Mapping of Govt guidance for IPC for COVID-19 in care homes - BushProof

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Mapping of Govt guidance for IPC for COVID-19 in care homes
Version: 14 May 2020

Purpose of this document:
1. To map the current guidance on infection prevention and control (IPC) in care homes from the UK
   Government and Public Health England
2. To understand the strengths and gaps – so we can advocate to get the gaps and weaknesses responded
   to
3. To inform our interim practical, in-one-place, guidance for use by Care Home Managers (see below), as
   a tool, building on the existing UK Govt and PHE guidance, while it is still scattered and in some cases,
   contradictory

Authors of this document:
This is a ‘living’ document that will be updated as Guidance is updated. It has been prepared by:
•   Dr Sarah House, BEng, DIS, MSc, D.Litt, CEng, MICE, C.WEM, FCIWEM, Water Sanitation & Hygiene
    (WASH) Consultant / Public Health Engineer, Leicester, UK
•   Eric Fewster, MSc, C.WEM, MCIWEM, CEnv, Independent Water & Environmental Manager, Salford, UK
A range of other reviewers contributed to the strategy on which the recommendations made in this
mapping document are based:

Care Homes Strategy for Infection Prevention & Control of Covid-19 Based on Clear
Delineation of Risk Zones - This strategy document has been prepared with inputs from a range of
experts who collectively have a mix of experience from medicine/health, care homes,
water/sanitation/hygiene, outbreak infection prevention & control (specifically from Ebola, SARS, cholera
and Lassa Haemorrhagic Fever outbreaks) and emergency response.
This can be found at: https://www.bushproof.com/care-homes-strategy-for-infection-prevention-control-
of-covid-19-based-on-clear-delineation-of-risk-zones/; or https://ltccovid.org/2020/05/01/resource-care-
homes-strategy-for-infection-prevention-control-of-covid-19-based-on-clear-delineation-of-risk-zones-
update/

Meaning of font colour and style within this document:
    •   Red text = gaps in guidance, contradictory points, questionable aspects
    •   Black bold = highlights certain useful points
                                                                                                            1
Contents
KEY DOCUMENTS UTILISED IN THIS MAPPING ANALYSIS ......................................................................... 3
  1.       OUR CARE HOMES IPC STRATEGY DOCUMENT ................................................................................................................ 3
  2.       THE UK GOVT GUIDANCE REFERRED TO (BY LETTER) IN THE COMPARISON TABLE .................................................................. 3
UK GOVERNMENT GUIDANCE VS OUR STRATEGY FOR IPC IN CARE HOMES ............................................. 7
  3.       CRITICAL ELEMENTS OF IPC ......................................................................................................................................... 7
       3.1 - Zoning / clarification of risks / risk areas ........................................................................................................................... 7
       3.2 - Encourages understanding of infection routes and how to prevent transmission ........................................................... 10
       3.3 - Symptomatic vs asymptomatic or pre-symptomatic transmission .................................................................................. 13
       3.4 - Discharge of COVID+ patients into a care home .............................................................................................................. 15
       3.5 - Acknowledgement of different geriatric symptoms to COVID-19 .................................................................................... 17
       3.6 - Allocation of staff responsibilities within the home ......................................................................................................... 17
       3.7 - Isolation vs communal sitting........................................................................................................................................... 18
  4.       PPE ...................................................................................................................................................................... 20
       4.1 – Donning and doffing areas .............................................................................................................................................. 20
       4.2 - Donning and doffing processes ........................................................................................................................................ 21
       4.3 - PPE - Use of gloves, handwashing and handwashing with gloves ................................................................................... 21
       4.4 – PPE – Use of aprons ......................................................................................................................................................... 23
       4.5 - PPE - Use of face masks .................................................................................................................................................... 24
       4.6 - PPE - Use of goggles / visors ............................................................................................................................................ 27
       4.7 - PPE – Use of gowns or lab coats ...................................................................................................................................... 28
       4.8 - PPE for aerosol generating procedures ............................................................................................................................ 29
       4.9 - Re-use of PPE .................................................................................................................................................................... 29

  5.       DISINFECTION, LAUNDRY, WASTES .............................................................................................................................. 31
       5.1 - Disinfection protocols ....................................................................................................................................................... 31
       5.2 - Cleaning routines and de-contamination ......................................................................................................................... 32
       5.3 - Laundry............................................................................................................................................................................. 34
       5.4 - Solid waste disposal ......................................................................................................................................................... 36
       5.5 - Management of incontinence pads, faeces and urine ..................................................................................................... 37
       5.6 - Management of bodies of the deceased .......................................................................................................................... 37

  6.       STAFF, TRAINING, TESTING, VISITORS........................................................................................................................... 38
       6.1 - Staff health/sickness ........................................................................................................................................................ 38
       6.2 - Staff training, hygiene and well-being ............................................................................................................................. 39
       6.3 - Testing of residents and staff ........................................................................................................................................... 40
       6.4 - Visitors .............................................................................................................................................................................. 41

  7.       VULNERABILITY, PEOPLE WITH MENTAL HEALTH CONDITIONS, AGPS ................................................................................ 42
       7.1 - Working with people who are hard of hearing or who have learning difficulties, autism or dementia........................... 42
       7.2 - Who is considered most vulnerable and requirements for each ...................................................................................... 43
       7.3 - Use of nebulisers and chest compressions ....................................................................................................................... 44

  8.       OTHER REFERENCES ................................................................................................................................................. 46
       8.1         Other UK Govt references............................................................................................................................................ 46
       8.2         Other guidance for care homes ................................................................................................................................... 46
       8.3         Zoning / traffic control bundling ................................................................................................................................. 47
       8.4         Other PPE guidance ..................................................................................................................................................... 47
       8.5         A-symptomatic and pre-symptomatic infection and transmission risks for COVID-19 ............................................... 47

                                                                                                                                                                                                     2
Key documents utilised in this mapping analysis

1. Our care homes IPC strategy document
     Core document        Date                Link                            Notes

