Today, the NHL have released their Phase 2 protocol memo. This is an extensive document that outlines the rules and procedures for small groups of players to workout and practice. The target date for this phase to begin is “early June”.

The next two phases of this Return to Play structure are training camp and then the actual games, so this phase covers only pre-training-camp workouts similar to the “no coaches allowed” practice sessions many teams put on before the official start of training camp in September.

There has been no decision made on when Phase 2 will start or how long it will last. The memo is a set of guidelines, but also a request for teams to report back on their ability to implement them.

Travel and Local Regulations

Participation in Phase 2 is voluntary, and teams will not be requiring players to return to the home city. This neatly sidesteps the current Canadian rules the would require a 14-day isolation for any international arrivals.

The Government of Canada has put in place an emergency order under the Quarantine Act. It applies to all travellers arriving in Canada. Its purpose is to slow the spread of COVID-19 in Canada. Failure to comply with this order is an offence under the Quarantine Act.

If you have recently arrived in Canada, Government of Canada officials will call you to monitor compliance with your mandatory quarantine.

Toronto is home, or temporary home right now, to many NHL players for other teams, and many Maple Leafs players are in other cities. We sometimes see players from other teams working out in the September pre-camp sessions, and we will likely see even more of that during Phase 2. Players will be allowed to use the NHL facilities where they are living, subject to scheduling and staff availability.

However, everything the NHL is planning to do is subject to local rules, and teams are required to consult with local authorities.

This activity will be permitted only in those jurisdictions where the applicable health authorities have sufficiently relaxed local restrictions to permit such gatherings. Clubs whose local health authorities would allow for the reopening of Club facilities will be required to consult with and seek approval from the League prior to any reopening of Club facilities. In those jurisdictions which continue to restrict or prohibit such activity from occurring, and in order to address potential competitive concerns, the League will work with those Clubs to facilitate alternative arrangements, if desired.

Teams are required to provide hotel rooms to players who don’t live in the local city, and to provide some transportation.

There is a provision to allow for players to return via commercial flights that does impose a 14-day isolation. So even in jurisdictions without Canada’s current rules, some players may need to do that isolation period before they can participate.

Even if not imposed by the local health authorities, such individuals returning to the Club’s home city by public transportation, including commercial air or rail travel, must serve a 14-day self-quarantine period post-travel before engaging in training activities at their Club’s facility. In addition, Club Medical personnel may impose a 14-day quarantine on Players and Permitted Personnel returning to the Club’s home city from a high-risk environment, even if they are not travelling via public transportation.

Players aren’t allowed to carpool to return to the home city or once they get there to travel to the facilities together.

Testing Protocol

The memo contains a detailed testing protocol that has two phases. One that comes before players are allowed to participate in training at the team facilities, and one that carries on once they are there.

Initial Testing and Medical Evaluation

As an over-riding principle, testing of asymptomatic Players and Club personnel must be done in the context of excess testing capacity, so as to not deprive health care workers, vulnerable populations and symptomatic individuals from necessary diagnostic tests (“Publicly Necessary Testing”). Secondly, testing by its nature is for the early detection of infection and is not a replacement for the hygiene, distancing, and cleaning and disinfecting methods outlined in this framework that can help prevent infection in the first instance.

Laboratory-based RT-PCR testing shall be administered to all Players and Club personnel designated to have “Player Access” (see Paragraph I (2) below) forty-eight (48) hours prior to any person returning to Club training facilities in order to detect active or recent infection (with results to be available within twenty-four (24) hours). For individuals whose results are not received within twenty-four (24) hours, such persons shall not utilize Club training facilities until results are available and indicate a negative testing result.

These initial tests must be conducted in accordance with local rules about the testing of asymptomatic people. The memo notes that the NHL is exploring the feasibility of offering league-wide testing themselves, but that isn’t the case now. Tests will be done by whatever process is in place locally.

