Covid-19 face coverings and guidance correspondence: FOI release
Information request and response under the Freedom of Information (Scotland) Act 2002
Information requested
a) “As an FOI I would please like to see:
i. the data, with sources referenced, that was used to come to the conclusion that now is the right time to remove the extended guidance on facemasks in health and social care settings.
ii. I would also like to request full details of the data sources that are being used to remain vigilant and monitor emerging trends and current status, regarding Covid-19 infection prevalence in the community and nosocomial infection, and incidence of post Covid conditions, including long Covid and tracking of new variants.
iii. I would also like to see the policy analysis undertaken, which the IPC advice from ARHAI was presumably one among other factors including outputs from stakeholder engagement, that were objectively weighed up in order to reach the conclusion that now is the right time to remove this essential protection.”
b) “I do not doubt that you retain capacity to identify people who are immunocompromised. It would be helpful to know the current number of people in that category and I would be grateful if you can provide the total number as an FOI.”
c) “I note, however, that you state “Consideration was given to the risk to a range of population groups”. Please can you send me this as an FOI. Of course, if (as regrettably seems to be the case) Scottish Government understands neither the risks nor the equality implications (both very considerable) it will not be equipped to carry out a meaningful EQIA.”
d) “Please can you also send me full details of the social care representatives and providers you engaged with in developing this change of policy. I would also like to see the evidence on which they based their conclusion that they were content for their care workforces and those they care for to be exposed to life-changing/ threatening airborne viruses. If there was no engagement with groups representing the diversity of social care support users, carers and people with lived experience themselves it would be good to understand why. It would also be interesting to know why, if care providers supported this move, Scottish Care issued such a damning statement concerning the removal of personal choice: https://scottishcare.org/scottish-care-comment-on-withdrawal-of-extended-use-of-face-coverings/.”
e) “Please can you let me have as an FOI:
- The guidance you and your colleagues have issued to healthcare and social care workers that makes this clear.
- The guidance issued to GPs on the role and importance of FFP3 masks in protecting from airborne transmission of Covid and other airborne viruses and pathogens and the enhanced risks of adverse sequelae from repeated reinfection.”
f) “As an FOI please can I see any correspondence between officials and the ARHAI which queried any aspect of those documents, and the ARHAI’s response”
Response
I enclose a copy of most of the information you requested in the format you asked for. An exemption under section 38(1)(b) of FOISA and an exemption under section 30(b)(i) applies to a small amount of the information. Further information on those exemptions can be found in Annex A. Please refer to Annex B for a response to the points raised in your correspondence.
a) As an FOI I would please like to see:
i the data, with sources referenced, that was used to come to the conclusion that now is the right time to remove the extended guidance on facemasks in health and social care settings.
- Health Board Daily Cases data
- JVCI and PHS Vaccination rate data
Flu & COVID vaccinations - COVID - JCVI - Scottish Health and Social Care Open Data (nhs.scot)
- Care Home COVID Absences data
Covid-19 statistics (careinspectorate.com)
- NHS COVID Absences data
COVID-19 Staff Absence | Turas Data Intelligence (nhs.scot)
- NRS COVID Deaths data
- ARHAI Scotland’s returned commission paper
ii I would also like to request full details of the data sources that are being used to remain vigilant and monitor emerging trends and current status, regarding Covid-19 infection prevalence in the community and nosocomial infection, and incidence of post Covid conditions, including long Covid and tracking of new variants.
Scotland’s National Respiratory Surveillance Plan and the 'Plan for monitoring and responding to new SARS-CoV-2 variants and mutations (VAMs)' are two Public Health Scotland’s planning documents that inform national health protection preparedness work. They are subject to ongoing review.
The PHS dashboard is updated with the latest available data on COVID-19 & respiratory pathogens in Scotland (Overview of the COVID-19 & respiratory surveillance dashboard - COVID-19 daily cases in Scotland dashboard - COVID-19 data and intelligence - COVID-19 - Conditions and diseases - Our areas of work - Public Health Scotland). The metadata section on the PHS dashboard includes details on the source of each indicator.
National Records of Scotland (NRS) publish deaths involving COVID-19 on a weekly basis in their Deaths registered weekly in Scotland publication. This includes all deaths where COVID-19 was mentioned on the death certificate, either as the underlying cause or as a contributory factor.
The COVID-19 and respiratory surveillance dashboard is publicly available at: Overview of the COVID-19 & respiratory surveillance dashboard - COVID-19 daily cases in Scotland dashboard - COVID-19 data and intelligence - COVID-19 - Conditions and diseases - Our areas of work - Public Health Scotland”
In terms of long COVID data sources, the Scottish Health Survey (SHeS), which is a national survey of the health of the Scottish population in private households, provides annual estimates of long COVID prevalence in Scotland.
ARHAI Scotland developed a new surveillance system to monitor hospital transmission of COVID-19 at pace during 2020 and published weekly statistics on the number of hospital onset COVID-19 cases. This monitored nosocomial COVID-19 infections (based on those presenting 8 days or more after admission to hospital) and was used to provide evidence to inform infection prevention and control measures, guidance and policy within hospitals. Due to the lower number of hospital onset COVID-19 cases, and to support NHS boards by reducing local Infection Prevention and Control Team resource required for surveillance, the last publication of these statistics was issued on 1 March 2023.
