Clearer data is now emerging on specific risk factors for individuals relating to COVID-19 infection. Proper risk assessments for medical staff are therefore imperative, but this is a big challenge given the large number of staff to be assessed and underfunded occupational health departments.
Concerns have been expressed by RCP members about how these assessments have been carried out. An independent expert group, including the Faculty of Occupational Medicine (FOM), has looked into the issue and produced a Risk Reduction Framework for NHS staff at risk of COVID-19 infection.
Key principles from the framework as well as practical points on implementation from FOM are summarised below.
Key principles of COVID-19 risk assessments
- Risk assessment – and the risk reduction which follows – is a management responsibility, linked to the legal requirements of duty of care in health and safety law.
- There are three components - workplace, workforce and the individual (as explained in the two diagrams at the end of the framework).
- Individual assessment is delegated to the line manager who is responsible for making decisions about deployment of staff. For trainees their ‘line manager’ will often be their consultant and this was implicit in the medical ‘firm’ arrangements.
- Factors to be considered may vary slightly with the particular circumstances or reasons for the risk assessment – Age/Sex/Pregnancy/Ethnicity/Existence of underlying health conditions are all relevant.
- Conversations by managers with their staff should be conducted one-to-one in a sensitive manner.
- Enquiry about health related matters is usually limited to functional capabilities, or to enquiry as to whether the employee has any health factors (without details) which should be considered.
- If further enquiry or assessment is needed before decisions can be made about deployment, this should be done by the occupational health (OH) department. With consent from the employee, OH should report back to the manager in functional terms without clinical details.
- The manager makes decisions about deployment taking into account the advice received from OH.
Conducting COVID-19 risk assessments in practice
- For the vast majority of staff, OH input is not required beyond basic checks and advice about immunisations and clearance for Exposure Prone Procedures (EPPS). These would typically be carried out anyway at the start of employment or training.
- It may be necessary for managers to make further enquiry than would usually be the case. This can be done by giving an information sheet to the member of staff listing potential vulnerabilities and asking if they feel that any of these apply to them.
- It is not appropriate nor necessary for all staff to be seen in OH. In the vast majority of cases, effective risk assessment does not require individual OH input.
- The role of OH (and particularly of the consultants in occupational medicine) is to work strategically with trust management to advise on appropriate methods of risk assessment where health factors are relevant. In many cases algorithms have been developed in consultation with OH to help mangers have sensitive conversations with their staff and to know when to seek further advice.
- At the request of management or on self–referral, an OH appointment or, as a ‘final’ step, occupational medical assessment by an accredited specialist may be necessary for a minority of staff. This is recognised and advised by NHS Employers but has never been mandated by NHSE/I.