 1   Our practical        April 18 –          https://www.bushproof.co         Focusses on providing simple
     recommend-           updated             m/care-homes-strategy-for-       practical guidance in one place. Focus
     ations on IPC        regularly           infection-prevention-            on zoning and hand-washing at
     strategy for care                        control-of-covid-19-based-       critical times to improve IPC through
     homes                                    on-clear-delineation-of-risk-    nudges. Incorporates responses to
     document                                 zones/; or                       asymptomatic / pre-symptomatic
                                                                               transmission. Understands that
                                              https://ltccovid.org/2020/0
                                                                               symptoms for older people are not
                                              5/01/resource-care-homes-
                                                                               the same as for younger people.
                                              strategy-for-infection-
                                              prevention-control-of-
                                              covid-19-based-on-clear-
                                              delineation-of-risk-zones-
                                              update/

 2   Webinar on our                           https://youtu.be/QNN9iTnn        Provides an overview on the strategy
     care homes IPC                           RH0                              above, including explaining the issue
     document                                                                  of asymptomatic and pre-
                                                                               symptomatic transmission and
                                                                               introducing key elements of the
                                                                               document

2. The UK Govt guidance referred to (by letter) in the comparison table
      Core               Date          Link                            Notes
      document

 A    Department         2 April       https://assets.publishing.s     This guidance focuses only on
      of Health &        2020          ervice.gov.uk/government        symptom-based screening, not taking into
      Social Care /                    /uploads/system/uploads/        account asymptomatic / pre-symptomatic
      PHE / CQC /                      attachment_data/file/878        cases. It also says you can give ‘care as
      NHS -                            099/Admission_and_Care_         normal’ for someone who does not have
      ‘Admission                       of_Residents_during_COVI        symptoms (presumably without PPE).
      and Care of                      D-                              It also recommends people with COVID+
      Residents                        19_Incident_in_a_Care_H         tests can be returned to the home. It does
      during Covid-                    ome.pdf                         not focus much on IPC.
      19 Incident in
      a Care Home’                                                     Says it is in the process of being updated.
      guidance

                                                                                                                       3
B   PHE              17 April   https://www.gov.uk/gover      Says it is drawn from ‘C’ below for
    Guidance for     updated    nment/publications/covid-     application in care homes and it is a guide
    working          27 April   19-how-to-work-safely-in-     (but where there is conflict with legislation
    safely in care              care-homes                    then the legislation prevails – so they leave
    homes                                                     the responsibility to the care homes to
                                                              investigate and interpret).
                                                              Some improvements on the A doc above
                                                              with clearer bits on PPE and when to use.
                                                              Brief mentions of possible asymptomatic
                                                              transmission + need for more than just PPE
                                                              – but does not say how to respond to
                                                              these issues.

C   UK Gov –         24 April   https://assets.publishing.s   This is the Govt’s main IPC document
    PHE, NHS,        updated    ervice.gov.uk/government      across hospitals, health centres, care
    PHS, PHA,        27 April   /uploads/system/uploads/      homes etc, from which document B has
    PHW, HPS -                  attachment_data/file/881      drawn. This document has a range of
    COVID-19:                   489/COVID-                    useful information in it and less incorrect
    infection                   19_Infection_prevention_      information than in A – but it’s quite hard
    prevention                  and_control_guidance_co       to locate the key information for use in the
    and control                 mplete.pdf                    case home setting.
    (IPC)
    guidance

D   Table 2 - PHE    8 April    Table 2:                      Tables which indicate the PPE that it is
    guidance on      2020                                     advised that care-workers use in care-
                                https://assets.publishing.s
    PPE in                                                    homes, and for when assessing someone
                                ervice.gov.uk/government
    community                                                 who may have COVID-19.
                                /uploads/system/uploads/
    care settings    9 April
                                attachment_data/file/877      Eye wear protection is just recommended
                     2020
    Table 4 -                   599/T2_Recommended_P          based on risk assessment and based on
    Additional                  PE_for_primary_outpatien      sessional use. We are recommending they
    consideration               t_and_community_care_b        should be used at all times when in contact
    s, in addition              y_setting_poster.pdf          with residents.
    to standard                 Table 4:
    infection and
    prevention                  https://assets.publishing.s
    control                     ervice.gov.uk/government
    precautions                 /uploads/system/uploads/
                                attachment_data/file/879
                                111/T4_poster_Recomme
                                nded_PPE_additional_con
                                siderations_of_COVID-
                                19.pdf

                                                                                                              4
E   Donning and      8 April    Donning:                      This is OK - except it misses a hand-
    doffing                                                   washing step after taking off an apron and
                                https://assets.publishing.s
    guidance                                                  before taking of the mask when doffing.
                                ervice.gov.uk/government
                                                              Risks infecting face.
                                /uploads/system/uploads/
                                attachment_data/file/878      Note that our document follows CDC
                                677/PHE_11606_Putting_        advice, advocating an additional hand
                                on_PPE_062_revised_8_A        hygiene between steps 3 and 4 during
                                pril.pdf                      doffing (i.e. after removing apron, and
                                                              before putting hands near face).
                                Doffing:
                                https://assets.publishing.s
                                ervice.gov.uk/government
                                /uploads/system/uploads/
                                attachment_data/file/878
                                678/PHE_11606_Taking_o
                                ff_PPE_064_revised_8_Ap
                                ril.pdf

F   DH&SC -          15 April   https://assets.publishing.s   Mentions that people who are COVID+ can
    COVID-19:        2020       ervice.gov.uk/government      be sent back to care homes while still
    Our Action       (V1)       /uploads/system/uploads/      positive to free up critical care beds in
    Plan for Adult              attachment_data/file/879      hospitals.
    Social Care                 639/covid-19-adult-social-    But also, that where the care home is not
                                care-action-plan.pdf          able to isolate / cohort them, that they can
                                                              be taken elsewhere for quarantine and
                                                              that the Govt has provided funding to
                                                              support discharge from hospital.

