4. Suppressing the virus
As seen from the clinical evidence, as we have cautiously re-opened society, the virus has taken advantage of opportunities to re-emerge and we have had to respond to a growing number of outbreaks. We have made changes at a pace and level that we think is right and safe for Scotland, and must ensure that we are in the best position to continue to do so. This means learning from our experiences to date, listening to and supporting people across Scotland whose lives have been impacted by this crisis, and ensuring the necessary infrastructure is in place to support people, businesses and other organisations to do their part.
This chapter sets out how we will do this by taking a levels-based approach to applying protective measures, the actions we will put in place to support that, and our wider strategy for suppressing the virus.
A 'protection levels' approach
We have always been clear that the current phase of the Route Map would require a continuing focus on containing outbreaks and responding to different conditions in different parts of the country. So far we have taken a tailor-made approach to the application of geographically-targeted protective measures, responding to the specific circumstances of each outbreak with individually tailored packages of interventions.
This approach has served us well, and helped make good progress in suppressing the virus, but we have also learnt from it – both in how we communicate the specific measures in place in different areas, and in terms of decision-making, guidance, regulation and enforcement. Looking ahead to the challenges of the coming months, it is clear that a refreshed approach is needed.
We now propose to move to a strategic approach to outbreak management based on five levels of protection, each with graduated packages of measures to reduce transmission of the virus, that can be applied locally or nationally, according to the evolving patterns of infection and transmission.
These remain a draft at this stage, ahead of detailed stakeholder engagement to finalise the contents of the tables, setting out the types of protections we envisage would be required at each level.
This approach will provide a more easily understood framework for managing outbreaks and allow rapid but proportionate responses to be taken, either locally or nationally, using a range of measures. This will aid decision-making, communication and implementation of protective measures. It will also allow individuals, families, businesses and services to better understand, anticipate, and prepare for the measures that might be introduced, as well as showing how protective measures can and will be eased where appropriate. As we have throughout the pandemic, we have sought to work closely across the four nations, aligning action where necessary but recognising the specific circumstances for Scotland may mean we need to do some things differently to best suppress the virus.
The protective measures in the higher levels, which are more restrictive, are designed to bring the rate of the transmission of the virus down quickly, so they are intended to be in place for a more limited period of time than the measures in the lower levels. It is also important to acknowledge that even at level zero – the baseline – we would expect some measures to remain in place. This is an honest reflection of the fact that we expect to be living with the consequences of the virus for some time.
We will take decisions about which levels to apply in which area, when to escalate if that is needed, and when areas can move down to a lower level, on the basis of advice from local Directors of Public Health and Public Health Scotland, through the National Incident Management Team, and the assessment of our own senior advisors against the four harms. We will also engage with our local authority partners prior to making decisions, whose support is vital to the success of this approach, and delivery bodies on whom we rely to implement and oversee the measures.
Once the initial levels have been set for each local authority area across Scotland, levels will be reviewed weekly in the light of the evolving situation to decide whether levels should be maintained, increased, or reduced. However, while levels will be reviewed weekly, areas are likely to move between levels less frequently than that. Once set, levels are likely to be in place for two to four weeks at least, to give time for the effect of changes to be observed in data about the virus, and to ensure that the incidence and prevalence of the virus are responding to measures put in place to suppress it.
Decisions on levels, both initially and on review, carry significant consequences, for the communities they affect and for Scotland as a whole, in relation to the "four harms" caused by the virus: its direct impacts on health, and the effect of measures to suppress it on wider health and care, society, and economic activity. In taking and reviewing these decisions, we will exercise care and judgement, applying the approach and principles set out in the Scottish Government's COVID-19 Framework for Decision-Making. In particular, protective measures will only be applied where and for so long as they are justified, necessary and proportionate.
These decisions require judgement to be applied to all the facts and considerations relevant at the time they are made, and in relation to the area directly affected and for Scotland as a whole. We are committed to ensuring that decisions will always be informed by data and analysis. To guide us, we will be monitoring key indicators on the state of the epidemic on a daily and weekly basis and taking changes in these into account when considering whether escalation is needed or whether an area can move down a level. These indicators may change over time as the virus develops and new data becomes available and we will keep it under review and open to scientific and clinical views. We will also set out more detail of the ranges we will consider as we take initial decisions on the application of the levels framework. However, the indicators are likely to include:
- The number of cases per 100,000 people over the past seven days, including for particular age groups of the population
- Forecasts of the number of cases per 100,000 over the fortnight ahead
- The percentage of tests that are positive over the past seven days
- Current and projected future use of local hospital beds, compared with capacity
- Current and projected future use of intensive care beds, compared with capacity
These indicators will be considered as part of a rounded assessment of the facts and circumstances relevant to each decision. We will publish, with each decision, a statement of the reasons for it.
