Key messages for UNISON health branches.
UK health authorities have updated and re-issued guidance for health and care settings to reduce the transmission of respiratory infections through winter 2021-2022. These apply to all healthcare settings across the UK.
The guidelines can be read in full here
Health and Safety Law
Under the Health and Safety at Work etc. Act 1974 and the Health and Safety at Work (Northern Ireland) Order 1978, healthcare employers are required to protect the health, safety and welfare of their employees and other people such as contractors and agency staff, who might be affected by their activity.
They must also carry out a suitable and sufficient assessment of the risk to health and safety under the Management of Health and Safety at Work Regulations 1999/ Management of Health and Safety at Work Regulations (Northern Ireland) 2000 and for exposure to biological agents under the Control of Substances Hazardous to Health Regulations 2002/ Control of Substances Hazardous to Health Regulations (Northern Ireland) 2003.
In general terms, under these regulations, employers must:
- Identify the hazard – i.e., SARs- CoV-2 and how it is transmitted. This video from the Health and Safety Executive explains aerosol, droplet and airborne transmission of SARs-Cov-2 COVID-19 Airborne and Droplet Transmission Risk: Prof. Cath Noakes – YouTube
- Decide who may be harmed and how – looking at the work environment, the activities carried out and people who may be at risk and by looking at existing measures in place to reduce the risk.
- Assess the risks and preventive measures required – using the information in step one and two to look at the level of risk and what new or additional measures need to be put in place to reduce the risk of exposure.
- Record the findings and communicate them to staff including contracted and agency staff.
- Implement and review the findings – a risk assessment is not a static document, it should be reviewed and updated where there are outbreaks, new national guidance or new variants of concern.
Infection prevention and control guidance can be used to inform what precautions, known as control measures, the employer needs to implement as part of a risk assessment. However, guidance alone is not a substitute for a risk assessment.
Employers must take steps to reduce the risk so far as is reasonably practicable. This means if the risk of harm is high the employer should spend more time and resources reducing the risk.
Health and safety legislation requires that a competent person, with a mixture of skills and experience, carries out a risk assessment. UNISON would expect health and safety advisers to be working with infection prevention and control leads, estates and facilities staff, local managers and safety reps to assess the risks and the effectiveness of control measures such as ventilation.
Hierarchy of Controls
The new ‘Infection prevention and control for seasonal respiratory infections in health and care settings (including SARS-CoV-2) for winter 2021 to 2022’ guidance refers to the hierarchy of controls, which is already part of existing health and safety regulations, and the steps employers should follow when reducing the risks of exposure.
The steps include:
- Elimination – physically remove the hazard from the work environment e.g., through screening/triaging and making sure staff who are infectious don’t attend work
- Substitution – can care or advice be delivered in different ways e.g., phone or video consultations
- Engineering controls – effective ventilation (see advice below) and screens
- Administrative controls – physical distancing, cleaning regimes, vaccination, training, and guidance for staff
- Personal Protective Equipment – such as gloves, goggles and including the use of tight-fitting face masks where the measures listed above are not enough to reduce the risk of exposure
Although it is called a hierarchy, employers should consider all measures, and how effective they are when applied together. COVID-19 controls will often need a mixture of measures, especially in health and care environments where social distancing is not possible and healthcare workers need to be close to an infected or potentially infected individual.
Ventilation
A well-ventilated workplace is essential to reduce the risk of COVID infection. Someone who has coronavirus breathes out small particles (aerosols) of the virus. Adequate ventilation reduces how much virus is in the air, so it reduces the risk of breathing in the virus. Ventilation in the workplace, including healthcare workplaces, must be assessed, and improved alongside other measures to reduce the risk of exposure to coronavirus.
As part of a COVID risk assessment, employers should carry out the following steps:
- Assess the risk of poor ventilation (in both clinical and non-clinical areas where staff work or have to enter)
- Identifying poorly ventilated areas
- Decide what steps need to be taken to improve ventilation
- Implementing those steps and monitoring
You can find out more by reading HSE Guidance on Ventilation and air conditioning during the coronavirus (COVID-19) pandemic and UNISON guidance on ventilation which includes a checklist for health and safety representatives
Vaccination
Vaccination is a control measure under the hierarchy of controls and the Approved Code of Practice to the Control of Substances Hazardous to Health Regulations 2002 states that where a risk assessment concludes there is a risk of exposure to biological agents such as Covid, for which effective vaccines are readily available, these should be offered.
The role of UNISON Health and Safety Reps
Employers must consult union health and safety representatives on measures they put in place to protect members.
There is a critical role for union reps across the UK in working with employers to ensure that
- risks are addressed effectively and meaningfully
- appropriate action is taken to support staff to work safely
- employers properly listen to the issues and concerns staff have about their circumstances
Health branches and in particular health and safety reps should be aware of the new ‘Infection prevention and control for seasonal respiratory infections in health and care settings (including SARS-CoV-2) for winter 2021 to 2022’ guidelines and the changes, which are summarised here
Key actions for UNISON Health Branches
There are several key actions for UNISON branches to take locally in response to these changes.