G   Gov.UK –         3 May      https://www.gov.uk/gover      Based on the WHO advice on re-use (6
    Management       2020       nment/publications/wuha       April).
    of shortages                n-novel-coronavirus-          Discusses the need for face fit for FFP2
    in PPE                      infection-prevention-and-     respirators + that they are user specific.
                                control/managing-
                                shortages-in-personal-        Notes where acute shortages of PPE it
                                protective-equipment-ppe      allows the sessional use and reuse of PPE.

H   HM               May        https://assets.publishing.s   This new document has a section on
    Government       2020       ervice.gov.uk/government      protecting care homes (Section 5.2 – page
    – Our plan to               /uploads/system/uploads/      34). For the first time it has a specific focus
                     CP 239
    rebuild: The                attachment_data/file/884      on IPC - as well as testing, workforce,
    UK               (11 May)   760/Our_plan_to_rebuild_      clinical support, guidance and local
    Government’                 The_UK_Government_s_C         authority role.
    s COVID-19                  OVID-                         IPC section says:
    recovery                    19_recovery_strategy.pdf
    strategy                                                  •   Govt stepping in the support PPE to
                                                                  care homes, hospices, residential
                                                                  rehabs and community care orgs.
                                                              •   “It is supporting care homes with
                                                                  extensive guidance, both online and by
                                                                  phone, on how to prevent and control
                                                                                                                5
COVID-19 outbreaks. This includes
                                                                detailed instructions on how to deep
                                                                clean effectively after outbreaks and
                                                                how to enhance regular cleaning
                                                                practices”.
                                                            •   “The NHS has committed to providing a
                                                                named contact to help ‘train the
                                                                trainers’ for every care home that
                                                                wants it by 15 May”.
                                                            •   “The Government expects all care
                                                                homes to restrict all routine and non-
                                                                essential healthcare visits and reduce
                                                                staff movement between homes, in
                                                                order to limit the risk of further
                                                                infection”.

For other Govt and wider references for evidence which support the recommendations in the comparison
table (which follows) – see the end of the document.

                                                                                                         6
UK Government guidance vs our strategy for IPC in care homes
Issue                Govt guidance – UK Govt / PHE / NICE etc                 A    B    C    D   E   F   G   Our guidance          Rationale for our
                                                                                                                                   recommendations
                     (some of which is contradictory)

                     (“Until you need to take a break” = “a session”)                  Page number            (Section number)

3. Critical elements of IPC
3.1 - Zoning /       The following recommendations have some useful           5    7    28                   (1 & 2)               Recommendation for
clarification of     aspects of zoning or consideration of relative risk      10                                                   zoning / TCB is based
                                                                                                             Our
risks / risk areas   areas incorporated in them:                                                                                   on learning from SARS
                                                                              11                             recommendations
                                                                                                                                   in Taiwan, Ebola and
                     •   (A) “Any resident presenting with symptoms of                                       are based around
                                                                                                                                   cholera - to provide
                         COVID-19 should be promptly isolated (see Annex                                     the concept of
                                                                                                                                   nudges for staff to
                         C for further detail), and separated in a single                                    ‘zoning’ / ‘traffic
                                                                                                                                   remember particular
                         room with a separate bathroom, where possible”.                                     control bundling’
                                                                                                                                   transmission risks and
                         “Staff should immediately instigate full infection                                  (TCB) based on
                                                                                                                                   reduce risks. It also
                         control measures to care for the resident with                                      green/amber/red
                                                                                                                                   considers/responds to
                         symptoms, which will avoid the virus spreading to                                   zones
                                                                                                                                   the asymptomatic
                         other residents in the care home and stop staff                                     Plus, when to do      transmission.
                         members becoming infected”.                                                         hand hygiene +
                                                                                                                                   In some places PHE
                     •   (A) Resident contacts are defined as residents                                      change PPE +
                                                                                                                                   guidance seems to
                         that: a) Live in the same unit / floor as the                                       separate staff
                                                                                                                                   focus only on isolating
                         infectious case (e.g. share the same communal                                       groups + keep
                                                                                                                                   and caring for the
                         areas), or b) Have spent more than 15 minutes                                       cleaning
                                                                                                                                   symptomatic residents
                         within 2 metres of an infectious case. [not sure                                    equipment
                                                                                                                                   only and seems to
                         where this 15 min has come from, we understand                                      separate etc.
                                                                                                                                   assume this on its own
                         from experiences in Vancouver that transmission
                                                                                                                                   will prevent infection
                         has happened even with short contact in their
                                                                                                                                   to the other residents.
                         care homes?]

                                                                                                                                                             7
Issue   Govt guidance – UK Govt / PHE / NICE etc                 A   B    C    D   E   F   G   Our guidance        Rationale for our
                                                                                                                   recommendations
        (some of which is contradictory)

        (“Until you need to take a break” = “a session”)                 Page number            (Section number)
        •   (A) “Symptomatic residents should ideally be                                                           It also talks of
            isolated in single occupancy rooms. Where this is                                                      cohorting people with
            not practical, cohort symptomatic residents                                                            symptoms together if
            together in multi-occupancy rooms. Residents                                                           single occupancy
            with suspected COVID-19 should be cohorted only                                                        rooms are not
            with other residents with suspected COVID-19.                                                          available.
            Residents with suspected COVID-19 should not be                                                        But in other places it
            cohorted with residents with confirmed COVID-19.                                                       also recommends
            Do not cohort suspected or confirmed patients                                                          isolating contacts as
            next to immunocompromised residents”.                                                                  well.
        •   (A) Clearly sign the rooms by placing IPC signs,                                                       Scattered throughout
            indicating droplet and contact precautions, at the                                                     the various documents
            entrance of the room.                                                                                  there are some points
        •   (A – Annex C) Re what to do with contacts: states                                                      that suggest some
            to isolate contacts for 14 days ideally in single                                                      form or degree or
            rooms or in groups together. Extremely                                                                 zoning - but they are
            vulnerable residents should be in a single room                                                        time-consuming and
            and only one bathroom.                                                                                 not simple to find to
                                                                                                                   understand the whole
        •   (A – Annex C) It is also recommended that
                                                                                                                   concept and not clear
            residents who have not had any exposure to the
                                                                                                                   in presentation.
            symptomatic case can be cohorted separately in
            another unit within the home away from the                                                             However, instituting
            cases and exposed contacts.                                                                            the zoning or TCB
                                                                                                                   approach would
        •   (A – Annex E) Notes that signage should be used                                                        support a range of the
            to prevent unnecessary entry to the isolation                                                          PHE guidance.
            room, but then also says confidentiality must be

