UPDATE ON PROMOTING, PROTECTING AND SUPPORTING HEALTH IN WORK - Cordell Health

COVID-19 update for clients as at 7 Feb 2022

UPDATE ON PROMOTING, PROTECTING AND SUPPORTING HEALTH IN WORK

1.      The importance of vaccination
The Secretary of State for Health and Social Care has announced1 that regulations making vaccines a
condition of deployment for health and social care staff in England are set to be revoked, subject to
public consultation and Parliamentary approval2. This was to have been a requirement for those who
have face to face contact with patients (including ancillary staff such as porters or receptionists who
may have social contact with patients3) all CQC regulated health and care settings from 1st April 20224.
It has been a legal requirement to be fully vaccinated to work in a CQC regulated care home since 11th
November. For our social care clients, the position of those employed in care homes, or whose work
takes them into care homes remains unchanged until such time the legislation as it applies to all health
and care staff is repealed. The operational guidance for wider social care settings has however been
updated in light of the Government’s change in position on vaccination as a condition of deployment5.
The Faculty of Occupational Medicine (FOM) made clear its position during the consultation last Summer
that it is not supportive of mandatory vaccination as a condition of employment6. With this change in
Government policy, we as occupational health professionals will continue to encourage the uptake of
COVID-19 vaccine on a voluntary basis to protect individuals and populations. We remain happy to
continue to have consultations with health and social care staff who remain hesitant over vaccination.
As reported by the UK Health Security Agency (UKHSA) in their report on Omicron at Week 5 (as at 3
Feb 2022)7, vaccine effectiveness against hospitalisation started at around 90% dropping to around 75%
after 10 to 14 weeks for Pfizer boosters. However, effectiveness against symptomatic disease is
significantly less; two to four weeks after a booster dose of either the Pfizer or Moderna vaccine,
effectiveness ranges from around 60 to 75%, dropping to 25 to 40% from 15+ weeks after the booster.
Vaccination therefore remains important in protecting people from becoming severely ill but is less
effective at reducing the spread of the infection. Other measures to reduce transmission in the
workplace remain important, as determined by the employer’s risk assessment.

1
  Oral statement on vaccines as a condition of deployment. The Secretary of State for Health and Social Care
Sajid Javid updated Parliament on vaccines as a condition of deployment (31 Jan 2022) at:
https://www.gov.uk/government/speeches/oral-statement-on-vaccines-as-a-condition-of-deployment
2
  Covid-19 Update. Statement made on 3 February 2022. Statement UIN HCWS587 at: https://questions-
statements.parliament.uk/written-statements/detail/2022-02-03/hcws587
3
  Government to introduce COVID-19 vaccination as a condition of deployment for all frontline health and social
care workers at: https://www.gov.uk/government/news/government-to-introduce-covid-19-vaccination-as-a-
condition-of-deployment-for-all-frontline-health-and-social-care-workers
4
  Vaccination as a condition of deployment in health and social care settings at:
https://www.cqc.org.uk/news/providers/vaccination-condition-deployment-health-social-care-settings-our-role
5
  Coronavirus (COVID-19) vaccination as a condition of deployment for the delivery of CQC-regulated activities in
wider adult social care settings (as updated 3 Feb 2022) at:
https://www.gov.uk/government/publications/vaccination-of-workers-in-social-care-settings-other-than-care-
homes-operational-guidance/coronavirus-covid-19-vaccination-as-a-condition-of-deployment-for-the-delivery-of-
cqc-regulated-activities-in-wider-adult-social-care-settings
6
  FOM statement as at 2 Jul 2021. COVID-19 Guidance on Vaccination and Testing at:
https://www.fom.ac.uk/wp-content/uploads/COVID-19-Guidance-on-Vaccination-and-Testing.pdf
7
  COVID-19 vaccine weekly surveillance reports at: https://www.gov.uk/government/publications/covid-19-
vaccine-weekly-surveillance-reports

Cordell Health ©                                                                               7 Feb 2022 v57.2

2.     Risk assessment and testing
As set out in previous updates over these last two years, and as set out in Health and Safety Executive
(HSE) guidance, we continue to recommend the hierarchy of control approach to risk management8 and
the HSE guidance for risk management during the COVID-19 pandemic9. This is illustrated as follows:

In regard to the place of testing, last week one of our clients asked the following question:
“Now that we are out of GOV Plan B, please can I ask you to consider how long will COVID testing be
here for and what conditions are needed before we drop the need for COVID testing completely?”
There have been reports in the media that the Government may be ending the free provision of lateral
flow device (LFD) tests10, although there has been no official statement on this that we have seen. What
does seem likely is that the focus on testing will now be more on enabling earlier release from isolation
after as early as five days for those with COVID-1911, and to enable contacts who are vaccinated to be
in work, as well as enabling activities when people meet (at home or in work).
Routine testing of those working in higher risk settings, including health and social care, and high-risk
school settings12, is in our view likely to continue for the time being, but even this guidance has changed.
Rather than PCR once a week and twice weekly LFD tests, this is more targeted at testing with LFD on
days that for example the health or social care worker is in work (at home before coming in to work)13.
For other workplaces, our recommendation is that any decision on testing should consider the likelihood
of infection occurring in the workplace, the impact of infection occurring (both in terms of the impact
on individuals and on business continuity) and on the effectiveness of controls. With a general drive to
consider COVID-19 more like influenza, whereas vaccination is likely to remain important, our own view
is that routine asymptomatic testing for staff is not likely to add value beyond the end of March 2022.