Decisions around changes to advice and guidance are not informed by data alone. Collective consideration of such data and other information, which provides a system-wide view, is important. This takes place in a range of forums including Scottish Government's Covid Four Harms Group. Discussions here informed the conclusion that we were in a different phase of the pandemic and that it was the right time to remove the extended guidance on facemasks in health and social care settings.
iii I would also like to see the policy analysis undertaken, which the IPC advice from ARHAI was presumably one among other factors including outputs from stakeholder engagement, that were objectively weighed up in order to reach the conclusion that now is the right time to remove this essential protection.
SEE TABLE OF ATTACHMENTS BELOW
b) “I do not doubt that you retain capacity to identify people who are immunocompromised. It would be helpful to know the current number of people in that category and I would be grateful if you can provide the total number as an FOI.”
Public Health Scotland maintains the current cohort list for COVID-19 vaccinations. This winter, all those aged six months and over who are in a clinical at risk group, as defined in tables 3 and 4 of the COVID-19 Green Book chapter are eligible for a COVID vaccine. The immunosuppressed sub-set of the clinical at risk group has identified 170,915 eligible individuals. Household contacts of the immunosuppressed (aged 12+) and carers (aged 16+) are also eligible for a COVID vaccination this winter.
If you require further information on how this data is derived and the sources it is obtained from, I would advise you to contact the Public Health Scotland Freedom of Information team who can be contacted at phs.foi@phs.scot
As noted previously, the eligibility criteria for COVID-19 treatments were developed by an independent expert working group commissioned by the UK Department of Health and Social Care, based on detailed clinical evidence. The criteria are set out in an updated independent advisory group report, published in March 2023. The policy targets those higher risk individuals who have the potential to both be least likely to generate a material immune response to vaccines and be at highest risk of disease progression, hospitalisation and death.
The Scottish Government does not hold data on the number of immunocompromised people eligible for COVID-19 Antiviral Treatments. As Public Health Scotland also maintains the current eligible cohort list for COVID-19 treatments, you may also wish to contact their Freedom of Information team at phs.foi@phs.scot, who may be able to provide more information.
Personal Protective Equipment (PPE) should continue be worn in accordance with the National Infection Prevention and Control Manual (NIPCM). FFP3 respirators must be considered by healthcare workers, if a patient is admitted with a known/suspected infectious agent/disease spread wholly by the airborne route, or when carrying out aerosol generating procedures (AGPs) on patients with a known/suspected infectious agent spread wholly or partly by the airborne or droplet route.
c) “I note, however, that you state “Consideration was given to the risk to a range of population groups”. Please can you send me this as an FOI. Of course, if (as regrettably seems to be the case) Scottish Government understands neither the risks nor the equality implications (both very considerable) it will not be equipped to carry out a meaningful EQIA.”
SEE TABLE OF ATTACHMENTS BELOW
d) "Please can you also send me full details of the social care representatives and providers you engaged with in developing this change of policy. I would also like to see the evidence on which they based their conclusion that they were content for their care workforces and those they care for to be exposed to life-changing/ threatening airborne viruses. If there was no engagement with groups representing the diversity of social care support users, carers and people with lived experience themselves it would be good to understand why. It would also be interesting to know why, if care providers supported this move, Scottish Care issued such a damning statement concerning the removal of personal choice: https://scottishcare.org/scottish-care-comment-on-withdrawal-of-extended-use-of-face-coverings/.”
Scottish Government Adult Social Care and Oversight Assurance policy team met with Scottish Care, Coalition of Care and Support Providers in Scotland, a care home provider and Trustha, a housing, care and support provider on 9th March to discuss the current guidance and get their opinions on what guidance the social care sector needs, based on their experience.
Below shows the emails to arrange the meeting (sent between 7th and 8th March), a note following the meeting on 9th March outlining the discussion and feedback (sent 27th March) and also confirmation that the guidance would be withdrawn (5th May).
In regard to your enquiry on the views of Scottish Care, they were consulted within these discussions. If you have any further queries on their views, I would advise that you contact them directly.
e) “Please can you let me have as an FOI:
- The guidance you and your colleagues have issued to healthcare and social care workers that makes this clear.
SEE TABLE OF ATTACHMENTS BELOW
- The guidance issued to GPs on the role and importance of FFP3 masks in protecting from airborne transmission of Covid and other airborne viruses and pathogens and the enhanced risks of adverse sequelae from repeated reinfection.”
Advice and assessments of the enhanced risks of adverse sequelae from repeated reinfection would have been undertaken by Public Health Scotland and ARHAI Scotland. In this instance, the Scottish Government recommends that the requester contacts both organisations at: NSS.ARHAIinfectioncontrol@nhs.scot and phs.HealthProtectionEnquiries@phs.scot
f) “Correspondence between officials and ARHAI in relation to the versions of the NIPCM and CH-NIPCM that were in existence at the time of the announcement of the removal of extended guidance on the wearing of facemasks in health and social care settings, and also appendix 19 of the NIPCM, as per 2 June 2023, concerning officials’ review, challenge and acceptance of their content, up-to-dateness, completeness, accessibility and layout and ARHAI’s response/s”
SEE TABLE OF ATTACHMENTS BELOW
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