                                                                                                                                            8
Issue   Govt guidance – UK Govt / PHE / NICE etc                   A   B    C    D   E   F   G   Our guidance        Rationale for our
                                                                                                                     recommendations
        (some of which is contradictory)

        (“Until you need to take a break” = “a session”)                   Page number            (Section number)
            maintained [we agree on the need for signage –
            but this risks being contradictory – how can you
            maintain confidentiality if a sign is placed?].
        •   (B) “You and or your manager may want to
            monitor your residents for symptoms. If any of
            your residents develop symptoms, become
            suddenly unwell with a cough and or temperature
            or you are concerned about any of them you must
            inform your manager immediately. Whilst you will
            wear PPE for all patients as per
            recommendations, when you know someone has
            symptoms it may be appropriate to visit those
            individuals at the end of rounds (where safe to do
            so) and discuss with your manager ways you
            might be able to minimise direct contact where
            practical, to further reduce risk to yourself”.
            [doesn’t go into IPC requirements – seems to
            over simplify the situation – just leaving them
            until the end of the rounds]
        •   (C) “A single session refers to a period of time
            where a health and social care worker is
            undertaking duties in a specific clinical care
            setting or exposure environment… A session ends
            when the health and social care worker leaves the
            clinical care setting or exposure environment.
            Once the PPE has been removed it should be
            disposed of safely. The duration of a single session

                                                                                                                                         9
Issue              Govt guidance – UK Govt / PHE / NICE etc                   A    B    C    D   E   F   G   Our guidance        Rationale for our
                                                                                                                                 recommendations
                   (some of which is contradictory)

                   (“Until you need to take a break” = “a session”)                    Page number            (Section number)
                       will vary depending on the clinical activity being
                       undertaken”. [“The clinical care setting or
                       exposure environment” – is effectively saying
                       going between zones]
                   •   (C) “The following important factors would safely
                       reduce gown usage over a session but
                       organisations should develop an implementation
                       and action plan suitable to their organisation: a)
                       Label all higher risk area bays, single rooms,
                       corridors, treatment rooms and nurses’ stations
                       as ‘clinical’ areas within a specific hospital area.
                       Limit ‘non-clinical’ areas to staff kitchen/rest
                       areas and changing room. b) Once gown or
                       coverall is donned, the gown/coverall should
                       remain on the staff member until their next break.
                       Plastic aprons and gloves should be changed
                       between patients (with the notes from aprons
                       highlighted below). C) Staff should doff the gown
                       or coverall only when going from the clinical to
                       nonclinical area of the ward, or if they are leaving
                       the ward for a break”. [This paragraph is
                       effectively zoning]

3.2 - Encourages   These statements which are scattered through the           11   3    13                   (1, 2 and whole     The consideration of
understanding of   documents, highlight some elements of the PHE and               4                         document)           the possible routes for
infection routes   UK Govt understanding of infection routes:                      5                         Our document has    transmission including
and how to                                                                                                                       from asymptomatic
                                                                                                             the understanding
                                                                                                                                 and pre-symptomatic
                                                                                                             of transmission
                                                                                                                                                           10
Issue          Govt guidance – UK Govt / PHE / NICE etc                  A   B    C    D   E   F   G   Our guidance             Rationale for our
                                                                                                                                recommendations
               (some of which is contradictory)

               (“Until you need to take a break” = “a session”)                  Page number            (Section number)
prevent        •   (A) States that “when transferring symptomatic                                      routes - at the core     patients has been the
transmission       residents between rooms, the resident should                                        of its logic - and the   biggest weakness in
                   wear a surgical face mask” [but does not state                                      recommended              the PHE guidance.
                   other PPE for staff or IPC procedures].                                             strategies are           We have stricter
                                                                                                       produced on this
               •   (B) Notes: “PPE is only effective when combined                                                              recommendations for
                                                                                                       basis (such as
                   with: hand hygiene (cleaning your hands regularly                                                            PPE, recommending
                                                                                                       zoning and
                   and appropriately); respiratory hygiene                                                                      that full PPE must be
                                                                                                       understanding
                   https://coronavirusresources.phe.gov.uk/hand-                                                                used when in contact
                                                                                                       asymptomatic and
                   hygiene and avoiding touching your face with                                                                 with any residents at
                                                                                                       pre-symptomatic
                   your hands, and following standard infection                                                                 all times. And also
                                                                                                       spread).
                   prevention and control precautions.                                                                          stressing the
                   www.nice.org.uk/guidance/cg139” [good that it                                       Our guidance also        importance of
                   says you need to follow standard IPC precautions                                    recognises the risk      changing PPE between
                   - but does not give specific guidance – it won’t be                                 from care workers        zones.
                   easy for all care homes to pull out the relevant                                    to the residents as      PHE has recognised
                   guidance needed from the NICE document link                                         well as vice versa.      some risks for
                   provided].                                                                                                   transmission such as
               •   (B) It talks about gloves being to protect you from                                                          through sharing
                   body fluids and secretions [but does not talk                                                                mobility devises,
                   about the virus on solid materials]. It also                                                                 electronic gadgets etc.
                   mentions the mask being to protect the carer,
                   [but not highlighting that it also protects the
                   resident, as the carer can also be asymptomatic].
               •   (B) Recommends only to use a mask but no other
                   PPE needed if within 2m of patients but not
                   touching them, including in communal areas.
                   Does not think that eye protection, plastic apron
                                                                                                                                                          11
Issue   Govt guidance – UK Govt / PHE / NICE etc                   A   B    C    D   E   F   G   Our guidance        Rationale for our
                                                                                                                     recommendations
        (some of which is contradictory)

