Pandemic Personal Protective Equipment: consultation

A consultation on the future supply of pandemic Personal Protective Equipment in Scotland

Introduction

This is a consultation seeking your views on:

Part 1) what lessons should be learned about provision of PPE in the current pandemic; and

Part 2) what arrangements should be put in place for PPE so that we are ready for any future pandemic that may occur.

Background

In response to the Covid-19 pandemic, global demand for personal protective equipment (PPE) increased dramatically and the 'just in time' supply chain model in place at that time broke down. This brought about unprecedented challenges to the existing PPE buying approaches and supply mechanisms within Scotland. Scotland's existing pandemic PPE stockpile, which was purchased in collaboration with other UK nations, was also put under pressure.

Despite these circumstances, through the quick adoption of entirely new approaches to PPE supply, including establishing a new Scottish manufacturing base for PPE, the Scottish Government, NHS National Services Scotland (NSS), the business community, and other partners ensured Scotland and our NHS and social care sectors always had a sufficient supply of PPE. However, we know that in some cases supply was limited for a period of time and distribution difficulties were experienced, making that early phase of the pandemic very challenging for some front line staff.

Whilst acknowledging that the Covid-19 pandemic continues and the situation could change, the PPE market has now stabilised, all sectors can access PPE through their supply chains and the NHS has an ample stockpile of PPE. Furthermore, the resilience of the supply chain has been increased by the creation of a domestic PPE manufacturing base.

There is now an opportunity to examine how Scotland can learn from the Covid-19 pandemic to build a sustainable and robust PPE supply strategy to meet the challenges of any future pandemic.

Changes in primary and adult social care PPE provision during this pandemic

Prior to the pandemic, NSS was responsible for supplying PPE to NHS Scotland Hospitals and Health Centres, and the primary and adult social care sectors were responsible for their own PPE supplies. However, during the pandemic the role of NSS expanded significantly, and it distributed PPE free of charge to the primary care sector either directly or through arrangements with NHS Boards.

For adult social care providers NSS provided top-up and emergency PPE free of charge from the national stock via 48 regional distribution Hubs, alongside an emergency triage service for adult social care providers who had an urgent shortage of PPE. We anticipate the PPE Hub provision will be extended beyond March 2022, subject to discussions with delivery partners.

Supply of PPE to public sector organisations and others providing essential services via framework arrangement

Additionally, the Scottish Government provided support to essential public services to ensure everyone could buy PPE. A framework was set up to enable all Scottish public bodies outwith the NHS and regulated care sector, eligible private businesses that provided an essential public service, and all third sector organisations to obtain PPE from a private framework supplier when their traditional supply routes failed. 1,200 organisations signed up to be part of these arrangements, which provided considerable assurance to a range of sectors, including the public sector and businesses such as funeral directors. As traditional supply routes have now recovered and stabilised this framework was brought to an end in October 2021. More information on this framework can be found in Annex B.

What we are planning for the future

In June 2021 Audit Scotland published a report which examined the Scottish Government's approach to PPE supply during the Covid-19 pandemic. The report stated that a new, long term approach to PPE supply was required, for both business as usual PPE needs as well as preparing for future pandemics.

The Scottish Government, led by the PPE Strategy & Governance Board is therefore working with partners such as the NHS to ensure that Scotland is fully prepared for any future pandemic situation. A PPE Futures Programme has been put in place to plan for new approaches to pandemic PPE which will ensure we learn from experience, promote innovation, and have strong, sustainable foundations for any future pandemic. The objectives for the Programme are to secure:

1. a resilient PPE supply chain,

2. high quality PPE at an appropriate price, and

3. best value in PPE buying

Further information on the PPE Futures Programme can be found at the following link: Coronavirus (COVID-19): Personal Protective Equipment (PPE) Futures programme - overview - gov.scot (www.gov.scot)

Types of PPE and settings in scope for this consultation

The PPE required to prepare for any future pandemic could differ, and will be decided upon in line with expert clinical guidance and in alignment with other UK nations. However, it is very likely that, initially the included items will be those that have been commonly utilised throughout the Covid-19 pandemic.

Therefore the items under discussion for the purposes of the consultation are as follows:

• FFP3 and Fluid Resistant (Type IIR) Surgical Masks
• Gloves
• Visors and goggles,
• Aprons and non-sterile gowns
• Hand sanitiser (while this is not an item of PPE it has been included in the scope of this work)

Other items of PPE that, in future, are recommended for inclusion in the PPE pandemic stockpile will also come within scope. This includes new and innovative items of PPE.