We already provide a range of daily updates on national data and trends on our web page Coronavirus (COVID-19) Daily Data web page, and our modelling work Coronavirus (COVID-19): modelling the epidemic; and we publish a dashboard which brings together both data and evidence on the broader impacts of COVID-19.
The levels framework shown in Annex 1 remains draft at this stage – in finalising it, we want to ensure there is discussion and decision across all of our valued partners to what it contains, and how it will be applied.
We will undertake a short period of detailed engagement with our local authority partners, stakeholders, business and trade unions, enforcement and wider civic society, on the detailed design, operation and implications of our new approach.
To ensure proper parliamentary scrutiny, a final framework will also be subject to the views of the Scottish Parliament. We will engage with all political parties on the detail of the framework, and put this to a debate and vote in Parliament on 27 October.
We intend to apply the new levels system from 2 November.
Developing and deploying the capacity and capability of the Test & Protect system
As we move into this new system of levels, Test and Protect will remain a central element of our strategic response, ensuring we can quickly identify those who have COVID-19, and inform them and their contacts of the need to self-isolate to stop the virus spreading further in their communities.
Testing, on its own, does not reduce transmission. The whole system – from the moment a person first develops symptoms, to the moment the people they may have transmitted the infection to are instructed to self-isolate – has to respond quickly to be effective. This means working with the UK Government (as well as our own NHS Scotland laboratories) to ensure turnaround times for testing are as fast as possible – optimally within 24 hours to enable swift contact tracing to commence.
Our efforts to strengthen Test and Protect, as a public health intervention, are aimed at ensuring that each critical part of the system works together to reduce transmission. We must also recognise that, while Test and Protect is working well, it will be most effective when levels of infection are low, and its success is ultimately dependent on all our actions to reduce contacts, keep our distance, wash hands, and wear face coverings, especially indoors.
We will intensify our efforts to ensure the system is fast and effective in each of its three core component parts outlined below – from symptoms to testing; from testing to contact tracing; and from completed contact tracing to supported self-isolation.
We will encourage people to get tested as soon as they have symptoms. The Scottish Government will do this through our strengthened public health messaging, stressing the need to isolate and book a test as soon as symptoms are experienced. We will also look to businesses and others to help by encouraging employees to isolate and get tested as soon as they have symptoms and not to take the risk of transmitting to others. And we will continually improve access to testing – for example, increasing the number of walk-through test centres and deploying new technology.
The sooner someone isolates and is tested the quicker we can begin contact tracing to isolate their contacts – reducing spread of the virus. Waiting a day or two to see if symptoms pass means a delay to starting the testing and tracing system and risks spreading the virus.
There are two routes for sample taking and laboratory processing in Scotland – NHS Scotland routes and the UK Government network, including Lighthouse Laboratories. Our plans to develop the testing element of Test and Protect in the next three months are focussed on building capacity within NHS Scotland and deploying expansions in UK Government testing capacity and capability to its maximum effect in Scotland. Results from both systems feed in to our Test and Protect system and we are reliant on both routes operating efficiently and turnaround times being as fast as possible to make Test and Protect work.
Expansion of lab capacity in Scotland, over and above existing NHS Scotland lab capacity of up to 10,300 tests per day, is being built through the development of regional hubs and commercial and partner nodes:
- Regional Hubs – there will be three regional hubs in Scotland (based in NHS Grampian, NHS Greater Glasgow and Clyde and NHS Lothian). These will be brought on stream through a phased approach between November and December and will offer an additional 22,000 tests per day.
- Additional laboratory capacity from commercial and partner nodes will provide capacity of almost 3,700 tests per day by December.
The infrastructure required to support these developments, including recruitment of staff, is being established to ensure optimal use of the capacity as it becomes available.
