WHO criterion 5: Manage the risk of exporting and importing cases
WHO criterion 5: Manage the risk of exporting and importing cases from communities with high risks of transmission.
As we enter Phase 3 we have suppressed the virus in Scotland consistent with the phase criteria. Phase 3 involves gradual re-opening, resumption and scaling up of economic and social interactions. These are necessary to mitigate the overall harm caused by the pandemic and involve sometimes delicate and difficult balances. They also reflect our legal obligation to retain restrictions in place for no longer than they are deemed proportionate.
As noted below in relation to the re-opening of holiday accommodation, this gradual easing of restrictions increases transmission risk. Cross-border movements of people and goods will continue and increase as we ease restrictions, particularly those that have to this point served to limit cross-border tourism, student and business travel. Consequently, it is essential to our plans for a sustainable recovery that we reduce importation risk to an acceptably low level.
As the community transmission of COVID-19 decreases in Scotland, the importance of managing the risk of imported cases increases. the Scottish Government has worked with UKG and the Devolved Administrations (Northern Ireland Executive and Welsh Government) to address this risk.
The Health Protection (Coronavirus) (International Travel) (Scotland) Regulations 2020 came into force on Monday 8 June.
Under the regulations anyone arriving in Scotland, from outside the Common Travel Area, will need to
- provide their journey and contact details when they travel to Scotland
- not be allowed to leave the place they are staying for the first 14 days they are in Scotland except in very limited situations (known as 'self-isolating')
The regulations apply to people who live in Scotland and who are returning from outside Scotland, as well as to people visiting Scotland. These measures apply to international travellers into Scotland irrespective of their point of entry into the UK
There are also a number of exempt countries, sectoral exemptions and other categories of person who are exempt from to the requirement to self-isolate.
The regulations apply to people regardless of whether they are residents of Scotland or visitors. The regulations laid in the four nations attempt to align as much as possible. However, there are some differences contained within the Scottish Government regulations, including differences in the enforcement of the measures; the exemptions list and the self-isolation requirements. The Scottish Government coronavirus website provides guidance on how these measures apply to arrivals in Scotland and can be found here: Scottish Government public health measures
Duties are also placed on transport operators to provide passengers with information, both before booking and throughout the passenger journey, by the Health Protection (Coronavirus, Public Health Information for Passengers Travelling to Scotland) Regulations 2020.
An individual arriving in Scotland (from outside the Common Travel Area) must state on the passenger locator form where their accommodation is and travel straight to that accommodation, preferably by private transport.
They must self-isolate for 14 days and only leave that accommodation in limited specified circumstances. If they live with others who have not been out of the country in the previous 14 days they should - as per the regulations unless subject to a specified list of exemptions - minimise their contact with them and, if they require help buying groceries, other shopping or picking up medication they should, where possible, ask friends or relatives or order a delivery.
Rationale for measures
When transmission was high within community settings, expert advice was that bringing in such border health control measures at that stage would not make a significant impact on community transmission. With the reduction in domestic transmission rates and the continuing requirement to keep the R number low, the risks to public health from imported transmission have become more significant.
The low level of arrivals has allowed Border Force to provide regular checks of passenger locator forms and there have been no major issues reported. There has been a high level of compliance with this element of the measures.
As of Thursday 9 July, Police Scotland has only had seven referrals relating to suspected breaches of the self-isolation requirements. No Fixed Penalty Notices have been issued by Border Force or Police Scotland for offences under these Regulations (as of Thursday 9 July 2020).
Public Health Scotland is conducting follow up calls with a sample of travellers who are self-isolating. These calls will provide public health advice, information and guidance to travellers and began in the week commencing 6 July.
The regulations are subject to review at least once every 21 days on a rolling basis. The first review point was Monday 29 June. The review period has involved a cross Scottish Government working group (comprising of colleagues from Health, Justice, Legal, Migration and Transport) to assess both the impact of the regulations and the ongoing need to implement these regulations. Officials have also participated in a four nation Working Group led by UK Border Force.
Consideration was given to whether alternative arrangements could be put in place at the international border to reduce the risk of importing new cases of the virus, such as pre-departure testing or testing at the border. At present it is not considered that there is an alternative package of methods that would manage the risk of exporting and importing cases from communities with high risks of transmission to the extent that border health measures do. This will continue to be monitored and assessed, to ensure the most appropriate measures are in place moving forward.