All interested parties are invited to provide their comments on this consultation. It considers the PPE needs of all public sector settings and some private sector settings, and is not restricted to health and care services, but encompasses all settings where pandemic PPE may be required (noting, however, that the solutions that are put in place for different settings will vary). These could include:

• Services provided by Health Boards in hospitals and the community
• Primary Care independent contractors:
  • General Practice
  • NHS dentistry
  • Optometry
  • Community pharmacy
• Adult social care, including local authority, private sector and third sector run services
• Carers and personal assistants
• Local authorities and local authority services such as children's social care, schools and housing
• Large public sector users of PPE such as the Police Service, Fire and Rescue Service, Scottish Prison Service
• Other public sector organisations
• Universities and Colleges

The consultation is also of interest to private businesses and third sector organisations who require access to pandemic PPE items as part of their operations. These are defined as authorised private-sector organisations employing staff who provide essential public services where there is a risk to health, registered Scottish charities and voluntary organisations. This also includes private businesses contracted to provide such services to public bodies.

Manufacturers and suppliers of PPE may also have an interest in the content of this consultation.

Part 1: Lessons learned

While the consultation specifically concerns the future pandemic PPE supply element of the PPE Futures Programme, it is also integral to the Programme's aims to fully understand and consider the lessons learned as part of any future pandemic PPE supply strategy. Significant work has already been undertaken to explore the successes and the challenges of securing a PPE supply during the Covid-19 pandemic:

Key lessons learned from the COVID-19 pandemic:

• We must ensure that effective mechanisms for collaboration and communication between the Scottish Government and stakeholders are in place in the event of a future pandemic. This is especially relevant in regard to real time data sharing, stockpile management and being able to effectively prioritise PPE supply where it is most needed.
• Scotland's traditional PPE supply routes, just-in-time supply model and PPE stockpiling arrangements were not sufficient in pandemic circumstances. A reformed stockpiling and buying approach for pandemic PPE is required.
• Long term and sustainable PPE supply arrangements are required for the primary and adult social care sectors post March-2022 to ensure the challenges of any future pandemic can be met.
• Cross public sector collaboration with NSS on PPE supply issues was a success of the Covid-19 pandemic, and helped overcome the challenges of the volatile international PPE supply chain. Continuing this collaboration in some form should be considered as part of a future pandemic PPE strategy.
• During the Covid-19 pandemic Scotland always had a sufficient supply of PPE. However as the traditional routes of supply failed under worldwide demand pressures, new supply chains had to be set up quickly in order to meet demand. Therefore, surge capacity needs to be available to ensure that anticipated PPE demand is met during the volatile early stages of any future pandemic.
• It was not only health and care services who experienced difficulties in obtaining PPE from traditional supply routes in the early stages of the pandemic, non health and social care private businesses and third sector organisations faced the same challenges. Any future supply strategy needs to take this into consideration and ensure that these organisations are as prepared as possible for a future pandemic.
• During the pandemic Scottish manufacturing proved to be flexible and responsive when international PPE supply chains collapsed. We must build upon the progress made during the Covid-19 pandemic in terms of supporting the quick evolution of these new supply chains, and the development of better PPE supply and demand data modelling.

Your views are sought on whether these are the right lessons that we should draw from this pandemic; and whether there are any additional points we should consider.

Part 2: Preparing our PPE Stocks for Future Pandemics

The Scottish Government has worked with partners including NSS to develop several options for a general pandemic PPE supply strategy that could both implement the key lessons learned, and meet the required Programme objectives. From an initial list of nine, four options were shortlisted for appraisal:

Option A: Working jointly on a Four Nations basis. Scotland would be involved in the development and agreement of Four Nations pandemic PPE countermeasures and participate in UK PPE stockpile buying. This is a continuation of arrangements that were in place prior to the Covid-19 pandemic.

Option B: Have a strategic Scotland-led pandemic focus. This option maintains the Four Nations approach in Option A, while proposing a Scotland-only PPE stockpile is procured and managed by NSS. This would include NSS managing a surge capacity contract, and ensuring that sector-specific plans and guidance are put in place to support the response to a future pandemic whenever it may occur. The Scottish Government would continue to support Scottish based PPE manufacturing were it is able to do so.

