We are finally starting to see how the first labour and employment cases have grappled with COVID-19 in the workplace. One such decision is Garda Security Screening Inc. v. IAM, District 140 (Shoker Grievance) ([2020] O.L.A.A. No. 162)[1], an arbitral award centred on staff working at an airport. The Shoker Grievance stems from a bulletin entitled "Know the Difference: Self -- Monitoring, Self -- Isolation, and Isolation for Covid -- 19 guidelines" (the “Health Bulletin”) which was distributed by Garda to its workers in late March 2020.