As set out in the recent Clinical Review of the Testing Strategy, to ensure robust and realistic planning assumptions we are taking a cautious approach to planned UK Government laboratory expansion, reflecting the complexities involved in delivering significant laboratory capacity. Based on the latest forecast figures, the planned expansion of overall testing capacity to 65,000 tests per day by winter is on track.
These increases in capacity will primarily be required to meet demand from people with symptoms of COVID-19 – both those infected with COVID-19, and those with colds or flu, or other illness with similar symptoms. Total demand based on currently eligible groups – testing people with symptoms, testing for patient care, and regular testing of care home staff (including those in non-elderly adult settings) and groups of NHS staff – is currently estimated to be in the region of 54,000 tests per day. Therefore, we will be able to use our additional laboratory capacity to expand our use of testing among people who do not have symptoms. The unanimous agreement of our clinical and scientific advisers, published in the Clinical and Scientific Review of the Testing Strategy, is that the overriding priorities of testing capacity are symptomatic demand and clinical care, with prioritisation of further capacity built in this next phase to be focussed on protecting those most vulnerable to severe harm.
Following this advice, as a first step in expanding our use of testing among people who do not have symptoms, we will introduce testing for all people being admitted to hospital in an emergency as soon as possible.
In line with clinical and public health priorities, we will also extend routine weekly testing of asymptomatic groups in a way which focusses on protecting those most vulnerable to the most harm, including those at highest risk of mortality. Regular testing of this type sits alongside other measures such as the use of PPE to reduce the risk of staff who have COVID-19, but do not have symptoms, transmitting the virus to those they are caring for.
We will therefore extend routine testing to groups of health and care staff who visit care homes delivering close contact personal care such as community nurses, and we will introduce testing for visitors to those who live in care homes where this can add an additional layer of risk mitigation to enable safe visiting to continue. Our targeted programme of regular testing of NHS staff to protect patients in hospital will be broadened in scope to cover more groups of staff. We will also extend testing to staff who provide care at home for those most vulnerable to harm.
We will also undertake more testing of people who do not have symptoms to support outbreak management, and address areas where we are concerned about transmission. This includes undertaking more testing of close contacts of confirmed cases when recommended by our local health protection teams and more intensive use of other asymptomatic testing in outbreaks – for example, outbreaks focussed on a particular workplace. We will also continue to keep under review how testing could be used alongside other measures to reduce transmission in student populations, including encouraging and supporting the use of asymptomatic testing as part of the response to outbreaks in student halls of residence. We will also build on the delivery of the first 11 walk through test sites to continue work to support symptomatic students to access testing rapidly.
Contact tracing is a key part of how we keep the virus under control and ensuring consistent fast turnaround times in test results is critical to enable contact tracing to begin as quickly as possible. This stops potentially infectious contacts spreading the virus further. We will work with the UK Government to drive down turnaround times in Lighthouse Laboratories. We will move care home testing to NHS Scotland Laboratories, improving turnaround times and enabling swift action to remove any asymptomatic care home staff who test positive from the workplace, preventing outbreaks.
Test and Protect is performing well, even in the context of rising prevalence. Over 27,000 cases have had contact tracing successfully completed since 28 May, and from these cases 117,939 contacts have been traced. Since the Case Management System went live on 22nd June, 91.9% of people with a positive test were able to be contacted, as well as 93.8% of all contacts. In the four-week period from 21 September to 18 October, more than 17,000 individuals with a positive test – or 91% – successfully completed their phone interview within 48 hours. For the same period almost 14,000 cases, or 74.7% of the total, were completed within 24 hours. This means their contacts were identified and instructed to self-isolate – the critical action which stops the virus spreading. Contacts for which mobile numbers are available are notified to self-isolate by SMS immediately following the completion of the case interview, ensuring notification happens as quickly as possible.
We initially identified 2,000 people who could be deployed as contact tracers and have been increasing permanent staffing levels to manage demand. We will continue to prioritise resourcing contact tracing as a key measure to break the chains of transmission and suppress the virus. NHS Boards are required to have in place arrangements to ensure we have capacity to deal with the demand. We have provided NHS Boards with £19 million to ensure they can retain sufficient contact tracing capacity while remobilising their services, and Boards' staffing plans are under regular review to ensure capacity is maintained. Additional resilience also continues to be in place at a national level in the form of the National Contact Tracing Centre run by NHS National Services Scotland. The contact tracing service has been sufficiently staffed throughout the summer, rapidly responding to increases in demand. We expect the workforce to continue to flex and adapt as we head into winter.