Option C: Have a strategic Scotland-led pandemic focus and join up buying of pandemic PPE. This option moves away from the pre-Covid-19 Four Nations approach to pandemic planning for PPE in Scotland. In addition to the deliverables outlined in Option B, a limited additional degree of joined-up public sector pandemic PPE buying with a focus on sustainability and maintaining local supply chains is introduced. The intention is to retain as much domestic manufacturing capacity as possible, subject to contracts being awarded as the result of open and fair procurement exercises.

Option D: Have a strategic Scotland-led pandemic focus which tasks NSS to hold and manage the pandemic stockpile, invest in surge capacity, and buy and supply PPE to the public sector. In addition to the deliverables outlined in Option B, centralise Scottish pandemic PPE buying will be introduced as soon as is practical and to the maximum degree which can be agreed across the public sector, with a focus on sustainability and local supply chains. The intention is to retain as much domestic manufacturing capacity as possible, subject to contracts being awarded as a result of open and fair procurement exercises.

The assessment of these options was that Option D is, by a clear margin, the most likely to achieve the Programme's objectives to secure:

1. a resilient PPE supply chain,

2. high quality PPE at an appropriate price, and

3. best value in PPE procurement.

Therefore, the following broad arrangements are proposed:

National arrangements

1) Scotland will have a stockpile of pandemic PPE items. This will be held and managed by NSS, however this will be accessible on an emergency basis by sectors that need it.

Prior to the Covid-19 pandemic, Scotland's pandemic PPE stockpile was procured as part of a co-ordinated approach to pandemic PPE with the rest of the UK. This was a vital part of the early response and supplemented existing arrangements until supply chains became more stable. However, there was limited opportunity to rotate the PPE items within the stockpile, resulting in some stock going out of date and having to be revalidated before use. At the moment, PPE stock levels are very good and continue to be actively managed by NSS.

For the future, it is proposed that Scotland have its own pandemic PPE stockpile. This will ensure that an adequate supply of high quality PPE can be accessed quickly if required in the event of a future pandemic, should the usual routes of PPE supply be disrupted or unavailable. This will allow the stock to be managed and rotated to minimise wastage, and the need for revalidation.

While it is proposed that the stockpile is managed by NSS, it is not yet clear which sectors should be able to access it, and what contribution should be made by those sharing the stockpile to the cost of creating and maintaining it.

It is also important to note that that the Scottish Government is, and will continue to be, fully engaged with the current work on Four Nations countermeasures planning, and joined up work on infection prevention and control issues will also continue.

We would be interested to know –

• Do you agree Scotland needs its own pandemic PPE stockpile?
• What organisations or sectors should be able to access it and what contribution should they make to the cost of it?

2) Public sector organisations and social care providers will have the opportunity to opt into an arrangement where their pandemic PPE is purchased collaboratively by NSS.

One of the successes of Scotland's Covid-19 pandemic response was the cross public sector collaboration with NSS in order to overcome extremely difficult PPE supply issues, and this success should be maintained and built upon.

As a direct result of the Covid-19 response we have a Scottish PPE supply chain in place. Collaborative purchasing can increase buying power, and support the Scottish PPE supply chain, within the rules of public procurement. Having a domestic supply chain builds in resilience and will be advantageous in the next pandemic when it occurs. Therefore, if we can maintain it, we should do everything we can to make sure we do.

Collaborative procurement can also help drive connections and close joint working with manufacturers, and will supply them with the certainty around orders they need to innovate and drive efficiencies, and provide products that best meet the needs of users.

It is therefore proposed that NSS manages the buying of pandemic PPE for those organisations that choose to opt into the arrangement. This will likely include the management of the supporting data and financial flows, a rotation system to minimise wastage and ensuring all PPE items are high quality and represent best value. Those opting into this arrangement will pay for the PPE provided by NSS, however the payment mechanism and how it will work is still to be determined.

We would be interested to know –

• Do you agree that increasing public sector buying power has the potential to help support Scottish PPE manufacture?
• Do you agree this will help Scotland be more resilient for the next pandemic whenever it might occur?
• For public sector respondents – in principle, would your organisation be willing to participate in this collaboration?
• Do you have any other views on collaborative procurement of pandemic PPE?

3) An emergency PPE supply mechanism for other private sector organisations providing essential public services and third sector organisations will be considered as part of the future supply strategy. This will include, but not be restricted to, access to the PPE stockpile. It will be a successor arrangement to the private procurement framework that was in place until October 2021.

In the early stages of the pandemic the Scottish Government put an agreement in place with a private sector distributor which covered supply terms and conditions, logistics and payment to ensure that eligible essential public services and third sector organisations could access PPE if their usual supply routes failed. It is proposed that a similar support should be put in place in the event of future pandemics, to ensure that disruption to these important services and organisations is minimised.

