Public Health Orders-Clarifications

June 29, 2021 11:08 | Shane Ray (Administrator)

Current Public Health Orders

Clarification regarding day camps

  • Effective June 26, 2021, day camps for children of all ages may open. The maximum number of children per group is 20. Joint activities between groups are not permitted and campers are required to bring their own food and beverage or all food and beverages served at the camp are individually packaged. Overnight camps are not permitted. For additional guidance on public health measures, operators should reference the Early Learning and Childcare Practice Guidance found at Province of Manitoba | fs - COVID-19 Notices and Circulars ( Mask use is required for staff and campers when in indoor public spaces, as per the public health orders. Personal protective equipment as outlined on pages 15 – 18 of the practice guide is not required, but is encouraged for staff if possible. The guidance on documentation beginning on page 18 of the guide does not apply to day camps and is only for Early Learning and Childcare programs.  


Clarification from Sport Manitoba about sport related activities


  • Outdoor organized sports and recreation activities may reopen for groups up to 25 people, with no tournaments allowed. The group of 25 participants DOES NOT include coaches or officials. So, an outdoor sport activity can include 25 athletes, plus coaches and officials. In addition to the group of 25 participants, you are allowed up to 25 spectators, physically distanced by at least 2 metres, as per the outdoor gathering size limit for public spaces.
  • Indoor organized sport and recreation activities may reopen to groups of no more than 5 athletes plus coaches/instructors. The five-athlete plus coach/instructor groups cannot intermingle. No tournaments are allowed. Dressing rooms are limited to 50% of the usual capacity or to a number that ensures that all persons in the dressing room are able to maintain a separation of at least two metres from other persons, whichever is lesser. Masks are required at all times for indoor settings.


Clarification regarding swimming pools and swimming lessons

  • Outdoor & indoor public pools are allowed to open at 25% capacity. Is this 25% of their normal bather load as listed on their permits or something else? 

For outdoor pools:

Spectators are permitted at an outdoor sporting facility. Spectators are not to be included when calculating the number of participants in a sporting activity. Spectators must maintain a separation of at least two metres from other spectators.

The operator of an outdoor swimming pool must (a) limit the number of members of the public in the pool to 25% of the usual capacity of the pool; and implement measures to ensure that members of the public in the pool are reasonably able to maintain a separation of  at least two metres from other members of the public.

For indoor pools:

The operator of an indoor swimming pool must limit the number of members of the public in the pool to 25% of the usual capacity of the pool; and implement measures to ensure that members of the public in the pool are reasonably able to maintain a separation of at least two metres from other members of the public at the pool.

For pool bather load:

Operators must ensure 4m2/per person of pool surface area is provided.   Generally your bather load for a swimming pool is 1.5m2/per person and for an outdoor whirlpool it is 1 m2/per person so you can do a simple cross multiplication from the bather load listed on the permit to get your COVID 19 compliance bather load.  

If a pool has an assigned bather load of 200, the bather load is calculated by

Surface Area (SA)/1.5 persons per square meter (per Sec 14(1) of the Regulation)

Therefore to determine the SA, take the assigned bather load on the permit and multiply by 1.5. 300 m

                        i.e. 200 X 1.5 = 300 m2 

Therefore the bather load for this pool under the current PHO would be 300/4 m2 per person = 75 persons.


  • Can outdoor or indoor semi-public pools (aka hotel pools allowing other person besides their guests to have access) open, and if so are the limits the same as for public pools.


Yes the public health orders apply to all indoor and outdoor public and semi-public permitted pools.

All hotels that allow for users groups must adhere to the section of the regulation regarding user groups as well this take up capacity.

Pool Regulations- section 28 - Where the operator of a semi-public swimming pool other than a whirlpool allows access to the pool by the public or the pool is rented to a user group, the operator shall ensure that lifeguards and safety equipment are provided in accordance with section 23.

  • Can outdoor and or indoor public pools offer public swimming lessons (e.g. preschool, parent & tot, learn to swim, aquacise, ….) if so is the total class size including instructor 5 or 10 persons.

Indoor swimming…25% is the indoor capacity of the pool. If there is a swim lesson you can have an instructor plus 5 people in your group.   You can have several groups to total the 25% capacity of the pool

If the outdoor lesson is in the pool then 25% the usual capacity of the pool.  

So if you are doing water polo, aquafit class you are likely to have a normal class size or 2 teams as long as you are within the 25% bather load and don’t go over 25 in that group.

  • Outdoor private pools (backyard pools) – can swimming lessons occur as long as there are no more than 10 persons in total including the instructor in the class and/or the total number of persons at the site, and they meet Section 28 of the Swimming Pools and Other Water Recreational facilities Regulation (MR 132/97).

Private pools offering classes to the public have to register, obtain a valid Health Permit and meet all sections of the provincial pool regulations because now they are not private but rather semi-private pools.  A pool used for lessons would have to be permitted by our department. However if someone has their own children and an instructor is on site at their own pool, that is not the same, the public is not attending for lessons, and that is private use and private lessons at their own home.

  • If it is 10 for a private pool and if it is 5 for a public pool, why? Is it overall risk of potential larger gathering sizes at a public or semi public pool?  (I will get the question if there is a difference)

The outdoor gathering size at a residence is 10. Persons may gather on the outdoor

portions of the property on which their private residence is located with no more than 10 other persons who do not reside at their residence.

  • If the backyard pool owned by the person is used as part of their business for running public swimming lessons, are they limited to 5 or 10 people in total (assuming that they meet Section 28 of the Swimming Pools and Other Water Recreational facilities Regulation)?

Private pools used by the public for swimming lessons are not allowed unless they meet all requirements of the regulations and hold a valid Health Permit issued by a Public Health Inspector.

  • Can public swimming lessons at a lake? If so, is the class size 5 or 10 persons including the instructor?

Yes can occur and groups are kept separate. Persons may engage in any type of outdoor sporting or recreational activity but they must not engage in an activity as part of a group of more than 25 persons.

  • There are no changes to the conditions for training aquatic staff from the previous health orders – right?

Yes correct under 2(4) This Order does not apply to any gathering where persons receive training respecting first aid, emergency response measures or workplace safety and health protocols.

  • Lifeguards on deck and swimmers in the water do not have to wear a mask. However, Instructors on deck must wear a mask – right? Can an instructor who needs to enter shallow  water, but will not be swimming, wear a clear face shield instead of a mask both on the deck and in the water? If they are splashed, they may then be trying to breath through a wet mask.

No mask requirement for a person who is swimming or acting as a lifeguard;  They don’t include instructors.  However if the instructor is in the water then they would be considered a swimmer and therefore would not require one in the water.  However an instructor in the water is also taking up bather capacity.



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