We also continue to learn from experiences with the system to date, identifying ways of increasing the efficiency of the system and streamlining processes. Through these improvements, such as streamlining case interviews and expediting digital improvements to the case management system, we continue to enhance our contact tracing model to ensure it is robust, responsive to demand and swift in informing those who need to self-isolate to stay indoors.
This capacity and capability is strengthened further through our proximity tracing app – Protect Scotland – which over 1.5 million people have downloaded. As part of its continued development, further automation and improvement is planned, so app users can be alerted as quickly as possible if they have been in close proximity to someone who has tested positive. We are also working to ensure interoperability with contact tracing apps in other parts of the UK and Ireland, and will have the technology required in place to enable this by the end of October. We are also exploring options to connect with apps in Europe and elsewhere in the world to support future travel.
Support for self-isolation
We know that self-isolation can bring significant hardships. The efficacy of the testing and contact tracing programme in reducing transmission can only be realised by achieving broad compliance with self-isolation guidance which in turn requires people to have confidence they will be supported. A vital aspect of ensuring high rates of population wide compliance is removing the barriers that large numbers of people face in attempting to adhere to self-isolation guidance.
We have introduced the Self-Isolation Support Grant, providing people on low-income benefits who are asked to self-isolate, and in employment they cannot carry out from home, with a £500 grant payment. In addition to a National Assistance Helpline, the Self-Isolation Assistance Service, funded by the Scottish Government and delivered by local authorities, provides a pro-active triaging service, to consider the support requirements of people self-isolating who are most likely to require support and engage services locally to meet these needs.
Both the Helpline and Assistance Service are targeted to groups of people most likely to require support, but to continue to improve compliance rates population wide, further expansion of support services is required for a wider range of people. To ensure we provide the necessary support measures to enable high compliance and suppress the virus, we will:
- Provide further investment in the expansion of the Self-Isolation Assistance Service to a broader range of people
- Develop novel, targeted measures to address specific and discrete barriers to compliance
- Consider the capacity of community volunteering to provide additional resource for practical support interventions such as deliveries of food and medication and remote emotional support
- Work with employers and trade unions to help employees have the confidence and support to self-isolate and get a test as soon as they have symptoms, or are asked to self-isolate by Test and Protect, without detriment to their employment, pay or conditions
Hospital Acquired Infection (HAI)
We have acted quickly to reduce the risk of hospital associated transmission of COVID-19, particularly focusing actions on the most vulnerable to harm. All staff must adhere to infection protection and control (IPC) principles at all times, and we will continue to make sure that access to PPE and expanded COVID-19 testing offer additional layers of protection. We established the COVID-19 Nosocomial Review Group to consider evidence and provide recommendations, and have ensured that IPC measures are integral to Health Boards' remobilisation plans.
All healthcare workers should be tested where there is an outbreak of COVID-19 and, to further reduce the risk of transmission and infection in hospitals, we have introduced weekly testing of health care workers in high-risk specialties. This includes regular testing of all hospital staff working in specialist cancer services, as well as those who provide long-term care for the elderly, and those working in long-stay mental health facilities. The testing of healthcare workers is kept under active review, informed by expert advice.
We are working to introduce testing of all emergency admissions to our hospitals and the serial testing of in-patients should continue to be assessed by Boards locally based on local epidemiological evidence. Pre-admission testing of patients undergoing elective surgery is already in place – reducing the risk of poor outcomes in patients with unsuspected COVID-19 infection, and supporting reduction of hospital acquired infection by reducing the introduction of COVID-19 into hospitals.
As we enter winter 2020, it is essential that we both reduce the risk of a major second wave of COVID-19 and plan for the possibility of an increased need for PPE, ensuring we have the necessary supplies in place to ensure the safety of people using services and staff. We will shortly publish a new PPE Action Plan across a range of areas, including building up Scottish supply chains, future planning, and ensuring sufficient supplies.
Homeworking as a public health measure in response to the pandemic has been a crucial factor in mitigating the transmission of the virus amongst the general population. Until it is deemed safe for workplaces to reopen, working from home and working flexibly will remain the default. We need strong employer and sectoral support on homeworking to help drive Scotland's economic recovery and continue to mitigate the transmission of the virus. Many employing organisations had to implement homeworking quickly, as an immediate response to the pandemic and their contribution to the public health effort must be recognised as should the workers who are practising homeworking. Those who are working from home are making it safer for those workers who cannot work from home – it is an effort we must continue. Where homeworking is not possible, businesses and organisations are encouraged to manage travel demand through staggered start times and flexible working patterns.
