NHSScotland Control of Substances Hazardous to Health Workforce Policy: Equality Impact Assessment

Key Findings

The EQIA has highlighted areas with potential impacts on different groups and opportunities for promoting equality.

NHSScotland Control of Substances Hazardous to Health (COSHH) Policy has a positive impact in eliminating unlawful discrimination, harassment and victimisation across all protected characteristics. The Control of Substances Hazardous to Health (COSHH) Policy:

• Aims to support the implementation of the Public Sector Equality Duty. It requires public bodies to have due regard to the elimination of unlawful discrimination.
• Is accessible through a purpose built NHSScotland Workforce Policies website. The website scores high on the System Usability Scale (universal usability scoring system). This can support older staff and visually impaired staff who may experience issues using smart phones or laptops to access the internet. This also means that the policy is accessible from a personal mobile phone or laptop, therefore someone on maternity or paternity still has access to the policy.
• Includes a standard sentence in scope section of policy reinforcing compliance with equality act and linked to appropriate standard section.
• Has been written to meet legislative requirements, meeting statutory responsibility.
• Applies to all employee regardless of their protected characteristic.
• Advocates a risk based approach to meet the legislative requirements to protect pregnant employees.

NHSScotland Control of Substances Hazardous to Health (COSHH) Policy has a positive impact in advancing equality of opportunity across all protected characteristics. The Control of Substances Hazardous to Health (COSHH) Policy:

• Aims to support the implementation of the Public Sector Equality Duty. It requires public bodies to have due regard to the elimination of unlawful discrimination.
• Can be downloaded and printed for those who have issues accessing or navigating the website.
• Provides information on risk assessments that include considerations to inform actions to protect and support pregnant employees and employees with disabilities.
• Advocates a person-centred approach and adopts gender neutral language to support inclusion.
• Provides information on risk assessments, in the event certain PPE is required or restricted due to religious practices.

The website scores high on the System Usability Scale (universal usability scoring system). This may particularly support older staff or staff with certain disabilities, advancing equality of opportunity through accessibility. Insights from user testing have been used to improve the experience for all staff. The following may particularly support older staff or staff with certain disabilities, advancing equality of opportunity through accessibility:

• screen can be zoomed beyond 300%
• used an 18px font size as standard, making the starting size for fonts more readable.
• alternative formats page where users can request content in a format that suits their needs.
• a site map, that can help some people find content more easily.
• supporting documents have an HTML version that makes the content more accessible than they would be in PDF or other file formats.
• links all use meaningful text which can be read and understood out of context by screen reader users.
• headings follow a sematic structure allowing screen reader users to easily scan and understand the content structure.
• colour contrast of all text is compliant to WCAG 2.1 Level AA standards.
• meaningful text alternative created for the visual flowcharts. This is linked to before the visual flowcharts to support screen reader users.
• development of a style guide for policy writing which focuses on improving readability for a range of users. For example, by reducing sentence length, best use of grammar and providing meaningful website links to advance equality of opportunity through accessibility.

The NHSScotland Control of Substances Hazardous to Health (COSHH) Policy has no negative impact in promoting good relations between people who share a protected characteristic and those who do not. The Control of Substances Hazardous to Health (COSHH) Policy:

• Aims to advance the equality of opportunity and foster good relations between different groups.
• Is open to all employees and managers are encouraged to take a person-centred approach.

• Demonstrates a commitment to safeguarding maternal health.

The website was developed through extensive user testing and is compliant to Web Content Accessibility Guidelines (WCAG) 2.1 Level AA standard. However, in terms of access to the policy, it was identified that some staff may struggle with technology or do not have access or experience of using IT equipment and could be disadvantaged. This may be more likely in older age groups.

The following actions have been taken to minimise any negative impact:

• Policies and supporting documents have been created as downloadable documents which can be printed and shared in hard copy.
• Upon initiating a workforce policy, managers are required to formally write to the employee informing them of this. Within this, managers are asked to include a hard copy of the policy, flowchart and any other relevant supporting documents.
• Downloadable copies of the policy and supporting documents include a references section. This details in full any hyperlinks contained within the document to support those accessing hard copies and provide signposting.
• Review of the Standard Sections to consider how we can support staff with additional needs to access policy.
• Inclusion of national level expectation to apply a person-centred and flexible approach to support staff.

Scottish Government will continue to monitor and review this EQIA to ensure ongoing assessment of potential impacts on people with protected characteristics.