UK Covid-19 Inquiry Module 3 report: Scottish Government response

Recommendation 3 - Better preparation for fit-testing

Chair’s recommendation:

The UK Government, Scottish Government, Welsh Government and Northern Ireland Executive should work with employers, including health boards and trusts, to review the availability of qualified fit testers and take steps to increase the number of fit testers accordingly. Availability should be reviewed every three years in line with the Inquiry’s Module 1 Report (Recommendation 4).

The Health and Safety Executive and the Health and Safety Executive for Northern Ireland should update their guidance to employers to emphasise the need to ensure that sufficient fit testing capacity is available.

Scottish Government response:

The Scottish Government accepts the recommendation to review the availability of qualified face fit testers.

The Scottish Government accepts in principle the recommendation to increase the number of face fit testers accordingly. We agree with the intent of ensuring sufficient face fit testing capacity is available across health and social care services. However, any decision on future numbers should be informed by an assessment of operational need, existing capacity and future workforce requirements across Scotland.

The Scottish Government also accepts in principle the recommendation that availability should be reviewed every three years. In line with feedback from CIREG, we support the principle of regular review and assurance of face fit testing capacity and plan to review arrangements at least every three years. However, we consider that the timing of reviews should be aligned with wider resilience, workforce planning and pandemic preparedness arrangements while delivering the intent of the recommendation. These considerations may influence the exact timing of future reviews.

The recommendation relating to updated employer guidance is a matter for the Health and Safety Executive and Health and Safety Executive for Northern Ireland rather than the Scottish Government.

Since the pandemic, the Scottish Government has taken forward work to understand and strengthen face fit testing arrangements. PSD Scotland was commissioned to review current and future filtering facepiece respirator 3 (FFP3) face fit testing arrangements across health and social care in Scotland. Recommendations from that review were submitted in May 2026 and are being considered by the Scottish Government.

In parallel, the Scottish Government has sought information from NHS Board Health and Safety Leads on current face fit testing coverage, sustainability arrangements, risks and gaps, to support understanding of current face fit testing coverage and FFP3 provision across NHS Boards in Scotland. This will support assessment of current capacity and inform any further action required. The Scottish Government will also work with PSD Scotland to consider future face fit testing equipment requirements - including the demands of a pandemic response and continue to engage with the other UK nations as appropriate on preparedness and resilience matters.

In addition to FFP3 provision, it is important to note that powered hoods are an essential part of the Respiratory Protective Equipment available where face fit testing cannot be undertaken or successfully achieved. The Scottish Government will work with NHS Boards and care services to confirm access to powered hoods and seek assurance that there is appropriate maintenance and cleaning of equipment in place, and a register of staff education and training.

Ensuring robust face fit testing, where necessary powered hood provision, PPE education and training for health and social care staff should be maintained as part of preparedness and resilience and a register of staff education and training is in place.

Actions and implementation timescale(s):

The Scottish Government will consider the recommendations arising from the PSD Scotland review of current and future FFP3 face fit testing arrangements across health and social care and agree a proposed approach to implementation including appropriate timelines.

The Scottish Government will assess information provided by NHS Board Health and Safety Leads on current face fit testing coverage, sustainability arrangements, risks and gaps to inform future planning and identify any further actions required.

The Scottish Government will work with NHS Boards (inclusive of PSD Scotland) to assess future face fit testing capacity and equipment requirements and, where required, support implementation measures to strengthen preparedness. Thereafter, the Scottish Government will establish arrangements for the ongoing review of face fit testing capacity as part of wider resilience and preparedness planning, including periodic review.

The Scottish Government will work with NHS Boards and care services to confirm access to powered hoods and seek assurance that there are appropriate maintenance and cleaning of equipment in place, and a register of staff education and training.

Accountable Officer:

The Director General for Health and Social Care, working with the Directorates of the Chief Nursing Officer, Chief Operating Officer and Health Workforce, will be accountable for the implementation of the Scottish elements of this recommendation.