8
  Managing risks and risk assessment at work at: https://www.hse.gov.uk/simple-health-safety/risk/index.htm
9
  Risk assessment during the coronavirus (COVID-19) pandemic at:
https://www.hse.gov.uk/coronavirus/working-safely/risk-assessment.htm
10
   End of free lateral flow tests as country told to live with Covid (9 Jan 2022) at:
https://www.thetimes.co.uk/article/end-of-free-lateral-flow-tests-as-country-told-to-live-with-covid-3bpz8lnqf
11
   Stay at home: guidance for households with possible or confirmed coronavirus (COVID-19) infection (as
updated 1 Feb 2022) at: https://www.gov.uk/government/publications/covid-19-stay-at-home-guidance/stay-
at-home-guidance-for-households-with-possible-coronavirus-covid-19-infection
12
   Rapid asymptomatic testing in specialist settings (updated 19 Jan 2022) at:
https://www.gov.uk/government/publications/guidance-for-full-opening-special-schools-and-other-specialist-
settings/rapid-asymptomatic-testing-in-specialist-settings
13
   Coronavirus (COVID-19): testing in adult care homes at:
https://www.gov.uk/government/publications/coronavirus-covid-19-testing-in-adult-care-homes

Cordell Health ©                                                                             7 Feb 2022 v57.2

3.     Risk assessment for those who may be more vulnerable
The Government continue to advise those previously considered clinically extremely vulnerable (CEV)
that they will not be advised to shield in future or follow specific guidance14. The majority previously
advised they were CEV should be able to continue in their work as currently, as you have adapted this
if needed following risk assessment and following the guidance for the community in general15.
There are a proportion of those previously identified as CEV with impaired immune systems, who may
have continued vulnerabilities even with immunisation16. This will include people with blood cancers
(such as leukaemia and lymphoma), who have had organ or bone marrow transplants, as well as people
having treatments that may weaken the immune response (such as chemotherapy and radiotherapy, as
well as biological treatments). Such people have been identified as those who had a third primary dose
of COVID-19 vaccine (they will also have boosters), as well as eligibility for new treatments.
New treatments for COVID-19 (Sotrovimab, a neutralising monoclonal antibody, and Molnupiravir, an
antiviral) are now available through the NHS for people aged 12 and over who test positive for COVID-
19 and are at highest risk of getting seriously ill even though they have been vaccinated17.
Our advice is that those in the immunosuppressed group and others identified as being suitable for the
new treatments should be able to continue in their work as currently, as you have adapted this as
needed following your risk assessment. We should however be happy to advise on individual health risk
assessments for any staff members in this group where you consider further guidance is needed.

4.     Risk assessment for pregnant employees
The advice for pregnant employees was updated on 31 Jan 202218. Rather than earlier advice based on
stage of gestation, this is now principally based on whether the woman is vaccinated or not. Women
who are fully vaccinated, and without the known risk factors, are likely to be able to undertake their
usual role during pregnancy, following risk assessment, and with adherence to the risk management
controls in place for colleagues doing similar work. We suggest pregnant employees are referred for
an individual health risk assessment, to complement the employer’s risk assessment19. Referring early
allows us to advise on those who may be more at risk, to speak with them about any anxieties they may
have, and to advise those unvaccinated on the importance of COVID-19 immunisation in pregnancy.

Dr Robin Cordell
7 February 2022

14
   COVID-19: guidance on protecting people defined on medical grounds as extremely vulnerable (updated 24 Dec
2021) at: https://www.gov.uk/government/publications/guidance-on-shielding-and-protecting-extremely-
vulnerable-persons-from-covid-19/guidance-on-shielding-and-protecting-extremely-vulnerable-persons-from-
covid-19
15
   Coronavirus: how to stay safe and help prevent the spread as at: https://www.gov.uk/guidance/covid-19-
coronavirus-restrictions-what-you-can-and-cannot-do
16
   COVID-19: guidance for people whose immune system means they are at higher risk (published 24 Dec 2021)
at: https://www.gov.uk/government/publications/covid-19-guidance-for-people-whose-immune-system-means-
they-are-at-higher-risk
17
   Treatments for coronavirus (COVID-19) at: https://www.nhs.uk/conditions/coronavirus-covid-19/treatments-
for-coronavirus/
18
   Coronavirus (COVID-19): advice for pregnant employees at:
https://www.gov.uk/government/publications/coronavirus-covid-19-advice-for-pregnant-
employees/coronavirus-covid-19-advice-for-pregnant-employees
19
   HSE. Protecting new and expectant mothers at work at:
https://www.hse.gov.uk/mothers/employer/index.htm

Cordell Health ©                                                                            7 Feb 2022 v57.2