        (“Until you need to take a break” = “a session”)                   Page number            (Section number)
            or gloves are needed. [we think this is not
            adequate and full PPE should be worn when with
            residents at all times – for example, if a staff
            member is asymptomatic and does not wear a
            mask for example, they can infect surfaces that
            then can be touched by a resident or other staff
            member; and a resident may be asymptomatic
            and cough when not expected, leading to
            droplets into the eyes, or breathe on a staff
            member]
        •   (A) Mentioned dedicating specific medical
            equipment to residents of possible or confirmed
            cases.
        •   (A) Restricts sharing of personal devices.
        •   (C) A precautionary approach is recommended
            and close contact has been defined as within 2
            metres (approximately 6 feet) of a patient due to
            general opinion that droplets tend to not reach
            further than this distance.
        •   (C) “Survival on environmental surfaces is also
            dependent on the surface type. An experimental
            study using a SARS-CoV-2 strain reported viability
            on plastic for up to 72 hours, for 48 hours on
            stainless steel and up to 8 hours on copper”.
        •   (C) “Contact precautions - Used to prevent and
            control infection transmission via direct contact or
                                                                                                                                         12
Issue               Govt guidance – UK Govt / PHE / NICE etc                  A   B    C    D   E   F   G   Our guidance            Rationale for our
                                                                                                                                    recommendations
                    (some of which is contradictory)

                    (“Until you need to take a break” = “a session”)                  Page number            (Section number)
                        indirectly from the immediate care environment
                        (including care equipment). This is the most
                        common route of infection transmission”.

3.3 - Symptomatic   The following points identify the PHE and UK Govt         5   3    11                   (1 & 19)                We believe that any
vs asymptomatic     understanding of the transmission routes of COVID-            6                                                 PHE guidance that
                                                                                                            Our document is
or pre-             19:                                                                                                             does not acknowledge
                                                                                                            based on evidence
symptomatic                                                                                                                         the pre-and
                    •   (A) Care home providers should follow social                                        that spread is likely
transmission                                                                                                                        asymptomatic
                        distancing measures for everyone in the care                                        to be
                                                                                                                                    transmission is not fit
                        home, wherever possible, and the shielding                                          asymptomatic /
                                                                                                                                    for purpose, will give a
                        guidance for the extremely vulnerable group.                                        pre-symptomatic /
                                                                                                                                    false sense of security
                                                                                                            and symptomatic –
                    •   (B) Gives guidance on PPE when touching any                                                                 to staff and will not
                                                                                                            as per evidence
                        resident (with or without symptoms) or when                                                                 prevent infection.
                                                                                                            from Singapore,
                        within 2m of someone coughing [includes full PPE
                                                                                                            USA, Canada,            There is a brief
                        including eye protection – but only said is needed
                                                                                                            Germany etc. [see       mention in B and C but
                        for some residents]. Also gives guidance when
                                                                                                            references at end       does not give
                        more than 2m away / not touching / and in
                                                                                                            of this document]       recommendations for
                        communal areas.
                                                                                                                                    how to respond.
                    •   (B) In the Q&As it recognises that 1/3 of people
                                                                                                                                    C was updated 27 April
                        who test positive may not have symptoms and
                                                                                                                                    - but there have been
                        the risk between resident and staff and vice
                                                                                                                                    papers published in
                        versa. [good to see this acknowledged
                                                                                                                                    April on evidence from
                        somewhere – although it contradicts the doc C]
                                                                                                                                    a number of countries
                    •   (C) “Infection control advice is based on the                                                               in the asymptomatic
                        reasonable assumption that the transmission                                                                 nature of the virus
                        characteristics of COVID-19 are similar to those of                                                         while having the
                        the 2003 SARS-CoV outbreak”. [this is not                                                                   condition for large
                                                                                                                                                               13
Issue   Govt guidance – UK Govt / PHE / NICE etc                   A   B    C    D   E   F   G   Our guidance        Rationale for our
                                                                                                                     recommendations
        (some of which is contradictory)

        (“Until you need to take a break” = “a session”)                   Page number            (Section number)
            reasonable based on the evidence on                                                                      proportions of infected
            asymptomatic and pre-symptomatic positive                                                                cases in care homes
            cases]                                                                                                   and homeless shelters.
        •   (C) “The incubation period is from 1 to 14 days
            (median 5 days). Assessment of the clinical and
            epidemiological characteristics of COVID-19 cases
            suggests that, similar to SARS, most patients will
            not be infectious until the onset of symptoms. In
            most cases, individuals are usually considered
            infectious while they have symptoms; how
            infectious individuals are, depends on the severity
            of their symptoms and stage of their illness”. [this
            is not reasonable based on the evidence on
            asymptomatic and pre-symptomatic positive
            cases]
        •   (C) “The median time from symptom onset to
            clinical recovery for mild cases is approximately 2
            weeks and is 3 to 6 weeks for severe or critical
            cases. There have been case reports that suggest
            possible infectivity prior to the onset of
            symptoms, with detection of SARS-CoV-2 RNA in
            some individuals before the onset of symptoms”.
            [good that it is acknowledged – but they don’t
            suggest what to do about it]
        •   (C) “Further study is required to determine the
            frequency, importance and impact of
            asymptomatic and pre-symptomatic infection, in
                                                                                                                                           14
Issue                Govt guidance – UK Govt / PHE / NICE etc                    A   B    C    D   E   F   G   Our guidance        Rationale for our
                                                                                                                                   recommendations
                     (some of which is contradictory)

                     (“Until you need to take a break” = “a session”)                    Page number            (Section number)
                         terms of transmission risks. From international
                         data, the balance of evidence is that most people
                         will have sufficiently reduced infectivity 7 days
                         after the onset of symptoms”. [they have ignored
                         the people who are asymptomatic and pre-
                         symptomatic]

