GUIDELINE TO EMPLOYERS: COVID-19 VACCINATION ROLL-OUT
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ALEXANDER FORBES Introduction The Covid-19 pandemic has had a multi-sectoral impact on South Africa, including a significant socioeconomic impact, as well as an impact on healthcare costs. One intervention to rapidly interrupt Covid-19 transmission is an effective vaccination programme. The roll-out of the first wave of Covid-19 vaccinations is a welcome development and may be the start of workplaces getting back to some form of normality. The introduction of the vaccine will offer employers the opportunity, in time, to phase employees back to the workplace. The roll-out of a vaccine nationwide may present many challenges and raise a number of concerns that employers will need to address with ONE IN 3 sensitivity and care. According to an online survey conducted by the World Economic Forum in August, one out of three South Africans do not want to get a Covid-19 vaccine. The efficacy and safety of the vaccine appears to be a real concern for some. As an employer, you need to ensure that there is ongoing communication around the vaccine and how you, as an employer, will support the government roll-out. Why vaccines matter ■ Vaccines are an important part of stopping the spread of Covid-19 and preventing morbidity and mortality. ■ They offer protection to an individual by reducing a IN 3 ■ All vaccines go through a comprehensive approval process by medical regulators to ensure that they are safe. Pharmaceutical companies hand over all laboratory studies and safety trials to validate that the vaccine does work. person’s risk of infection or the severity of their symptoms, and also at a population level, which is referred to as herd ■ Any safety concerns are picked up by regulators when or population immunity. reviewing the data. ■ Herd immunity can be developed either through receiving a vaccine or by previously having been infected. ■ Achieving herd immunity helps to protect those who have not been vaccinated or who have not been previously infected by limiting how much the virus can spread within a population. ■ No single vaccine provides 100% protection, and herd 67% immunity does not provide full protection to those who cannot safely be vaccinated. But with herd immunity, these people will have substantial protection, thanks to those around them being vaccinated. ■ Vaccinating not only protects the individual, but also protects those in the community who are unable to be vaccinated. ■ Vaccines undergo rigorous trials to ensure they are safe South Africa is aiming to vaccinate approximately 67% of and effective. its population to achieve herd immunity. 2|
GUIDELINE TO EMPLOYERS: COVID-19 VACCINATION ROLL-OUT How does the vaccine impact on an employer’s duties around health and safety? ■ Employers have a general duty to ensure, as far as is ■ It is too early to say how the risk-mitigating impact of reasonably practicable, the health, safety and welfare at having a partially-vaccinated workforce might be reflected work of all their employees. This means employers should in an organisation’s Covid-19 risk assessment and its consider how the availability of a vaccine would impact on combination of risk controls to reduce transmission. In this duty over the coming months. particular, it is currently unclear if the vaccine will prevent ■ Employers need to, if not already done, undertake risk the vaccinated person from transmitting Covid-19 to assessments of the Covid-19 transmission risk for their those who are not vaccinated. ‘Covid-secure’ measures organisation. These will need to be revisited to assess are therefore highly likely to be required for some time. whether any ‘Covid-secure’ measures may be relaxed or However, some advanced thought might be given to stopped once part of the workforce is vaccinated. That may whether, for example, vaccinated employees could be be particularly important for organisations in which key grouped to undertake some essential tasks which have not activities have not been possible or have been substantially been possible or where few of the existing risk mitigations curtailed or impacted by having to undertake them in a are available. ‘Covid-secure’ way. It is important to remember that employers cannot procure vaccinations for staff and will have to abide by the government roll-out plan. Once the vaccine is widely available, can employers make it compulsory that employees are vaccinated? ■ Requiring an entire workforce to be vaccinated will be ■ Employers will need to remember that not all employees difficult to achieve from both a legal and labour relations will be willing to have the vaccination due to various perspective. The government is not currently introducing reasons such as religious beliefs, disability-related reasons legislation to make the vaccination compulsory and and personal preference. This cannot be made compulsory therefore it will be for individuals to decide whether or not and disciplinary action cannot be instituted. to be vaccinated. ■ Education and information are going to be key to ensure ■ The question of what is reasonable will be fact sensitive the majority of the workforce is vaccinated. Fear is a for every workplace, and is likely to depend on the risk powerful motivator – there is a belief that the Covid-19 and implications of Covid-19 in a particular setting. The shots were developed too quickly and haven’t been through higher the risk a non-vaccinated person in the workplace enough safety testing. Vaccines for diseases such as polio, presents to themselves and others, the more reasonable measles and whooping cough have been around for decades the requirement to have the vaccination becomes. What and their track records inspire confidence that they’re safe is ‘reasonable’ will also change over time, if, as expected, and effective. The same can’t be said of the Covid-19 people’s initial concerns about the vaccine dissipate vaccine — at least not yet — and this has an impact on and having the vaccine becomes more common. For each individual’s decision to vaccinate. the moment, the reasonableness of a requirement to be vaccinated is likely to be difficult to establish, in most circumstances, in light of it being new. How South Africa’s roll-out will work ■ The national health department will coordinate the vaccine ■ The roll-out of the vaccine will take a three-phase approach roll-out with provincial health departments and the private that begins with the most vulnerable in our population. healthcare sector. The target is to vaccinate 67% of the population by the ■ Distribution of doses will become less targeted as more end of 2021, which will allow our population to achieve vaccines become available. herd immunity. |3
