UK Guidance regarding use of PPE during COVID-19 pandemic, and advice for employers
The availability of Personal Protective Equipment (PPE) is a much discussed topic worldwide, and a big issue for many, given its shortage in most countries. In the United Kingdom, the lack of PPE is a problem that is very prevalent at the moment, posing a big challenge to the NHS (National Health Service), as the provision of adequate personal protective equipment to health and social care workers is of great importance in order to control and contain the prevailing COVID-19 pandemic.
On the 17th of April, 2020, the guidance provided by Public Health England (an executive agency of the Department of Health and Social Care in the United Kingdom) regarding COVID-19 personal protective equipment (PPE) has been updated. As the UK government has announced, the United Kingdom is currently experiencing sustained transmission. Thus, the governmental guidance has been updated to reflect pandemic evolution and the changing level of risk of healthcare exposure to SARS-CoV-2 in the UK.
It is stated that the revised guidance concerns the use of personal protective equipment (PPE) by health and social care workers, in the context of the current COVID-19 pandemic, and that it supersedes previous PPE guidance. It is added that the guidance solely relates to considerations of PPE, that it represents one section of infection prevention and control guidance for COVID-19, and that it should be used in conjunction with local policies.
The main changes in the updated guidance provided by Public Health England are the following:
- enhanced PPE recommendations for a wide range of health and social care contexts
- inclusion of individual and organisational risk assessment at local level to inform PPE use
- recommendation of single sessional (extended) use of some PPE items
- re-usable PPE can be used. Advice on suitable decontamination arrangements should be obtained from the manufacturer, supplier or local infection control
- guidance for when case status is unknown and SARS-CoV-2 is circulating at high levels
- recommendation on patient use of facemasks
- recommendation on the use of disposable fluid repellent coveralls as an alternative to long sleeved fluid repellent gowns for aerosol generating procedures or when working in higher risk acute areas. Staff need to be trained in the safe removal of coveralls [10 April 2020]
Within the guidance, safe ways of working for all health and care workers are outlined, and a summary of PPE recommendations for health and social care workers is given. It also refers to the sessional use of PPE and risk assessment issues. The recommendations given in the PPE guidance differ depending on the respective healthcare context. Also, the use of PPE for patients is explained, and an overview is given of recommended PPE types with a rationale for their use.
For viewing the complete guidance, please visit: GUIDE
The international law firm Clyde & Co offers various helpful resources in their COVID-19 information hub, such as articles on guidance or free webinars. As to the issue of PPE (Personal Protective Equipment), they are pointing out the challenges which this presents to employers, and offer practical guidance to ensure compliance of the employers´s legal duties.
As to an article by Tony Cawley, Mary Edis and Scott Taylor that was published on the website of Clyde & Co on the 21st of April, 2020, some of the numerous challenges in this context are, amongst others, the wide range of health and social care contexts in which NHS employees work (ranging from secondary care inpatient settings, primary, outpatient and community care settings, ambulances, paramedics, first responders and pharmacists); the fact that PPE requirements differ according to the setting and context it is used it; or accounting for the fact that the provision of healthcare is dynamic. Of course, the rapidly evolving situation is another big challenge.
Another important issue mentioned in the article are the duties employers have in this context. An employer has statutory and common law duties to ensure the health, safety and welfare at work of its employees, as stated in the Health & Safety at Work Act 1974, as well as various health and safety Regulations. There is increasing concern given the fact that the supplies of PPE to NHS staff are inadequate, raising the question of regulatory breaches – this issue still has to be investigated.
Clyde & Co gives advice as to which measures should be taken by employers in the healthcare sector for the time being. They mention that the measures to take, if reasonably practicable, should include (but are not limited to) the following:
- Act proactively and ethically to protect the safety of staff in the workplace by the provision of suitable and adequate PPE
- Proactively review risk assessments and control measures on a very regular basis
- Monitor and adhere to guidance from government and other public health bodies
- Ensure staff are trained in the correct use of PPE including "donning" and "doffing" of equipment. Videos are available
- Ensure staff know what PPE they should wear for each setting and context
- Ensure staff know which items are subject to single use/sessional use/reusable, and are aware of appropriate disposal and decontamination processes
- Ensure staff practice hand hygiene extended to exposed forearms after removing any element of PPE
- Keep clear and comprehensive records of what PPE they have, including detail of the various types of equipment
- Record those to whom it is provided
- Keep good records of requests for more equipment and the responses to such requests
- Log, collate, investigate and where reasonably respond to complaints from staff about the lack of PPE