If testing is not available at the start of Phase 2, Players who wish to participate in Phase 2 activities and “Player Access” Club personnel must self-quarantine for 14 days prior to entering the facility (or, certify that they have already served a self-quarantine for the prior 14 days in the Club’s home market, in which event they will be eligible to enter the facility when Phase 2 begins).

Ongoing Testing

Once players have been cleared by a medical evaluation and have either self-isolated or had a negative test for COVID-19, there is a process of ongoing symptom checking, evaluation and testing.

There will be further tests conducted in areas where that is allowed:

If such testing is available, Clubs shall make arrangements for, and shall administer, PCR testing to all Players and Club personnel with “Player Access” prior to the resumption of Phase 2 training activities, and if possible, on an ongoing basis (at least twice weekly and consistent with medically recommended intervals) throughout Phase 2.

There will be temperature and symptom checks done as self-assessments by the player on their own:

Each Club shall establish a process to record symptoms and conduct temperature checks on a daily basis, and not more than two (2) hours prior to each Player’s and Club personnel with “Player Access’s” entry to the Club facility. These checks shall be self-administered at the homes of Player and Club personnel with “Player Access” prior to their departure for the Club’s facility. A standardized self-screening checklist set out in a “app” (programmed to maintain information security) for use by Players and “Player Access” Club personnel will be provided prior to the commencement of Phase 2. Clubs shall obtain any necessary equipment, including digital oral thermometers, for use by Players and such Club personnel. See Paragraph G (Symptomatic Persons During Phase 2), below, which sets forth processes if Players and/or “Player Access” Club personnel develop symptoms, report a temperature >99.5°F or > 37.5°C, or are otherwise directed by the standardized self-screening checklist to follow the symptom-reporting procedure.

Teams will also be conducting checks before players and the staff who interact with them are allowed in the building each day:

Additionally, each Club must administer a separate temperature and symptom check at the entrance of the Club facility before any Player or Club personnel with “Player Access” shall be allowed to enter. Temperature checks shall be done by the Club Facility Hygiene Officer (see Section O) or a comparably qualified individual using a non-contact infrared thermometer. Any abnormal result using the non-contact infrared thermometer should be followed up with a confirmatory check using a tympanic membrane or hospital-grade oral thermometer. The Club’s Facility Hygiene Officer (see Paragraph O, below) shall oversee implementation of this procedure, and the guidance of the Club’s local infectious disease expert shall also be sought in connection with such implementation. The Clubs shall take appropriate measures to protect the privacy of the information collected and to maintain the security of the information collected. The information collected shall not be entered into the Player’s AHMS records and shall be kept separately

Note: the RT-PCR test is the nasal swab test that is processed in a laboratory.

Positive Tests

Some players may become ill, test positive, or show symptoms that might be from COVID-19 during this training phase.

During Phase 2, anyone who develops symptoms (or if persons sharing a home develop symptoms or tests positive for COVID-19) shall immediately notify Club medical staff of such, shall self-isolate, and shall be medically evaluated by the Club’s physician(s), who shall consult with the Club’s infectious disease specialist to determine next steps, and administer PCR testing, if appropriate. In the event a Player is diagnosed positive for COVID-19 (or has a resulting and/or related illness), the Club Physician shall issue an Exhibit 25-A designating the Player as “unfit to play”, the Player shall be deemed to have sustained an illness arising out of the course of his employment as a hockey player for such period as he may be removed from training, practice or play, and his condition shall be treated as a hockey related injury for all purposes under the Collective Bargaining Agreement, unless it is established, based on the facts at issue, that the Player contracted COVID19 or the resulting or related illness outside the course of his employment as a hockey player.

The NHL is setting a standard for contact tracing regardless of local rules, so they are requiring more than many jurisdictions currently insist upon or are capable of providing.