ALEXANDER FORBES Here are the roll-out phases: PHASE 1 PHASE 2 PHASE 3 Frontline healthcare workers Essential workers, persons in persons older than congregate settings, persons over 18 years, targeting 22 500 000 60 years and persons over 18 years of the population The vaccine will be delivered with co-morbidities using three platforms during phase one: 1. Work-based programmes: best for hospital-based staff, especially at district level private and public hospitals. 2. Outreach-based programmes: using mobile teams moving between facilities. Best for primary healthcare providers, community health workers and private medical centres. 3. Vaccination centres: particularly in remote areas - ideal for independent healthcare workers. During phases two and three the same programmes will be used, with the addition of vaccinations at public primary healthcare facilities: Phase 1 Phase 2 Phase 3 Frontline healthcare workers (HCW) Essential workers Other persons older than 18 years of age Target population: 1 250 000 Target population: 2 500 000 Target population: 22 500 000 Persons in congregate settings Target population: 1 100 000 Persons older than 60 years of age Target population: 5 000 000 Persons older than 18 with co-morbidities Target population: 8 000 000 Phase Priority group Definition Essential workers Police officers, miners and workers in security, retail food, funerals, teachers, banking and essential municipal and home affairs, border control and port health services 2 Persons in congregate Persons in care homes, detention centres, shelters and prisons. In addition, people working settings in the hospitality and tourism industry, and educational institutions are also at risk Persons 60 years and older Persons older than 18 years Persons living with uncontrolled diabetes, chronic lung disease, poorly controlled with co-morbidities cardiovascular disease, renal disease, HIV, TB and obesity Will workplaces go back to normal? ■ It remains to be seen how long it will take to complete ■ In addition, even employees who have been vaccinated may the vaccination programme and what effect this will have still not be comfortable with returning to their workplace. on the South African virus rates. With this in mind, at the Employers should consider how to manage any ‘reluctant moment, your Covid-secure working arrangements should returners’, as well as how to manage a potentially mixed remain in place and you should continue to adhere to workforce of those who have been vaccinated and those government guidance. The pandemic will be with us for who have not yet come through the programme (or have not some considerable time to come so employers should plan otherwise had the vaccine). for Covid-19 being an ongoing issue despite the vaccine. ■ A plan on how to phase the return to the workplace would be beneficial to consider despite the size of the organisation. This should consider your employee audits and high-risk employees. 4|
GUIDELINE TO EMPLOYERS: COVID-19 VACCINATION ROLL-OUT What steps can employers take now? While we wait for further information on the vaccination programme, there are a number of steps you can take now to help prepare for the roll-out: Step 1 Audit your Identify which roles can continue to be performed effectively from home, which roles can workforce continue to safely be performed with existing Covid-secure arrangements in place. Identify roles which may reasonably justify an employee having to have a vaccination to perform them. Consider how you will manage an employee whose role requires them to be vaccinated but who refuses to do so, remembering that cases will still need to be reviewed on an individual basis and vaccination is not mandatory. Step 2 Put an internal Providing clear information to employees on the vaccine programme may help encourage participation communications and will support any employees who may have doubts about the vaccination or may otherwise be strategy in place unable to have it. Be prepared for individuals to have concerns about the new vaccine, especially in the early days. Employees should be signposted to sources of further information and support, both internal and external. Make sure that external communications (such as to clients or in advertising) align with the internal messaging and that all messaging aligns with government guidelines. Step 3 Maintain safety The vaccination may not be available to all employees for a significant period of time and in any measures that case, should be used alongside Covid-secure practices for the time being. Employers may want to are already in remind employees to continue to abide by the Covid measures and not to relax their efforts despite place the vaccine. Step 4 Consider what Employers should start to assess what will happen with the roll-out of the vaccine within approach to their workforce and working arrangements. This will include consideration of issues such as working practices anticipated timescales, working requirements at different stages of the programme, differences will be put in across group companies (including in different jurisdictions), unvaccinated employees, and legal place and other risks. This planning may include undertaking a new risk assessment and updating any currently in place. Employers should also ensure that all relevant stakeholders are involved including, if relevant, trade unions. Step 5 Consider your Identify what approach to take to visitors to your premises. Will you require them to provide approach to third evidence that they have been vaccinated before allowing them to enter your premises? Make sure parties your approach to visitors does not undermine your approach to employees. Step 6 Facilitate Consider whether your day-to-day operations are likely to be disrupted by the vaccine roll-out. employees being For example, employees may need to take time off work to get the vaccine and to recover from vaccinated any side-effects. It is not yet known whether the vaccine will be available privately but if it is, employers may want to consider whether they would pay for employees to be vaccinated. Step 7 Consider how There will likely be changes to the medical information an employer will hold about its employees medical records and therefore data protection policies and processes should be reviewed to ensure that they are fit will be managed for purpose. Step 8 Keep up to date The vaccination programme and its impact will evolve over the course of the next few months. on developments Employers will need to be prepared to adapt their plans and approach in line with new developments. How can AF support and assist employers? ■ Provision of information as it is made available and ■ Once the vaccine is made available to medical schemes, we developments on the roll-out may assist with plans on rolling these out ■ Guide on review and updating of health policies for Covid-19 ■ Providing information on centres that will be vaccination points when information is available Contact Portia Mahlalela | Email: mahlalelap@aforbes.com Myrna Sachs | Email: sachsm@aforbes.com Alexander Forbes is a licensed financial services provider. The information in this document belongs to Alexander Forbes. You may not copy, distribute or modify any part of this document without the express written permission of Alexander Forbes. Photos: Getty Images |5 21202-POL-2021-01
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