The CMOs across the four nations took a collective view on the case for border health measures at the start of May. The CMO for Scotland has reviewed the case for a continuation of the public health measures and stated that it is his view 'that these measures remain necessary and are appropriate in current description.'
It was therefore assessed that there remains a requirement for them to remain in place to reduce the risk of transmission and safeguard health. This outcome was notified to the Scottish Parliament on Monday 29 June.
Further consideration has been given to the exemptions list during this review phase, with particular assessment of country specific and sectoral specific exemptions, often referred to as 'Air Bridges' or 'Travel Corridors'. The proposed exemptions apply to the second point of the regulations - namely the requirement to self-isolate. Passengers will still be required to complete the passenger locator form.
Country specific exemptions
The UK Government published its list of exempt countries and territories on 3 July. The list contains 59 overseas countries and 14 overseas territories
The UK Government has shared an outline of the methodology it has adopted to assess countries as low, moderate, or high risk. This involves considering two measures:
- Estimated point of prevalence - an estimate of the proportion of the population that is currently infectious. The incidence rate measures the rate of new infections and is a useful guide to whether prevalence is likely to increase or decrease. The approach adopted by the UK Government considers both prevalence and incidence.
- An assessment by Public Health England (PHE) of the risk of exposure to COVID-19 derived from data published on-line by each country's government or public institute (this assessment is being used to inform FCO Travel Advice).
This information is then used to place countries within an overall Red Amber Green (RAG) rating. If a country has a point prevalence higher than in the UK the country receives a red indicator and where it is close to the UK an amber indicator. PHE assign a red (high risk); amber (moderate) and green (low) risk rating to countries for their assessment. Countries who receive green in both categories are assessed overall as green; red in both categories red while those with a mixed assessment are rated as amber
The UK Government has published a list of exempt countries at https://www.gov.uk/guidance/coronavirus-covid-19-travel-corridors#travel-corridors-countries-and-territories-exemption-list. The list comprises mainly green (low risk) countries, though there are up to 14 Amber (moderate) countries on the list.
Consideration was given by Scottish Minsters as to whether Scotland will align with the UK Government approach. As the policy intention is based on public health principles, exemptions need to be considered on this basis. It has been assessed that prevalence is as much as five times lower in Scotland than in England and Wales. This may mean that the threshold around which risk becomes greater could be different for each country (and may also change quickly as each country's experience of the pandemic fluctuates).
Scottish Ministers were clear from the outset that a tailored approach is appropriate; that the Scottish Government should apply an exemption to travellers from countries with a lower level of risk than Scotland (green) and not to countries with a higher level of risk (red).
However, the range of moderate (amber) risk countries meant that further consideration was needed by Scottish Ministers. Subsequently, the UK Government provided data from the Joint Biosecurity Centre (JBC) and Public Health England to identify those countries who have a point prevalence significantly above Scotland. Scotland's point of prevalence on 3 July was 0.018% [0.012% - 0.027%].
The majority of moderate (amber) risk countries exempt on the UK Government list currently have a similar point of prevalence to Scotland. However, it was estimated that the point prevalence in Spain was 10 times higher than in Scotland, partly due to two localised outbreaks, and it is therefore considered that lifting restrictions on Spain would not be possible at this stage. Similarly, concerns about a recent outbreak in Serbia have led neighbouring states to close their borders with that country. The impact of that outbreak will not be seen in the data yet, but as a result we have determined Serbia should not be added to the exempt countries list. Spain and Serbia were both on the UK's exemptions list, although Serbia has since been removed following similar concerns to those raised by the Scottish Government.
On Wednesday 8 July the First Minister announced 57 countries and territories (plus 14 overseas UK territories) will be exempt from the self-isolation requirement on arrival to Scotland. The exemptions came into force in the regulations on Friday 10 July. This list will be closely monitored and assessed on a rolling basis within the 21 day review cycle. The list of exempt countries can be viewed https://www.gov.scot/publications/coronavirus-covid-19-public-health-checks-at-borders/pages/exemptions/.
Since 8 June a small number of people travelling to the Scotland in very limited circumstances do not need to self-isolate and/or complete contact detail declarations.
