As the Covid-19 pandemic has evolved through 2020 Occupational Health (OH) professionals have provided critical support to businesses and organisations as they have established programmes to assess and manage risk and protect employees.
Currently, two new issues – namely vaccination and testing – are evolving, and Occupational Health professionals are being asked to plan, execute or participate in such programmes.
In times of extreme urgency, it is easy to overlook the fundamental ethical and legal principles that are already firmly established to protect employees from risks such as breach of confidence, or tests being performed or interpreted by inexperienced or incompetent individuals. Upholding these principles are the bedrock of OH practice.
Occupational Health professionals are reminded that existing Ethics Guidance remains appropriate and essential in these new programmes.
In principle, any decision about promoting and partaking in an initiative and sharing special data generated by such an initiative must be made in accordance with existing legal, ethical and professional principles as summarised in the Faculty of Occupational Medicine Ethics Guidance.
VACCINATION
Occupational Health professionals should encourage the uptake of COVID vaccine to protect individuals and populations.
It is important to ensure that all elements of the vaccination programme are consistent with the national regulatory guidance such as those published by Medicine and Health products Regulatory Agency (MHRA), the Joint Committee on Vaccination and Immunisation (JCVI), Public Health England and the Chief Medical Officer Directorates and local NHS Boards. Notably from an OH perspective it should include, but not be limited to, adequate consideration of:
- Consent, which must be informed and freely given.
- Opportunity to address patients’ questions about the vaccine
- Accurate records which are readily accessible and in accordance with the national requirements (National Immunisation Vaccination System (NIVS)
- Rigorous application of transport and storage processes relevant to each vaccine type
- Competent and trained staff to screen the recipients, process and administer the vaccine
- Appropriate legal framework to prescribe the vaccine (Patient Specific Directions (PSD), Patient Group Directions (PGD), Written Instructions or Protocols)
- Facilities and competence to deal with anaphylaxis
It is imperative that OH professionals involved in vaccination programmes keep up to date with the national guidance.
TESTING
Organisations may request that Occupational Health establish testing programmes for various purposes including, but not limited to, access to the workplace, fitness to attend work, prior to remote working, contact tracing, prevalence, research and international travel. Occupational Health professionals are reminded of the advice summarised in the Ethics Guidance pertaining to any programme involving surveillance/testing of employees. The programme should include:
- Confirmation of the specific issue/scenario to be addressed by testing
- Identification of the appropriate testing method – PCR, Rapid Antigen, Antibody etc – for the specific scenario, in communication with the subject matter specialist e.g. virologist or laboratory scientist
- Confirmation that the purpose and proposed testing programme is consistent with current government guidance
- Reliability / licensing of the test method purchased or laboratory contracted
- Written procedure
- Information/instruction to participants on nature of the programme, details of the test e.g. how it is carried out especially if it is self-administered, how often, possible outcome, and the implications for them and their household. Consideration should be given to people with communication or learning difficulties or other impairments who may need additional support and to those for whom English is not their first language.
- Consent, which must be informed and freely given, should include to whom the result will be released (patient, personal physician, management, government etc)
- Competent trained staff to undertake the testing
- Record keeping in accordance with ethical, legal and professional principles
- Documented decision tree enabling immediate action based on the test results
Occupational health professionals may come under pressure from employers to approve or implement health or non-health interventions purporting to reduce the health or business impacts of the COVID-19 pandemic.
While some interventions may have significant benefits, others may result in expenditure with little benefit, or even harm. OH professionals should consider carefully the relevant factors pertaining to work and health when evaluating potential interventions, and should be able to justify their recommendations if challenged at a later date.
This advice is current as of 22 January 2021
It will be updated as new information on these aspects of COVID 19 emerge
- Ethics Guidance for Occupational Practice – 8thEdition, FOM
https://www.fom.ac.uk/publications-policy-consultations/ethics-guidance-for-occupational-health-practice [1] - Regulation 174 Information for UK Healthcare Professionals. Medicines and Health products Regulatory Agency
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/943417/Information_for_healthcare_professionals.pdf [2] - Legal mechanisms for administration of the COVID-19 Vaccine(s), NHS England and NHS Improvement
https://www.england.nhs.uk/coronavirus/publication/legal-mechanisms-for-administration-of-the-covid-19-vaccines/ [3] - COVID-19 vaccination programme: Information for healthcare practitioners, Public Health England
https://www.gov.uk/government/publications/covid-19-vaccination-programme-guidance-for-healthcare-practitioners [4] - COVID19 Vaccination, e-Learning for Health
https://portal.e-lfh.org.uk/Component/Details/675208 [5] - Chapter 14a – COVID-19 – SARS-CoV-2, the Green Book
https://www.gov.uk/government/publications/covid-19-the-green-book-chapter-14a [6] - Coronavirus (COVID-19) testing: guidance for employers and third-party healthcare providers, DHSC
https://www.gov.uk/government/publications/coronavirus-covid-19-testing-guidance-for-employers/coronavirus-covid-19-testing-guidance-for-employers-and-third-party-healthcare-providers [7] - UK COVID-19 vaccines delivery plan
https://www.gov.uk/government/publications/uk-covid-19-vaccines-delivery-plan/uk-covid-19-vaccines-delivery-plan [8] - Scottish Government COVID-19 vaccine deployment plan
https://www.gov.scot/publications/coronavirus-covid-19-vaccine-deployment-plan-2021/ [9]
ACKNOWLEDGEMENTS
The FOM is grateful for the work of the Faculty Ethics Committee, the principal authors, Dr Graham Bell and Dr Ali Hashtroudi and the current dialogue collaboration with colleagues, particularly those working in occupational medicine and the wider OH community, which has made this guidance possible.
Dr Anne de Bono
President
Dr Mark Groom
Chair, Ethics Committee
Date last modified: 22/01/2020