WHO criterion 5: Manage the risk of exporting and importing cases from communities with high risks of transmission
Importation of new COVID-19 cases represents one of the greatest threats to continued control of the virus - that is why the Health Protection (Coronavirus) (International Travel) (Scotland) Regulations 2020 regulations continue to be so important. There are two measures within the regulations (unless an exemption applies): the requirement to provide contact details when travelling to Scotland and the requirement to self-isolate for 14 days on arrival to Scotland. Guidance on these regulations is available here.
Scottish Ministers have continued to review the health measures closely over the last three weeks and have assessed that there remains a requirement for these regulations to remain in place. This decision was relayed to the Scottish Parliament on Monday 31 August via a Government Initiated Question (GIQ). The next review point is Monday 21 September.
We continue to assess country specific exemptions (often referred to as air bridges or travel corridors) on a weekly basis. The data we use to establish an evidence base for consideration is provided by the UK Government and comes through a Public Health England (PHE) risk assessment (outlining where countries sit within the Red, Amber, Green risk rating) and Joint Biosecurity Centre (JBC) analysis which provides data on the number of cases in the countries. Changes are made with great urgency to ensure public health is not compromised in Scotland. We are not required to wait for the formal review date to make these amendments to the regulations.
The data provided by the JBC and PHE is owned by the UK Government. We continue to urge the UK Government to publish the data transparently and to provide evidence of effective decision making.
Country specific exemptions
On Friday 10 July, the Scottish Government exempted 57 countries and territories (plus 14 UK overseas territories) from the requirement to self-isolate on arrival in Scotland. These countries and territories were deemed to be low or moderate risk, with lower infection rates than Scotland. All arrivals and returnees from exempt countries are still required to provide contact details through the Passenger Locator Form (PLF) and Public Health Scotland use this information from the PLF to contact the individual if they, or someone they have have travelled with develops coronavirus symptoms.
If there is clear evidence of risk we will take action to remove a country or territory from the exemption list if necessary to safeguard public health. The decision to remove a country must be made on public health grounds. There have been a number of changes to the country exemptions list since 10 July. Spain and France were removed from the list on 26 July and 15 August respectively, and a number of other countries have been removed as outlined in previous updates. There have been fewer additions to the list, including Portugal on 22 August.
Since the previous update, there have been further additions and removals to the exemptions lists. JBC/PHE data, week commencing 17 August, identified significant concerns regarding the rise in cases in Austria, Croatia, Switzerland and Trinidad & Tobago. Across the four nations there was agreement to remove Austria, Croatia and Trinidad & Tobago, and the Scottish Government also decided to exclude Switzerland due to concerns over the increase in its weekly virus cases in comparison to Scotland. The other UK nations decided not remove Switzerland, although they have since aligned with the Scottish Government position. There was also four nation agreement to add Portugal to the exemptions list, as evidence over a number of weeks has highlighted a reduced number of cases across the country. These changes were implemented on Saturday 22 August. The following week the Czech Republic and Jamaica were also removed from the exemptions list due to rising rates of the virus and Cuba was added to the list as the evidence identified a consistent trend in reduced cases. These changes were implemented on Saturday 29 August.
In the week commencing 31 August significant issues were raised relating to high numbers of imported cases from Greece into Scotland and the wider UK. Scottish Ministers subsequently considered that Greece represented an extraordinary situation and agreed to remove Greece from the exemptions list on Thursday 3 September.
Further concerns were raised in the full JBC/PHE analysis regarding the virus rates in Portugal and French Polynesia. Ministers therefore assessed that Portugal and French Polynesia represented a significant risk of imported transmission and agreed to remove both countries from the exemption list from 5 September.
We will continue to closely monitor the situation and if the evidence suggests an exempt country may provide increased risk, we will not hesitate to reinstate quarantine arrangements, as has been the case with several countries. It is clear that the situation can change very quickly and immediate action is likely to continue to be required – the last weekly cycle has shown a divergence in approach which can occur as the four UK Governments make their own decisions based on the balance the risk of imported transmission in relation to their own virus rates.