It is critical that social care support is maintained as far as possible to ensure the wellbeing, safety, dignity and human rights of people, and we continue to protect all people in receipt of social care from contracting the virus by taking firm action supported by robust clinical guidance for the sector.
The integration of health and social care has played an invaluable role in our response to the pandemic – ensuring people can receive the care they need, in a setting that is right for them, while protecting the capacity of our hospitals. We have already allocated £150 million for social care as part of our additional COVID-19 funding this year to help the sector mitigate the financial implications of the pandemic and ensure the remobilisation of packages of support. To avert and manage outbreaks of infections in care settings we are taking the following actions:
- Continuing to develop new and specific infection prevention and control (IPC) guidance for care homes and community care to support training and increased resilience through the Clinical and Professional Advisory Group as required
- Meeting the additional costs incurred by Health and Social Care Partnerships and providers for PPE to support access to PPE for staff, visitors and, where necessary, recipients of care over the winter period
- Ensuring adequate access to appropriate testing meaning staff in adult care homes will continue to have a weekly test to reduce the risk to residents, staff and visitors. We will prioritise testing for those across the wider sector as testing capacity becomes available
- Publishing a comprehensive Adult Social Care Winter Plan to deliver maximum protection for people who use social care support in residential and community settings and in their own homes, and to those who provide that care, including unpaid carers
We also recognise that the wellbeing and quality of life of people who provide and use social care remains a priority. For those within care home and other adult residential settings, visiting guidance will continue to be reviewed, taking account of local outbreaks and circumstances specific to each setting to maximise the amount of quality time families can spend together without compromising safety.
To ensure the wellbeing, safety, dignity and human rights of people are protected and enabled, we also continue to work with Health and Social Care Partnerships and Local Government to ensure that all social care packages are delivered to meet the needs of each individual.
To ensure we learn from the lessons of the pandemic, and put in place the best system for the future, an Independent Review of Adult Social Care is currently underway. The Independent Review is taking a human-rights based approach and will comprehensively review all aspects of adult social care including how it is organised, commissioned, regulated and funded. It will report in January 2021 and will recommend improvements to adult social care in Scotland, primarily in terms of the outcomes achieved by and with people who use services, their carers and families, and the experience of people who in it.
Compliance, Behaviour, Enforcement
Suppressing the virus means asking a lot from individuals, businesses and communities. It is difficult, but our actions can make a significant difference, and success depends on all of us. While no one can guarantee that we won't get COVID-19, or pass it on, we can all act to reduce our own risk, reduce the risk to others, and keep our communities safer. Together with our partners, we will support people, businesses and organisations to do the right thing. We will always strive to:
- Be clear
- Make it possible
- Build a team approach
We want people to be aware of and clearly understand the measures we are asking them to take to help suppress the virus and how. We also want people to be clear about how, by maintaining and changing their behaviour, they can help to keep the number of coronavirus cases low. While weekly polling data through the pandemic has shown evidence of strong knowledge and support, self-reported compliance and confidence in the approach to decision making has fallen. The three main reasons given for not complying with the protective measures are: (i) difficulty from a practical point of view; (ii) not agreeing in principle with measures; and, (iii) finding them difficult from an emotional point of view. As we develop new messages, we will seek to address these specific barriers to compliance, and find ways to help people comply.
We will continue to communicate clear public health guidance and explain the rationale behind the requests we are making of people. Significant numbers of people continue to use existing channels to access information on the virus. As of late September, around half of the population said that they consistently used the First Minister's briefing as a regular source of information, and during one week in August, Scottish Government social media posts reached over 4.5 million people. Our evaluations show people have high levels of trust in Scottish Government communications and that there is a clarity to the messages.
However, we also know public engagement can slip, that people are becoming tired as the pandemic continues, and with it adherence to what is needed may be reducing. As we move to a new levels approach, it is important we keep communications under review and ensure people have the necessary information to play their part. We will listen to people, monitor the latest consumption habits and media trends, and ensure delivery via channels that work for all segments of the population. As part of this, we will work with minority ethnic communities and organisations to ensure we get our messaging right and that it's delivered in the right way. And local authorities will play a leading role in ensuring the right communications are provided in the right way, in the right place, dependent on local circumstances.
