- 30 Jul 2020
Coronavirus advice for Telecoms Operators in relation to deployment and maintenance
- where we are now
- deployment activity during the Covid-19 pandemic
- outbreak management
- Test and Protect
- going to work
Digital connectivity has never been more vital than it has proven to be during the last few months, whether supporting our health and emergency services or in enabling people to work or study from home and stay connected to friends and family.
The telecoms sector is also critical in supporting the development and growth of Scotland’s economy, especially in more remote areas and in support of a resilient and green recovery from the impacts of COVID-19.
This is a further update to the 30 July Coronavirus (COVID-19): statement to telecommunications operators which confirmed the role of telecoms as part of our critical national infrastructure (CNI) and confirmed the key worker status of telecoms staff who have been undertaking critical maintenance and repairs throughout this challenging period.
This update does not constitute legal advice.
Inevitably, opening parts of our economy and society has provided new opportunities for the virus to spread and the Coronavirus (COVID-19): Scotland’s Strategic Framework was published on 23 October 2020, setting out how we will work to suppress the virus to the lowest possible level and keep it there, while we strive to return to a more normal life for as many people as possible and tackle the four harms we know the virus causes.
This framework sets out new approach to outbreak management based on five levels of protection consisting of four levels above the Route Map Phase 3 baseline (or 'Level 0') as set out below:
Level 0 (baseline) and Level 1
Within these levels, we would expect to see low incidence of the virus with isolated clusters, and low community transmission. Broadly, these levels are the closest we can get to normality, without a vaccine or effective treatment in place, before conditions will allow us to move to Phase 4 of the Route Map. They would be similar to the measures in place during the summer, once we reached Phase 3. The Baseline and Level 1 are designed to be sustainable for longer periods.
Within Levels 2 and 3, we would expect to see increased incidence of the virus, with multiple clusters and increased community transmission. There would be a graduated series of protective measures to tackle the virus, focusing on key areas of risk – broadly, indoor settings where household mixing takes place with less, or less well-observed, physical distancing and mitigations. The measures would be intended to be in place for relatively short periods (2-4 weeks), and only for as long as required to get the virus down to a low, sustainable level.
Within this level we would expect to see very high or rapidly increasing incidence, and widespread community transmission which may pose a threat to the NHS to cope. It is likely that this level would see the introduction of measures close to a return to full lockdown. Measures would be designed to be in place for a short period, to provide a short, sharp response to quickly suppress the virus.
The Scottish Government has engaged with operators and the Communications Workers’ Union to inform our view that in line with construction and road works, telecoms activity is well placed to continue, using experience gained throughout the previous months as restrictions eased to allow activity to resume.
This is reinforced by the updated Strategic Framework which states that the construction sector (including road works) and outdoor work can continue in all levels of restrictions up to and including Level 4 within the Strategic Framework subject to implementing agreed safe working practices for those sectors.
A further consideration is where operators are required to carry out works in-home or in business premises. Guidance on business and physical distancing and work in other peoples homes supports essential work in peoples’ homes continuing in Levels 1-3 of the Strategic Framework. This should be read as allowing both telecoms repairs and new installations, given how important broadband is in supporting the ongoing need for some people to work and study from home. The position for areas in Level 4 has also confirmed that broadband is considered an essential service within the framework therefor entering other peoples’ homes is permitted for the purposes of both installation and maintenance.
Building our digital infrastructure
Expanding our digital infrastructure, whether fixed broadband or mobile, involves a complex set of activities. Central to deploying the fibre which will ensure every premises in Scotland can access superfast speeds and which also supports the expansion of our 4G and 5G networks, is the partnership working between operators and local authorities
Most of the roll-out takes place through civils works on our road and footpath networks and so working closely with the Scottish Road Works Commissioner (SRWC) is key to ensuring the safety of engineers and others engaged in such activity.
In this regard the Commissioner issued a statement which signposts to supporting Health & Safety Executive advice and also highlights that the appropriate standard is the Safety at Street Works and Road Works, A Code of Practice 2013. The Commissioner states that it is the responsibility of each organisation working in or on the road network to undertake a site specific risk assessment before works are carried out. The code requires that this risk assessment be dynamic, and updated to reflect changing circumstances during operations.
The UK Government has also published guidance and whilst the content on ‘streetworks’ does not apply in Scotland, the rest of the guidance makes clear that landowners and occupiers of land who have entered into agreements with providers of telecommunications networks should continue to meet their obligations under those agreements.
Of course, there are elements of our mobile network expansion which is more closely aligned with traditional construction. Mobile UK is co-ordinating our engagement with the sector, as they consider the Scottish Government’s construction guidance and standard operating procedures.
All employers are by law required to carry out risk assessments and must engage employees in that process, through trades union or workforce representatives. Given the current risk to public health from Covid-19, self-employed persons should also carry out a risk assessment. The information on how to carry out a risk assessment is on the Healthy Working Lives website and includes sample assessments for different types of situations including working in other people’s homes.