3.4 - Discharge of   •   (A) “As part of the national effort, the care sector    4                             (1)                  We strongly
COVID+ patients          also plays a vital role in accepting patients as they                                                      recommend that it is
                                                                                                               We do not think      safer for the
into a care home         are discharged from hospital – both because                                           that due to the      government to always
                         recuperation is better in non-acute settings, and                                     infection risks for
                         because hospitals need to have enough beds to                                                              provide alternative
                                                                                                               many vulnerable      quarantine
                         treat acutely sick patients. Residents may also be                                    residents, that any accommodation for
                         admitted to a care home from a home setting.                                          patient who has
                         Some of these patients may have COVID-19,                                                                  people who have been
                                                                                                               COVID+ and has       discharged from
                         whether symptomatic or asymptomatic. All of                                           not had a negative hospital still positive
                         these patients can be safely cared for in a care                                      test, should be
                         home if this guidance is followed”. [but their                                                             with COVID to free up
                                                                                                               entered into a care acute care beds, rather
                         guidance is not strong enough to prevent spread]                                      home until that      than sending them
                     •   (A) “If an individual has no COVID-19 symptoms                                        negative test is     into care homes,
                         or has tested positive for COVID-19 but is no                                         obtained.            where they risk
                         longer showing symptoms and has completed                                             The DHSC plan for    infecting staff and
                         their isolation period, then care should be                                           COVID-19 says that residents. But we
                         provided as normal”. [so, what about people who                                       if effective         understand that some
                         are asymptomatic and pre-symptomatic?]                                                isolation/ cohorting care homes have been
                     •   (A) Negative tests are not required prior to                                          cannot be done       threatened with losing
                         transfers / admissions into the care home.                                            then alternative     funding if they do not
                                                                                                               quarantine           take in residents who
                                                                                                                                                         15
Issue   Govt guidance – UK Govt / PHE / NICE etc                 A   B    C    D   E   F   G   Our guidance          Rationale for our
                                                                                                                     recommendations
        (some of which is contradictory)

        (“Until you need to take a break” = “a session”)                 Page number            (Section number)
        •   (A – Annex D) – If someone is discharged from                                      accommodation.        have not been tested
            hospital with no symptoms of COVID-19 then                                         should be made        or are positive:
            they should provide ‘care as normal’. If they have                                 available.            https://news.sky.com/
            tested positive from COVID and are no longer                                                             story/coronavirus-
                                                                                               Being in a hospital
            showing symptoms and have not yet completed                                                              care-homes-faced-
                                                                                               increases a
            their 14-day isolation, then they should remain in                                                       funding-cut-if-they-
                                                                                               person’s risk of
            room for the rest of the 14 days and staff should                                                        didnt-take-in-covid-19-
                                                                                               catching COVID-19,
            wear PPE.                                                                                                patients-11986578
                                                                                               so we think any
                                                                                               new resident being    It is also concerning
                                                                                               discharged from       that they recommend
                                                                                               hospital or           in (A) that if a person is
                                                                                               otherwise should      discharged from
                                                                                               be isolated for the   hospital to a care
                                                                                               first 14 days on      home without
                                                                                               arrival.              symptoms they should
                                                                                                                     be provided with ‘care
                                                                                                                     as normal’.
                                                                                                                     Being in a hospital
                                                                                                                     increases a person’s
                                                                                                                     risk of catching COVID-
                                                                                                                     19, so we think any
                                                                                                                     new resident should
                                                                                                                     be isolated for the first
                                                                                                                     14 days on arrival.

                                                                                                                                                 16
Issue                 Govt guidance – UK Govt / PHE / NICE etc                  A    B    C    D   E   F   G   Our guidance         Rationale for our
                                                                                                                                    recommendations
                      (some of which is contradictory)

                      (“Until you need to take a break” = “a session”)                   Page number            (Section number)

3.5 -              •      (A) “Care homes should implement daily                5                              (2)                  PHE does not seem to
Acknowledgement           monitoring of COVID-19 symptoms amongst                                                                   recognise the
                                                                                                               We have listed a
of different              residents and care home staff, as residents with                                                          differences in
                                                                                                               range of symptoms
geriatric symptoms        COVID-19 may present with a new continuous                                                                symptoms for older
                                                                                                               that include less
to COVID-19               cough and/or high temperature. Assess each                                                                people and younger
                                                                                                               obvious ones that
                          resident twice daily for the development of a fever                                                       people – older people
                                                                                                               have been noted
                          (≥37.8°C), cough or shortness of breath.                                                                  do not tend to get a
                                                                                                               for older people.
                          Immediately report residents with fever or                                                                cough or fever.
                          respiratory symptoms to NHS 111, as outlined in
                          the section below”. [This ignores that symptoms
                          for older people tend to be different to younger
                          people]

3.6 - Allocation of   These are all positive recommendations in alignment       11        13                   (4)                  The PHE makes some
staff                 with a zoning strategy – but the points are a bit                                                             occasional
                                                                                                               Recommends staff
responsibilities      scattered and not emphasised in the (B) document:                                                             recommendations
                                                                                                               are allocated to
within the home                                                                                                                     about allocation of
                      •   (A) “Staff caring for symptomatic patients should                                    either green,
                                                                                                                                    staff to different areas
                          also be cohorted away from other care home                                           amber or red areas
                                                                                                                                    with symptomatic /
                          residents and other staff, where                                                     (or green and
                                                                                                                                    non symptomatic
                          possible/practical. If possible, staff should only                                   amber + red) to
                                                                                                                                    residents.
                          work with either symptomatic or asymptomatic                                         reduce risk of
                          residents. Where possible, staff who have had                                        transmission.       So, our
                          confirmed COVID-19 and recovered should care                                         And to not mix with recommendation is
                          for COVID-19 patients. Such staff must continue                                                          similar, but just stated
                                                                                                               staff from other
                          to follow the infection control precautions,                                                             more clearly.
                                                                                                               zones during
                          including PPE as outlined in this document”.                                         breaks.