We will further invest in how people can access information, through options such as helplines, live chats and a postcode level checker so that they can access the information that addresses circumstances and location, and in the way they want to access it. We will undertake a review of guidance and associated products, rationalising and coordinating guidance across Scottish Government functions and will take a more strategic and holistic view of that guidance. And we will undertake new marketing campaigns which will focus on educating and persuading everyone to follow the current protective measures, including getting tested and self-isolating as soon as symptoms develop, where regulations and guidance have changed, and when there are new enforcement measures in place.
Make it possible
We will support people when they need to self-isolate. As noted previously, we have introduced significant financial and practical support for people who need to self-isolate, and ensure they are supported to do so, including by their employers.
We will ensure the necessary support for those in education. In higher education, there will be appropriate support for students self-isolating and in quarantine. Universities Scotland have announced a Consistent Core of Care package which commits every institution to providing regular check-ins for self-isolating students, help with food and groceries, cleaning supplies, and internet access. In schools and nurseries, we will continue our partnership approach to decision making with local authorities as the education authority in each area. We will work locally and nationally with local government politicians to ensure that schools and nursery based education is safe, effective and focused on the needs of the child and their family. The Care Inspectorate continue to regulate childcare settings, and the Health and Safety Executive has undertaken a programme of compliance checks regarding implementation of School Reopening Guidance which they have stated was generally of very good quality. Education Scotland are also developing channels to share good practice that is identified with practitioners to drive more effective implementation of guidance, and we will soon launch a communication and engagement strategy targeted at young people of secondary school age. We have worked with Young Scot to ensure this is age appropriate and that it will encourage greater compliance with school-based mitigations and FACTS when leaving the school grounds.
We will support people to stay safe outdoors, continuing to support outdoor activity that is safe. We will support local authorities to prioritise safe spaces in town centres and urban areas over the winter period, recognising it is important to have a place where we can meet. This has been supported by the £38 million funding for Spaces for People which has supported local authorities to provide extra space for walking and cycling. We have also published the Safe Public Space guidance which we are in the process of updating, and have launched the Scotland Loves Local Fund, giving priority to projects that evidence inclusion and encouraging people to shop local.
We will support people to stay safe while travelling. We have published guidance on how to travel safely on public transport and while sharing a car, if people have to, with others outside their household. We have produced detailed guidance for public transport operators, who have introduced a range of measures to increase cleaning regimes and maintain physical distancing, with some operators introducing apps which help identify how busy services are. We are working in partnership with operators to ensure that compliance on the wearing of face coverings is high and will adapt our communications as evidence emerges. Transport Scotland is exploring a potential pilot for QR code scanning on longer rail and ferry journeys to assist with Track and Trace services, and we are working to determine whether the QR code generator for hospitality venues can be adapted for travel services.
Build a team approach
We will work in closer partnership with communities, businesses and other organisations, trade unions, regulators, NHS, Police Scotland and equality organisations. We will also continue to work to ensure the needs of all children and families are considered in decision making.
We will continue to work closely and in partnership with local government, locally and nationally, taking into account local needs and concerns in the decisions that we make. Local Government is also continuing to share best practice, and to help their communities take the lead in establishing safe behaviours.
Working with our Communities
Community cohesion and empowerment has been a hallmark of the pandemic. We will build on the great work of our communities, including by local authorities across Scotland, who have worked to recruit volunteer banks who have mobilised in their communities to provide important services such as deliveries and support for people socially isolated.
Neighbourhood and community groups will continue to be involved in supporting self-isolation. The third sector has also been central to the COVID-19 response to date and we are strengthening this to help ensure that support can continue. We are providing a £25 million Community and Third Sector Recovery Programme, helping organisations adapt their operations and income generation to increase sustainability, and support communities as they re-start and adapt service and activity delivery.