Further advice on preventing transmission of COVID-19 along with other good hygiene practice amongst employees, customers and all those on business premises is available from Health Protection Scotland. If an employee becomes ill at work with Covid symptoms you should follow the Test and Protect guidance.
If workers think their working conditions are unsafe, they have rights under Section 44 of the Employment Rights Act (1996). For workers who are members of a trades union, they may wish to speak to their trades union representative.
Organisations should suspect an outbreak if there is either:
Two or more linked cases (confirmed or suspected) of COVID-19 in a setting within 14 days - where cross transmission has been identified; or
An increase in staff absence rates, in a setting, due to suspected or confirmed cases of COVID-19.
If an organisation suspects a COVID-19 outbreak, they should immediately inform their local NHS board Health Protection Team (HPT). The organisation may be then contacted by them, as they may get information from NHS Test & Protect or other sources.
In the event of an outbreak:
- continue to follow 'General Guidelines' to reduce risk, as detailed above.
- the local Health Protection Team will undertake a risk assessment and conduct a rapid investigation. They will advise on the most appropriate action to take.
- staff who have had close contact with case(s) will be asked to self-isolate at home. In some cases, a larger number of other staff may be asked to self-isolate at home as a precautionary measure. Where settings are observing guidance on infection prevention and control, which will reduce risk of transmission, the local health protection team will take this into account in determining whether closure of the whole setting will be necessary.
- depending on the risk assessment outcome, the Health Protection Team may establish an Incident Management Team (IMT) to help manage the situation.
- the Incident Management Team will lead the Public Health response and investigations, and work with the organisation to put appropriate interventions in place.
To control an outbreak the Health Protection Team and Incident Management Team will work with the organisation to put appropriate interventions in place. These will generally include ensuring that the preventive measures described in 'General guidelines to prevent spread of COVID-19' (detailed above) are fully implemented. Other measures may include:
- cleaning in the setting: for cleaning and waste management, refer to guidance on cleaning in non-healthcare settings guidance on cleaning in non-healthcare settings for maintaining hygiene.
- consider wider testing of affected population and staff.
- information: ensure that staff (and other relevant people) are aware of what has happened and the actions being taken.
- closure: may be done following advice from the Health Protection Team and Incident Management Team or the business may make their own decision on closure ahead of this advice as a precaution or for business continuity reasons
The Health Protection Team or Incident Management Team will declare when the outbreak is over.
Test and Protect and self-isolating
Test and Protect, Scotland’s approach to implementing the 'test, trace, isolate, support' strategy, is a public health measure designed to break chains of transmission of coronavirus (COVID-19) in the community.
Staff, visitors or users who develop symptoms consistent with COVID-19 must follow the Test and Protect guidance.
This guidance includes advice for employers. Those who do test positive for COVID-19 will be asked to continue to self-isolate for 10 days following symptom onset and their close contacts, identified through contact tracing, will be asked to self-isolate for 14 days.
Until they have been tested and told if it is safe to leave home, organisations should make sure that staff do not have to, or feel that they have to, come in to work. Workers can request an isolation note through NHS Inform.
People who have tested positive for the virus will need to self-isolate for a minimum of 10 days. NHS contact tracers will interview them and get in touch with people they have been in close contact with, and tell them they must self-isolate for 14 days. If organisations are informed by a contact tracer that they should isolate, organisations should help them to do so straight away. They may feel well, as the virus could still be incubating when they are asked to isolate. Some people who are asked to isolate may not become unwell, but they must stay at home and self-isolate for the full 14 days. Organisations can ask them to work from home if they are able to and they are not unwell. Organisations should not ask someone isolating to come into work before their period of isolation is complete, in any circumstances.
Where Infection Prevention Control measures have been utilised such as protective screen or use of PPE the contact tracer will conduct a risk assessment to identify contacts at risk. The priority is to public health in order to break the chain of transmission of COVID-19.
See Scottish Test and Protect website and NHS Inform for further health advice and information including on duration of self-isolation.
Updated 4 January 2021
We have added additional advice which is specific to going to work from 4 January 2021. Due to what we now know about the higher transmissibility of the new variant, the CMO is now writing to people on the shielding list to advise you that if you cannot work from home, you should not attend work for as long as these additional protective measures are in place in the area where you live or work.
This additional advice on going to work does not apply to areas that remain at level 3. If you live or work in a level 3 area, you can continue to go to work if the workplace can be made safe.
While level 4 restrictions across mainland Scotland increased protection for those who are at most clinical risk, we have considered what additional measures we can advise to reduce the increased risk of transmission of the new strain of coronavirus and further reduce opportunities for infection. One of the key areas we can focus on is the workplace.
- Our additional advice to those who had previously shielded has not changed. Please consider all of the advice in the table and think about what is right for you