                                                                                                                                                               17
Issue                Govt guidance – UK Govt / PHE / NICE etc                 A    B    C    D   E   F   G   Our guidance         Rationale for our
                                                                                                                                  recommendations
                     (some of which is contradictory)

                     (“Until you need to take a break” = “a session”)                  Page number            (Section number)
                     •   (C) “Assigning a dedicated team of staff to care
                         for patients in isolation/cohort rooms/areas is an
                         additional infection control measure. This should
                         be implemented whenever there are sufficient
                         levels of staff available (so as not to have a
                         negative impact on nonaffected patients’ care)”.
                     •   (C) “Staff who have had confirmed COVID-19 and
                         recovered, should continue to follow the infection
                         control precautions, including personal protective
                         equipment (PPE)”.
                     •   (C) “Domestic/cleaning staff performing
                         environmental decontamination should: a) ideally
                         be allocated to specific area(s) and not be moved
                         between COVID-19 and non-COVID-19 care areas;
                         and b) be trained in which personal protective
                         equipment (PPE) to use and the correct methods
                         of wearing, removing and disposing of PPE”.

3.7 - Isolation vs   Presuming this means when there is a specific            21                             (7)                  Once there is a first
communal sitting     outbreak:                                                                                                    case, then we strongly
                                                                                                             We recommend:
                                                                                                                                  recommend that no
                     •   (A – Annex H) Notes that all gatherings should be                                   • That at the first communal activities
                         cancelled and alternative arrangements to be                                           case within a     should be permitted
                         made for communal activities which incorporate                                         care home, that for the period of the
                         social distancing.                                                                     all communal      outbreak.
                                                                                                                sitting and
                                                                                                                                  Even when there are
                                                                                                                activities should
                                                                                                                                  no people with
                                                                                                                be prohibited
                                                                                                                                                           18
Issue   Govt guidance – UK Govt / PHE / NICE etc           A   B    C    D   E   F   G   Our guidance            Rationale for our
                                                                                                                 recommendations
        (some of which is contradictory)

        (“Until you need to take a break” = “a session”)           Page number               (Section number)
                                                                                               for 2 weeks     symptoms, it is still
                                                                                               minimum - or    possible that people
                                                                                               longer until    are pre or
                                                                                               everyone tests  asymptomatic, and so
                                                                                               negative.       in reality the best
                                                                                                               situation would be for
                                                                                         •     That at all
                                                                                                               everyone to be
                                                                                               times, whether
                                                                                                               isolated in their rooms
                                                                                               there is a case
                                                                                                               all the time, as the
                                                                                               or otherwise,
                                                                                                               general population has
                                                                                               staff should
                                                                                                               been in their houses
                                                                                               have no contact
                                                                                                               (although the general
                                                                                               with anyone
                                                                                                               public has been
                                                                                               (resident or
                                                                                                               allowed out for
                                                                                               staff member)
                                                                                                               exercise).
                                                                                               without
                                                                                               wearing a mask However, for long-
                                                                                               as a minimum, term well-being (in the
                                                                                               and a higher    coming 12 months)
                                                                                               PPE level when there needs to be
                                                                                               in contact with strategies for safe
                                                                                               any resident in socialising /
                                                                                               all zones.      interaction, so we have
                                                                                                               agreed that some form
                                                                                         •     If no outbreak,
                                                                                                               of contact would be
                                                                                               then for the
                                                                                                               beneficial, but it has to
                                                                                               longer-term,
                                                                                                               be with strict
                                                                                               ways to be
                                                                                                               distancing.
                                                                                               found for

                                                                                                                                       19
Issue               Govt guidance – UK Govt / PHE / NICE etc                A   B    C    D   E   F   G   Our guidance             Rationale for our
                                                                                                                                   recommendations
                    (some of which is contradictory)

                    (“Until you need to take a break” = “a session”)                Page number            (Section number)
                                                                                                                communal
                                                                                                                sitting and
                                                                                                                activities – but
                                                                                                                with strict 2m
                                                                                                                social
                                                                                                                distancing and
                                                                                                                use of windows
                                                                                                                or perplex
                                                                                                                sheets between
                                                                                                                people to
                                                                                                                reduce risk of
                                                                                                                transmission.

4. PPE
4.1 – Donning and   •   (B) When removing and replacing PPE, ensure             8                         (9)                      We are recommending
doffing areas           you are 2 metres away from residents and other          9                                                  systematising the
                                                                                                          We have
                        staff – see Donning and Doffing of PPE video                                                               process and awareness
                                                                                                          recommended a
                        www.gov.uk/government/publications/covid-19-                                                               moving from one zone
                                                                                                          dedicated area (or
                        how-to-work-safely-in-carehomes/covid-19-                                                                  to another + correct
                                                                                                          areas in a big
                        putting-on-and-removing-ppe-a-guide-for-care-                                                              putting on/taking off
                                                                                                          home) to
                        homes-video                                                                                                of PPE and to reduce
                                                                                                          systematise
                                                                                                                                   risk of contamination
                    •   (B) Your manager and yourself will need to decide                                 process + have
                                                                                                                                   of clean PPE and/or
                        the best place to do this in the care home e.g.                                   posters to follow
                                                                                                                                   multiple other surface
                        have dedicated area for putting on and taking off                                 for how to don and
                                                                                                                                   or receptacles for used
                        PPE.                                                                              doff + have a tap
                                                                                                                                   PPE.
                                                                                                          and sink and

                                                                                                                                                         20
Issue                Govt guidance – UK Govt / PHE / NICE etc               A    B    C    D   E   F   G   Our guidance          Rationale for our
                                                                                                                                 recommendations
                     (some of which is contradictory)

                     (“Until you need to take a break” = “a session”)                Page number            (Section number)
                                                                                                           containers for
                                                                                                           waste and used
                                                                                                           PPE.