For example, people are exempt if they are travelling to maintain essential supply chains, critical national infrastructure or to contribute to crisis response or other essential government work. Seasonal agricultural workers must remain for 14 days on the farm where they are working and staying. Further guidance for seasonal agricultural workers is available here: https://www.sasa.gov.uk/covid-19-guidance
In Scotland there are some further specific differences from the exemptions in England, Wales and Northern Ireland:
- registered health or care professionals travelling to the UK to provide essential healthcare, including where this is not related to coronavirus, will need to self-isolate for 14 days if they are staying in Scotland
- frequent travellers for work: if they live in the UK but work in another country and travel between the UK and country of work at least once a week; and/or they live outside the UK but work in the UK and travel between their country of residence and the UK at least once a week - they will need to self-isolate for 14 days if you are staying in Scotland.
From 10 July, the following industries have been included in the exemption from the self-isolation requirements:
- elite sporting events - elite sportspersons and support workers on major sporting events - in adherence with the Resumption of Performance Sport guidance
- film and TV production - personnel being engaged to work on a film or high-end TV programme
We have concluded that the regulations introduced on Monday 8 June continue to manage the risk of exporting and importing cases from communities with high risks of transmission. The regulations have been amended to allow some exemptions from the self-isolation requirements through an evidence based risk assessment. Arrivals from the exempt countries and industries will still need to complete the passenger locator form. The review cycle of 21 days and rolling consideration of the exemptions list provides a process for us to ensure these regulations continue to be assessed as appropriate to protect public health in Scotland.
Importation risk from Ireland
In aviation there is currently very little passenger demand, although we are beginning to see some airlines slightly increase the number of flights they are operating. The introduction of these public health measures is expected to limit the volume of international travel to and from the UK, reducing the risk of imported transmission.
Ireland has had success in suppressing the virus. According to the latest data, and Irish government statements, the virus is close to being eliminated at community level, with any incidence currently limited to either long term residential settings, or linked to international travel. On 7 July Ireland had its first consecutive two days with no new deaths of patients confirmed with COVID-19. As of the same date, 19 patients were in ICU with confirmed COVID-19.
The Irish government is advising against all but essential international travel. All incoming passengers arriving at ports and airports are legally required to submit passenger locator information and requested to self-isolate for a 14 day quarantine period (which is not legally enforced). The Irish Government will review this advice again by 20 July, when it is expected that announcement will be made on a green and amber list of countries which Irish people can safely travel to, and from which there will be a relaxation in the quarantine requirement
There is the potential risk of exporting or importing cases from communities with high risk of transmission in Scotland or in the other countries of the UK.
Restrictions on the provision of holiday accommodation have had the effect of limiting to some degree long distance travel within and to and from Scotland throughout the duration of Phases 1 and 2, thus limiting transmission between communities. However all holiday accommodation is able to reopen on 15 July, following the earlier opening of self-contained, self-catering accommodation and travel restrictions for leisure purposes have been lifted.
Managing transmission to and from communities with high rates of transmission in the rest of the UK will depend amongst other things on systems for instituting local lockdowns being developed in each country - e.g. if the UK Government were to lock down localities in England with hot spots, including the use of travel restrictions, then that could have the effect of limiting travel from those areas to Scotland (and anywhere else) without needing separate provision in Scotland.
In the event of a significant local outbreak, Ministers have regulation making powers under the Coronavirus Act 2020 that would allow the re-imposition of lockdown restrictions on a local or regional basis within Scotland if necessary, thus managing the risk of exporting cases from high risk communities.
As Scotland transitions to the next phase of the COVID-19 pandemic, we are developing a responsive system of community surveillance for COVID-19 direct and indirect impacts at national, regional, and local level. This approach will utilise a range of existing data sources and build on the existing community of expertise across Scotland.
The enhanced surveillance approach will gather routine and new data. In the community this is gathered from all kinds of places including citizens, households, closed settings, primary healthcare, occupational groups, and age groups. These data will be monitored closely for trends and also linked to other data sources to enable a fuller picture to be understood of COVID-19 across the population - this will allow identification of signals that the severity, transmission, or impact is worsening in the population and then to be able to respond appropriately to those signals and emerging risks. This will allow rapid implementation and action on the ground (including through Test and Protect) by the right actors at the right time.
The development of this surveillance system will help to minimise the spread of COVID-19 in Scotland including those derived from imported cases by quickly identifying COVID resurgence, clusters, and outbreaks.