Working with business on compliance
We will continue to work with businesses and their representatives, to highlight the benefit of them taking a lead in developing solutions to keep the virus suppressed in their premises and practices. Such an approach – with businesses aiming to act in a way that minimises the ability of the virus to spread within their premises and activities – is good for business, for employees, and for suppressing the virus. Many businesses are applying risk assessment and risk management techniques to manage the virus and we know from a number of Incident Management Teams that effective implementation of preventative measures in all workplace settings is key. The first three guidance publications for safer workplaces (construction, manufacturing, retail) were developed with the active support of sector representative bodies, businesses, and trade unions. That created a model which is now our standard approach for all sectors. Based on positive examples in certain sectors, including work by Food Standards Scotland in the meat industry, we will work with sectors to develop appropriate evaluation tools to assess the ongoing effectiveness of the implementation of their measures. We will take that forward with regulators, with business, and with trade unions.
We will work with business organisations and sector bodies to understand the challenges they face in maintaining their operations while keeping employees and customers safe from the virus. We will use this engagement to help shape and enhance guidance to ensure that it is effectively understood and implemented by businesses across all sectors. As part of this, and our levels approach, we will engage with business to ensure critical national infrastructure can remain in place, as we saw during lockdown, and so that businesses providing vital services and deliveries can continue.
We will continue to work closely with business leaders to develop this strategic approach and to support them in communicating key messages that maintain compliance and help to suppress the virus, minimise and mitigate impacts on jobs and the economy, and promote personal and corporate responsibility for the actions which will deliver those ambitions.
Working with the hospitality industry
We will work in partnership with industry to build on the proactive approach we have seen taken across the majority of hospitality. We recognise the significant effort and investment that has been made by operators to adapt their businesses and we want to thank everyone for that. We also recognise that the hospitality sector has been heavily impacted by coronavirus and the measures that have been necessary to combat it, but we want to see safe and viable businesses that the public can enjoy, while observing all required mitigating behaviours. That will continue to require vigilance and high levels of compliance at all times, from operators and the public particularly where hospitality operates at a lower level of physical distancing than other premises or spaces. We will continue to develop our ongoing engagement with industry and compliance partners to ensure this is maintained, and to explore, develop and share best practice so that the sector can stay open, protecting jobs and local services.
Working with the retail sector
The safety of people – customers, employees and business owners – is the number one priority and we are working with retailers to ensure that people can still shop safely. Guided by the need to ensure shopping is safe, we want people to use their local high streets, towns and city centres, to ensure that crowding is avoided, that good hygiene measures are in place and that physical distancing is maintained at all times.
Working with workers
Worker representatives and trade unions have an important role to play in helping us to ensure that we all comply with the rules and guidance designed to keep workplaces safe. The Scottish Government and Scottish Trades Union Congress (STUC) published a joint statement in March, with a refreshed statement in July signed jointly with the STUC, local government and business and third sector partners. This outlined the importance of a Fair Work approach to the COVID-19 crisis, with partners working collaboratively to reach collective decisions on worker protection, public safety, and support to help organisations survive and to keep people in work. The success of our approach rests upon our ability to sustain strong compliance which will reduce the need for further protections.
Listen and understand
We will continue to learn and adapt our approach. We will build on the existing data we gather from polling and from public health and enforcement activity to target our activity. We will also consider what further information can be gathered quickly to help us understand levels of compliance, the public's response to protective measures, and ensure our actions are evidence based. We will explore the use of new and innovative processes – such as citizens panels – to engage people, building on our two open consultations, and will continue to test public views on the effectiveness of our measures through focus groups.
Enforce the law where there is no alternative
We are grateful to all organisations involved in enforcement, including Police Scotland and local authorities, for their continued proportionate enforcement of the regulations, and their use of the 4 E's approach: Engage, Explain, Encourage and, only where necessary, Enforce.
We have used the current period of additional protective measures to review the current fine levels associated with offences under the Health Protection (Coronavirus) Scotland regulations. As we move to the new protection levels approach, we will keep this under review and consider whether it is appropriate to increase the fine level.
We are exploring conferring additional enforcement powers on Environmental Health Officers and Trading Standards Officers, building on direction-making powers put in place earlier this year, to support their intelligence-led approach to enforcement.
Given indoor household meeting restrictions, we are also exploring providing the police with further powers of entry. However, we recognise that there is broad compliance, and willingness to follow the necessary regulations, and will continue to prioritise clear and consistent public guidance and communications.
Tackling importation and spread of the virus
Managing the risk of importing and exporting cases from communities with high risks of transmission is key to suppressing the virus, particularly as we reduce the prevalence of the virus in our communities. For Scotland, this risk has two dimensions: international travel, and travel within the Common Travel Area (the UK, the Republic of Ireland, the Isle of Man and the Channel Islands).
