with the exception of select significant updates published after that time.
 Certain sections of those orders were subsequently amended with respect to non-health services. More details is available at https://www.alberta.ca/covid-19-orders-and-legislation.aspx.
 Lifting of restrictions does not apply to the communities of Lloydminster and La Loche.
 With exceptions for dieticians, medical laboratory technologists, medical laboratory assistants, nurse practitioners, home care workers, public health nurses, public health officers (inspectors), paramedics, pharmacists, physicians, resident physicians, speech language pathologists, staff who provide podiatry type care, inter-facility transport staff, delivery persons, trades people, regular and biochemical waste removal people, biomedical engineers, visitors or any other person exempted by the medical health officer.
 Thank you to articling students Anna Lu, Fatima Husnain, Jessica Nolan, Marissa Di Lorenzo, Rachel Kardal and Rob Legge for their research assistance.