Use of Personal Protective Equipment (PPE)
Health Protection Scotland guidance offers advice on use of PPE, confirming workplaces should use PPE consistent with local policies and in line with measures justified by a risk assessment.
Where PPE is already in use in undertaking CLD activity in respect of conventional (non-COVID-19) risks you should continue to do so. Additional PPE is not normally required outside of healthcare settings when managing the risk of COVID-19. Control measures being developed for a COVID-19 risk assessment should focus on hygiene and physical distancing. The exception to this is health care provision or a small number of other roles for which public health advice is to use PPE as a COVID control (for example, for first responders).
The Scottish Government and Health and Safety Executive recommend a risk based approach focussed on a hierarchy of control which seeks to eliminate risks, combats risks at source, adapt workplaces to individual needs, and ensure adequate training for staff, volunteers and learners. Using any form of PPE is a last resort after you have assessed the risks. Where PPE is required, users must be provided with adequate information, instruction, training and supervision to ensure it is used and disposed of correctly.’ PPE should be made available as identified in the risk assessment provided to CLD staff, volunteers and learners as appropriate.
COVID-19 guidance for non-healthcare settings sets out guidance on use of PPE. This advice confirms that workplaces should use PPE consistent with local policies and in line with measures justified by risk assessment. It should be reflected in the risk assessment where additional PPE is required to control risks associated with COVID-19.
It is important to note the difference between face masks and face coverings. Face coverings are not intended to help the wearer, but to protect against inadvertent transmission of the disease to others if you have it asymptomatically. Face coverings are not classed as PPE.
Use of face coverings in the circumstances set out in this guidance should be seen as just one mitigation within a package of measures. The other mitigation measures in this guidance, including two metre physical distancing, environmental cleaning, personal hand and respiratory hygiene remain vitally important. Face coverings should not be used for the purpose of reducing physical distancing requirements.
Face coverings are recommended in all indoor settings. For the purposes of CLD activity, face coverings should be worn indoors by all participants, staff and volunteers over the age of 14 years. This mitigation should be put in place as well as having a minimum of 2m physical distancing within the learning environment.
Face coverings should also be worn in when people are not engaged in activity. This is especially important where 2m distance cannot be guaranteed.
Some individuals are exempt from wearing face coverings. Further information on exemptions can be found in wider guidance from the Scottish Government.
Face coverings should also be worn in the following circumstances (except where someone is exempt from wearing a covering):
- where people are moving about in corridors, confined communal areas (including toilets), and other areas of buildings where physical distancing is particularly difficult to maintain
- in line with the current arrangements for public transport, where adults and young people aged 5 and over are travelling on public and dedicated transport used by CLD services
Face coverings must be worn in shops, libraries and certain other indoor spaces, except where a person is exempt from wearing a covering, as specified in the regulations and Scottish Government guidance.
CLD services may wish, subject to appropriate risk assessment and consultation with staff and trade unions, should consider strengthening the use of face coverings in other areas of settings to address specific local circumstances (e.g. particular concerns or anxieties around distancing or confidence building in the context of local or wider outbreaks).
An example of local “stepping up” of measures may be the use of face coverings in circumstances where increased community transmission is being seen.
In making any such local decisions on the stepping up of use of face coverings, it will remain vitally important to consider the potential impact including via the appropriate use of Equality Impact Assessments. The impact of wearing a face covering for young people, adult learners or staff with additional support needs, including any level of hearing loss, should be carefully considered, as communication for many in this group relies in part on being able to see someone’s face clearly. Individuals who may not be able to handle and wear face coverings as directed (those with additional support needs or disabilities) should not wear them as it may inadvertently increase the risk of transmission.
Incident Management Teams may recommend a further strengthening of the use of face coverings in other areas of settings when dealing with a local outbreak.
It is vital that clear instructions are provided to young people, adult learners and staff on how to put on, remove, store and dispose of face coverings in all of the circumstances above, to avoid inadvertently increasing the risks of transmission. The key points are as follows:
- face coverings should not be shared with others
- before putting on or removing the face covering, hands should be cleaned by washing with soap and water or hand sanitiser
- make sure the face covering is the right size to cover the nose, mouth and chin
- when temporarily storing a face covering (e.g. during classes), it should be placed in a washable, sealed bag or container. Avoid placing it on surfaces, due to the possibility of contamination.
- re-usable face coverings should be washed after each day of use at 60 degrees centigrade or in boiling water
- disposable face coverings must be disposed of safely and hygienically. Staff, volunteers and learners should be encouraged to place their face coverings in the general waste bin. They are not considered to be clinical waste in the same way that used PPE may be
There should be regular messaging from CLD services to staff, volunteers and learners about these instructions.
It is reasonable to assume that most people will now have access to re-usable face coverings due to their increasing use in wider society, and we have made available a video on how to make a simple face covering. However, no-one should be excluded from CLD services on the grounds that they are not wearing a face covering. Where a learner is struggling to access a face covering, or where they are unable to use their face covering due to having forgotten it or it having become soiled/unsafe, CLD services should take steps to have a contingency supply available to meet such needs.
We are continuing to review advice on the use of face coverings. This advice should be considered as part of the risk assessment process when considering CLD activity.
If you would like to provide feedback or have any questions related to this guidance please email Elisha.Fisher@gov.scot