This is unlikely to take the same form, but could include other supportive measures, such as ensuring that these sectors could access the national PPE stockpile if their usual supply routes failed. It could also include the Scottish Government providing guidance on how organisations can enact their own pandemic preparedness measures, such as what PPE should be stockpiled, in what quantities, and what steps to take should they find themselves unable to buy PPE in a pandemic situation.

This will ensure that private and third sector organisations providing essential public services will be able to effectively prepare for a future pandemic, and always have access to high quality PPE when they need it. This will minimise disruption to the important services they provide.

We would be interested to know –

What support to secure pandemic PPE do you think should be offered to those providing essential public services in third and private sectors, in the event of their supply chains failing during a future pandemic?

Sector-specific proposed arrangements

There is no single supply approach that is suitable for all sectors, and it is important to note that these proposals are still under development. Therefore, the consultation seeks views on the proposed future strategic arrangements, and the results will help to ensure that the experiences of securing pandemic PPE during the Covid-19 pandemic from across all sectors are fully considered as the proposals are developed for implementation.

We are proposing that there should be cross-public sector collaborative buying of pandemic PPE items, led by NSS. Participation in this would be optional, but strongly encouraged to maximise Scotland's resilience and support Scottish PPE manufacturing and the supply chain. Additional arrangements will be put in place for those not part of the proposed arrangements, either by choice or because they are in the private sector (providing an essential service), third sector or are individual carers.

For ease of reference, below is an outline summary of the pandemic PPE buying arrangements for each sector before and during the Covid-19 pandemic, and the changes proposed. It is important to note that details such as distribution, finance, and what 'emergency support' would entail are still under development.

Sector	Pre-pandemic PPE supply routes	Pandemic PPE supply routes	Proposed: potential participant in collaborative buying led by NSS	Proposed: access to emergency stockpile if required in future pandemic	Proposed: emergency only support available if required in future pandemic
NHS Board services including hospital and community services	Primarily provided by NSS (also bought own)	Primarily provided by NSS (also bought own)	Yes	Yes	N/A
Local authorities and local authority services including adult social care settings	Available from Scotland Excel framework, also bought own	Available from Scotland Excel framework, also bought own. Additional support from NSS, Hubs and private framework.	Yes, if they opt in, which would be strongly encouraged	Yes	Yes, if not buying collaboratively
Other public sector e.g. prisons, fire service, police service	Bought own	Primarily bought own, or have access to frameworks such as APUC. Increased cross-sector collaboration, and additional support from private framework. NSS also provided PPE to the police and prison service.	Yes, if they opt in, which would be strongly encouraged especially for larger users	Yes	Yes, for those not involved in collaborative buying
Primary care independent contractors	Bought own	Provided by NSS for NHS services only	For discussion, but that would be possible	Yes	Yes, if not buying collaboratively
Private and third sector run adult social care settings	Bought own	Emergency/ top-up provision from NSS via Social Care Hubs; Sustainability funding available	Yes, if they opt in	Yes	Yes, if not already opted in
Universities and Colleges including research and testing laboratories	Available through framework and also bought own	Available from APUC frameworks and DHSC, where relevant. Additional support provided from NSS	Yes, if they opt in	Yes	Yes, if not buying collaboratively
Carers and personal assistants	Bought own	Emergency/ top-up provision from NSS via Social Care Hubs	Long term PPE support to carers and PAs will require further consideration	Yes	Yes
Private sector non-essential services	Bought own	No change	No change	No change	No change

We would be interested to know –

Do the proposed PPE arrangements for your sector seem appropriate?

What changes should be made?

PPE Costs

The overarching proposal for the public sector is that there should be a collaboration in place, which sees NSS buying for all those who use pandemic PPE in a business as usual setting.

We would seek to find a mechanism by which the costs for this would be appropriately recovered so that the NHS is not left bearing costs which would normally be borne by other public sector partners.

There are a number of means by which this could be done, including a standing contribution to the overall cost of buying; or recharge after the PPE has been procured. The important issue will be fairness to all parties, and we would be keen to maintain that, and to develop this mechanism as collaboratively as possible.

We would be interested to know –

Do you agree that a mechanism (or mechanisms) should be found by which the cost of PPE is appropriately split between the organisations that are using that PPE?

What mechanism or mechanisms would be most appropriate in your view?

Scottish Government

January 2022