We have aligned with the UK Government on some changes to the regulations relating to maritime workers, updating the sporting competitions which are applicable for exemption and a small change to the Passenger Locator Form. It is considered that these amendments do not negatively impact on the rationale behind these regulations but we continue to review these exemptions as part of our ongoing review process and will not hesitate to make changes if evidence suggests that any of the current exemptions pose a risk to public health. We continue to work with partners to ensure there is appropriate advice and guidance available to sectors who have exemptions from the requirement to self-isolate. Further exemptions for consideration have been provided to officials that are being reviewed; it is likely that we will adopt a cautious approach to any further exemptions.
Border Force continue to carry out spot checks on arrivals at the border to ensure they have completed the Passenger Locator Form. Work continues to improve and streamline the Passenger Locator Form which should allow for greater compliance.
Police Scotland can be notified of potential breaches of the requirements under International Travel regulations through two main routes: from members of the public using the 101 number and through a referral process from Public Health Scotland. As of 26 August, published data shows that Police Scotland made 168 referrals to the Home Office to check on the self-isolation and exemption status in relation to reported breaches of the requirements and have issued one Fixed Penalty Notice. As with the domestic lockdown measures, Police Scotland's proportionate operational approach is based on the 4 Es, where officers, Engage, Educate, Encourage and only Enforce if absolutely necessary.
Passenger arrivals into Scotland are provided by the Home Office to Public Health Scotland (PHS). PHS then take a sample of those passengers who are required to quarantine and pass the data to NHS National Services Scotland, which runs the National Contact Tracing Centre. Up to the end of July, the National Centre has been averaging around 600 contacts per week. Up to 6 September 5,323 individuals have been contacted so far, with 4,085 successful contacts made and a further 389 in progress. Scottish Ministers have agreed to provide further resource to Public Health Scotland to enhance capacity for follow up calls offering advice and guidance to people self-isolating on return. Public Health Scotland can also refer concerns they have to Police Scotland for further investigation. For the period 31 July to 23 August, Public Health Scotland has confirmed that the details of 103 passengers were passed to Police Scotland under these arrangements.
Internal border (Common Travel Area)
There is a risk that the virus will be exported from communities with higher prevalence in Scotland and elsewhere in the UK to communities with lower prevalence. Tourism to Scotland has now opened up (including all holiday accommodation), which means that citizens from other parts of the UK can now travel to Scotland.
A practical approach for managing transmission to and from communities with high rates of transmission in the rest of the UK is to rely on systems for instituting local lockdowns being developed in each country. The UK Government on 17 July published a COVID Contain Framework for local decision making with statutory guidance which sets out greater powers for councils to take action to address local outbreaks. This includes clear instructions that people should not travel outside of lockdown localities in England. On 31 July, the UK Government introduced stricter lockdown rules for parts of northern England following evidence of increased transmission. This should have the effect of limiting travel from those areas to Scotland (and anywhere else).
In the event of a significant local outbreak, Ministers have regulation-making powers under the Coronavirus Act 2020 that would allow Ministers to re-impose lockdown restrictions on a local or regional basis within Scotland if necessary, thus managing the risk of exporting cases from high risk communities. Following an increase in the number of cases in the Aberdeen City Council area, restrictions on travel, indoor gatherings and hospitality were introduced on 5 August. Restrictions were introduced in Glasgow, East Renfrewshire and West Dunbartonshire from 2 September and extended to East Dunbartonshire and Renfrewshire on 7 September.
Scotland is developing a responsive system of community surveillance for COVID-19 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 various 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 supports 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.
Phase 3 brought further gradual re-opening, resumption and scaling up of economic and social interactions. Those changes were 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 for no longer than they are deemed proportionate. However this gradual easing of restrictions increases transmission risk. Cross-border movements of people and goods will continue and increase as we ease restrictions. Consequently, it is essential that we reduce importation risk to an acceptably low level.
On the basis of the evidence summarised above, the assessment is that this criterion has been met at this review point. However, continuing vigilance is required around the management of importation risk.
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