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 Friday 9 October, via a Government Initiated Question (GIQ). The next review point is Monday 2 November.
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) and Joint Biosecurity Centre (JBC) analysis and risk assessment which provides evidence on a range of factors including incidence rates; test positivity; testing rates; deaths and hospitalisations and imported cases. Any removals from the list 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 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 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.
Since the previous update, there have been further additions and removals to the exemptions lists. The week beginning the 28 September all four nations removed Turkey, Poland and Bonaire, St Eustatius and Saba from the exemption list on the basis of evidence provided by the JBC suggesting of a significant rise in cases and increase in test positivity. In addition the Scottish Government added Madeira and the Azores to the exemption list.
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 – there have been times where there has been a divergence in approach across the four UK Governments as they make their own decisions based on the balance the risk of imported transmission in relation to their own virus rates.
The UK Government announced a number of changes to sectoral exemptions which came into force on 26 September. The Scottish Government will continue to assess the sectoral exemptions and where it is considered that there is a clear basis for an exemption and that the changes would not negatively impact on the rationale behind the regulations or present a risk to public health then we will make changes. Similarly we will continue to review all of the 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 that there is appropriate advice and guidance available to sectors who have exemptions from the requirement to self-isolate.
Work continues to improve and streamline the Passenger Locator Form which should allow for greater compliance. We are in regular contact with Border Force through weekly updates and with any operational challenges they are experiencing.
Passenger arrivals into Scotland are provided by the Home Office to Public Health Scotland (PHS). Public Health Scotland contacts all individuals via email, who require to self-isolate, on return from a country that is not exempt from quarantine. The National Contact tracing centre subsequently contacts a sample of those individuals.
Up to 11 October 10,904 individuals have been contacted so far, with 8,036 successful contacts made. Further resource is now in place 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.
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. (Note that this was the position at the point of the 15 October review.)
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. Further consideration should be given to the effectiveness of existing mechanisms to control intra-UK importation, particular if there is significant regional variation in prevalence.
On 14 October the First Minister advised against non-essential travel to those regions in the North of England which had been placed on very high (Liverpool City Region) or high alert levels. The First Minister also advised against travel to Blackpool because in the previous month 180 people with Covid reported that they had recently gone to Blackpool, 94 in the previous week. Note – this had increased to 286 in the previous month by the 15 October. There was also concern that football fans were planning to travel to watch the Celtic vs Rangers match in pubs in Blackpool around the match date on 17 October.
Linked to the advice to avoid high prevalence areas in the North of England was their growing incidence rate. Liverpool which has been placed on very high alert had an incidence rate of 634.7, which was significantly higher than the central belt areas in Scotland which were placed on enhanced measures on 10 Oct – Lothian (127), Lanarkshire (263), Forth Valley (94), Ayrshire & Arran (148) and Greater Glasgow & Clyde (227).
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 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.