Contact tracing shall be conducted by the Club immediately upon a positive test result, and shall be in conjunction with, and pursuant to, regulations from local health authorities to identify other people who have been in contact with the person who tests positive. Clubs should proceed with contact tracing even if the response of local health authorities is delayed. If there are no such applicable local regulations, the Club infectious disease expert shall develop a process for contact tracing.

In the Phase 2 environment of strict monitoring, testing (if applicable), regular cleaning and disinfecting, and adherence to the measures in this protocol, subject to any applicable local health regulations, it is not anticipated that an isolated case(s) of COVID-19 would necessitate widescale quarantine of a Club; however, testing of Players in the same Player’s training session and “Player Access” Club personnel may be appropriate, as determined by Club medical staff in consultation with the Club’s infectious disease consultant and local health authorities.

Bold text added for emphasis by me. See below for further explanation on some of these terms.

Permitted Activities

The actual training itself will be limited to player-only non-contact skating. No coaches or other staff are allowed on the ice, and only six players may skate or workout together at a time. Workouts can include weight training that does not require a spotter, and other exercises that can be done with physical distancing.

Coaches and staff can observe, but can’t participate in on-ice sessions, and teams are not allowed to do fitness testing.

Protection of Staff and Players

In order to protect everyone involved, the Phase 2 protocol requires each team to appoint a Club Facility Hygiene Officer. That person is responsible for overseeing the implementation of the protocol, and one of their jobs is to provide colour-coded identifying badges for staff.  The staff on-site is to be split into two groups, those who have player access and those who don’t. The player-access staff, as noted in some of the rules quoted above, go through the same initial testing as the players do.

Teams are required to operate with a minimum level of staff, and no media, agents, family or several classes of support staff are allowed on the site.

Medical evaluation is allowed via remote “telehealth” methods with some limited exceptions, and no dental exams will take place.

Staff at all levels are required to maintain physical distancing and to avoid close contact with players. Medical staff and athletic trainers are required to wear PPE (masks and gloves) while in close contact with players, and other staff like equipment managers are to make an effort to avoid the players entirely.

Players are required to wear masks when not on the ice or working out.

There is a comprehensive set of rules about use of water bottles, food and supplement distribution and personal hygiene or medical products. No sharing the Tiger Balm, in other words.

Players are not allowed to socialize outside the team facilities, and aren’t allowed to use any other outside facility to skate or workout. Players are being encouraged to shower at home, and use of facilities has to be dependant on the ability to maintain physical distance. Players will remain in their maximum six-man groups throughout the entire Phase 2 session to produce mini-bubbles within the group to help contain any actual infection that might occur.

On the staff side, there are rules and procedures for everything from cleaning to special medical considerations for people with higher risk factors associated with COVID-19.

Not included in the memo is any process recognizing the right of refusal to work by staff or players.

Taxi Squad Players

With the AHL season and playoffs now cancelled, teams are assembling so-called taxi squads of players who finished the season in the AHL and will be available as recalls when play resumes. No formal official rules have been announced on how this will work or how large a roster a team will be allowed to have.

Presumably these players will be permitted to voluntarily attend training sessions in Phase 2. The Maple Leafs have reportedly told the Marlies players they want to use for this purpose to be available when called.

Phase 2 in Toronto

Given the size of the Leafs training facility in Toronto, with multiple ice pads and other facilities, they are well situated to not merely meet the guidelines in this memo, but to exceed them. We should expect MLSE to exceed them wherever they can, and to ensure that the local health authorities aren’t taxed with serving their activities when they have other work to do. We should hold them to account if they don’t meet our expectations. They should also be able to accommodate players for other teams fairly easily.

This memo does not detail the NHL’s ability to monitor players who are outside of North America, and since return is voluntary, some players may choose to stay where they are until Phase 3 (training camp) is on the horizon and the voluntary becomes mandatory.

This seems like a lot of planning and infrastructure work to get ready within a few weeks. We’ll see if early June is a feasible date or not as teams try to implement this protocol.