- Confirm employers are reviewing and updating risk assessments and associated guidance for this winter
Risk assessments must be carried out in all areas where staff work, by a competent person.
‘The risk assessment should include evaluation of the ventilation in the area, operational capacity, and prevalence of infection/new variants of concern in the local area.’
Considering the potential presence of the Omicron variant around the UK, the employers risk assessment should be reviewed regularly Government Infection Prevention and Control Guidance and additional precautions or actions taken if concerns are identified.
Ask your employer to work with your local health and safety reps to ensure the new guidance has been considered and local risk assessments and procedures updated.
- Check employers are reviewing and updating individual risk assessments
The guidance states individual risk-assessments are required for those who might be at higher risk of complications from respiratory illnesses and COVID-19.
Employers should sensitively discuss and complete a risk assessment with those in higher risk groups. This includes
- older males
- those who have a high body mass index (BMI)
- those who have health conditions such as diabetes
- pregnant women
- those who are from Black, Asian or minority ethnicity (BAME) backgrounds
- those who are medically exempt from the COVID-19 vaccine
They must ensure advice is available to all, including any specific advice for those identified as at risk. This must include all bank, locum, agency and private contracted staff the same as permanent members of staff. More information is available from NHS Employers on supporting staff with underlying health conditions and those who are in higher-risk groups.
- Support for more vulnerable groups of staff to raise concerns
It is essential that all members of staff are protected from COVID-19 and respiratory infections. This means everyone who comes into contact with patients, not only doctors and nurses.
Some groups of staff may feel less confident about raising concerns or may be less familiar with assessing their risk of contracting an infection. Those who provide intimate personal care to patients may be at the most risk.
The new guidance recognises that a ‘hierarchy of controls’ is necessary to reduce the risk of infection. This includes measures like isolation of the patient or ventilation.
With the correct application of these controls, higher grade Respiratory Protective Equipment (RPE) such as FFP masks may not always be necessary. However, the new guidance recognises that the extended use of RPE may be necessary in some cases if an unacceptable risk such as poor ventilation remains after the application of other controls.
The new guidance also recommends FFP3 masks or equivalent when caring for patients with a suspected or confirmed infection spread by the airborne route, during the infectious period. It defines Airborne transmission as
The spread of infection from one person to another by airborne particles (aerosols) containing infectious agents. Airborne particles are very small particles that may contain infectious agents.
UK Health Security Agency Information on how SARS-CoV-2 is transmitted:
SARS-CoV-2 is primarily transmitted between people through respiratory particles (droplet and aerosol) and indirect contact through fomite transmission (contact with contaminated surfaces). When someone with COVID-19 breathes, speaks, coughs or sneezes, they release droplet or aerosol particles containing SARS-CoV-2. Aerosol particles can also be released when certain procedures or support treatments are performed in health and care settings. A person can be infected when these particles are inhaled, or come into contact with the eyes, nose or mouth.
Transmission risk is highest where people are in close proximity (particularly within 2 metres) and/or in poorly ventilated indoor spaces, particularly if individuals are in the same room together for an extended period of time. UKHSA COVID-19: epidemiology, virology and clinical features – GOV.UK (www.gov.uk)
In light of the rapid spread of the Omicron variant, new interim guidance from the World Health Organisation(22 December 2022) recommends the use of masks for health workers providing care to patients with suspected or confirmed COVID-19.
WHO Recommendations:
A respirator (FFP2, FFP3, NIOSH-approved N95, or equivalent or higher-level certified respirator) or a medical mask should be worn by health workers along with other personal protective equipment (PPE) – a gown, gloves and eye protection – before entering a room where there is a patient with suspected or confirmed COVID-19.
Respirators should be worn in the following situations:
- in care settings where ventilation is known to be poor* or cannot be assessed or the ventilation system is not properly maintained
- based on health workers’ values and preferences and on their perception of what offers the highest protection possible to prevent SARS-CoV-2 infection.
Note: this recommendation applies to any setting where care is provided to patients with suspected or confirmed COVID-19, including home care, long-term care facilities and community care settings.
Ask your employer to communicate this message to all staff, so all understand that if they believe there is a significant risk to themselves, they can request further RPE. This communication should reach all staff groups and take account of those who may need additional support, such as students on placement or newly arrived nurses from overseas. Where higher grade RPE is necessary staff must be trained how to fit check RPE and be fit tested.
We have provided a template letter for staff members to use to raise concerns about the risk they are exposed to if they are uncertain of how to do so. See the resources section below.
Further information
- Further information on health and safety risk assessments and hierarchy of controls
- Further information on ventilation and COVID
- Health and Safety Executive advice Coronavirus: latest information and advice