For the majority of international travellers into Scotland, there is currently a requirement to quarantine for 14 days. This means that international travellers, with a small number of exemptions, chiefly related to maintenance of critical national infrastructure, must complete an online passenger locator form and, unless they fall within an exempted category, they should self-isolate for two weeks. Individuals who arrive in Scotland from elsewhere in the UK, having travelled internationally within the last 14 days, must also complete a Passenger Locator Form on arrival in the UK, with this information shared across the four nations.
We publish a list of the limited number of exempt overseas destinations, where the prevalence of the virus and consequently the risk of importation is low. Travellers from these areas are not required to quarantine, although they are still required to complete a passenger locator form. That list is reviewed every week by the Joint Biosecurity Centre (JBC), based on assessment of various factors, and we also take into account information from Test and Protect on cases with an international travel link. These actions mean the risk of importations from overseas is lower now than it was during the summer. However, as the protective measures we put in place begin to reverse the increase in infections, the significance of importation risk will once again grow.
We need to ensure that travel restrictions are achieving their objective and are effective, while recognising the impacts they have on people's civil liberties, the travel industry and wider economy. We are discussing with the travel sector whether alternative approaches, potentially involving a reduced period of quarantine coupled with testing, might deliver similar or better outcomes than the 14 day quarantine period. We are also taking part in the Global Travel Taskforce established by the UK Government to explore alternative options to quarantine as well as continuing to assess the need for sectoral exemptions.
Travel within Scotland, the UK and the wider Common Travel Area (CTA)
We also need to minimise the opportunities for the spread of the virus from areas of high prevalence, whether in Scotland, elsewhere in the UK, or the wider CTA. That means that we have to limit non-essential travel to and from such areas. We will therefore advise people to avoid unnecessary travel either to or from Level 3 or Level 4 areas in Scotland. Similarly people – whether they live in Scotland or elsewhere – should not travel between Scotland and areas of high prevalence elsewhere in the UK or in the wider CTA unless they really need to do so.
More generally, people who live in an area where there are protective measures in place should not travel to another area to avoid them. And in Level 4 areas, if the prevalence of the virus requires it, it may be necessary also to set limits on the distance people should travel, or to ask them to remain at home wherever possible.
As in the spring we will set out the travel restrictions in guidance, with the option of enforcement through regulations where that is necessary. Regardless of our approach, we would expect everyone to follow the evidence and expert advice about what is required to suppress the virus. We will enable low-risk activities outdoors as far as possible and seek to avoid adverse effects such as loneliness. We will ensure that there are exceptions, for example, for essential travel including for work (where that is not reasonably practicable at home), education, outdoor exercise, and access to healthcare and other essential services, for weddings and funerals, for essential shopping where that is not possible locally, and for transit through restricted areas. We will continue to engage closely with local authorities and transport providers, particularly those covering our rural and island communities to consider the specific issues they may face.
Once completed on a large enough scale, vaccinations will play an important role in ensuring we return to as close to normal life as possible. While global efforts to develop vaccines are still underway and may take time, we will ensure our immunisation infrastructure is in place now, to respond as quickly as possible when one becomes available. This will build on our successful programme of vaccinations, but given the pace and scale will bring new challenges.
The Joint Committee on Vaccinations and Immunisation (JCVI) provide independent advice to the four nations on vaccines, and we anticipate they would provide timely recommendations. On the basis of assumptions – which may change once we have received the JCVI's advice – we are undertaking operational planning to put us in the strongest position once we have that advice, including:
- Seeking a Memorandum of Understanding with the Department of Health and Social Care for the deployment of vaccines, having already put in place an agency agreement to enable the UK Vaccines Taskforce to procure vaccines on a four nations basis
- Developing a protocol under the amended Human Medicines Regulations to enable a wider workforce to vaccinate
- Scoping out delivery channels such as drive and walk through centres, mobile units and outreach facilities for care homes and those that can't leave home
- Securing additional refrigeration capacity throughout Scotland, modelling workforce requirements to deploy vaccinators, and developing an improved IT and digital platform
In the absence of a vaccine, and anticipated delivery schedule, we are focused on how best to vaccinate the greatest proportion of the population most vulnerable to harm and those health and social care workers at highest risk of infection, based on the information we have. We will provide more detail once we have greater clarity on likely timings and delivery schedules.
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