4.2 - Donning and    •   (B) When removing and replacing PPE ensure you          8                         (16)                  To prevent risk of
doffing processes        are 2 metres away from residents and other staff                                                        contamination on face
                                                                                                           Same as PHE
                         – see Donning and Doffing of PPE video                                                                  when removing mask
                                                                                                           guidance except to
                         www.gov.uk/government/publications/covid-19-                                                            and goggles/visor.
                                                                                                           add in additional
                         how-to-work-safely-in-carehomes/covid-19-                                         hand-washing step     Note that with the
                         putting-on-and-removing-ppe-a-guide-for-care-                                     before removing       recommendation to
                         homes-video                                                                       goggles/visor. Ours   only remove apron
                                                                                                           aligns with the       and gloves (and not
                                                                                                           CDC’s.                mask and eye
                                                                                                                                 protection) between
                                                                                                                                 each resident who you
                                                                                                                                 have direct contact
                                                                                                                                 with (in scenario
                                                                                                                                 where not enough
                                                                                                                                 PPE), there is a need to
                                                                                                                                 keep on your mask and
                                                                                                                                 eye protection, and
                                                                                                                                 this complicates the
                                                                                                                                 doffing procedures.

4.3 - PPE - Use of   •   (A) States washing hands with soap and water       17   6        T2           3   (3)                   Gloves on hand-
gloves,                  needed after contact with resident, removal of                   T4               We are stressing      washing is a lesson
handwashing and          PPE and cleaning if equipment and the                                                                   from successes in the
                                                                                                           the need for
                         environment                                                                                             SARS outbreak and
                                                                                                           alcohol gel to be
                                                                                                                                                         21
Issue              Govt guidance – UK Govt / PHE / NICE etc                 A   B    C    D   E   F   G   Our guidance          Rationale for our
                                                                                                                                recommendations
                   (some of which is contradictory)

                   (“Until you need to take a break” = “a session”)                 Page number            (Section number)
handwashing with   •   (A) It states alcohol-based hand rub should be in                                  throughout the        based on basic
gloves                 prominent places ‘where possible’ [this is not                                     care home             understanding of
                       enough]                                                                            including both        transmission risks. We
                                                                                                          sides of every        are concerned that the
                   •   (B) States that gloves should be single use and
                                                                                                          residents’ room       PHE guidance that
                       thrown away after completion of a procedure or
                                                                                                          door.                 does not focus on this
                       task and after each resident. Plus, to care not to
                                                                                                                                gives staff a false sense
                       touch the mouth or eyes when wearing gloves.                                       We have
                                                                                                                                of security when
                                                                                                          emphasised the
                   •   (B) Mentions that handwashing must be                                                                    wearing PPE,
                                                                                                          need for more
                       performed immediately before every episode of                                                            particularly gloves and
                                                                                                          handwashing /
                       care and after any activity or contact that                                                              feel they can touch
                                                                                                          hand gelling while
                       potentially results in your hands being                                                                  anything they like and
                                                                                                          gloves are on in
                       contaminated. This includes removal of PPE,                                                              be safe/not transmit
                                                                                                          between touching
                       equipment decontamination and waste handling.                                                            the virus.
                                                                                                          objects, as well as
                   •   (C) “If wearing an apron rather than a gown (bare                                  when gloves are       The recommendation
                       below the elbows), and it is known or possible                                     off. This is not      for re-use of rubber
                       that forearms have been exposed to respiratory                                     mentioned in PHE      gloves for cleaners is
                       secretions (for example cough droplets) or other                                   guidance.             to enable the nitrile
                       body fluids, hand washing should be extended to                                                          gloves to be available
                                                                                                          We are
                       include both forearms. Wash the forearms first                                                           for the care staff. We
                                                                                                          recommending
                       and then wash the hands”.                                                                                did the same for Ebola.
                                                                                                          that they should be
                   •   (G) States that gloves cannot be re-used.                                          changed between
                                                                                                          people who you
                   •   (G) Further work is being done on validating
                                                                                                          have had direct
                       methods to safely reprocess masks and fluid
                                                                                                          contact with. Plus,
                       repellent gowns is under way and future updates
                                                                                                          that the standard
                       will be circulated when available.
                                                                                                          disposable gloves

                                                                                                                                                        22
Issue                Govt guidance – UK Govt / PHE / NICE etc                 A   B    C    D   E   F   G   Our guidance           Rationale for our
                                                                                                                                   recommendations
                     (some of which is contradictory)

                     (“Until you need to take a break” = “a session”)                 Page number            (Section number)
                                                                                                            should not be re-
                                                                                                            used. This is the
                                                                                                            same as PHE
                                                                                                            guidance.
                                                                                                            We are though
                                                                                                            recommending
                                                                                                            that cleaners can
                                                                                                            use rubber gloves
                                                                                                            to minimise use of
                                                                                                            the nitrile gloves,
                                                                                                            and that the rubber
                                                                                                            gloves can be re-
                                                                                                            used after soaking
                                                                                                            in chlorine. This is
                                                                                                            not in PHE
                                                                                                            guidance.

4.4 – PPE – Use of   •   (B) States that aprons should be single use and          6        T2           3   (9)                    Use of rubber gloves
aprons                   thrown away after completion of a procedure or                    T4                                      to minimise use of the
                                                                                                            We are
                         task and after each resident. Plus, to care not to                                                        nitrile gloves where
                                                                                                            recommending
                         touch the mouth or eyes when wearing gloves.                                                              stocks are low, and
                                                                                                            that aprons should
                                                                                                                                   that the rubber gloves
                     •   (G) States that gowns cannot be re-used.                                           be changed
                                                                                                                                   can be re-used if
                                                                                                            between people
                     •   (A) and (C) – also has similar recommendations                                                            disinfected in chlorine
                                                                                                            who you have had
                         on aprons not to be re-used                                                                               (as we did for Ebola).
                                                                                                            direct contact with.
                                                                                                            Plus, that
                                                                                                            disposable aprons
                                                                                                                                                             23
Issue                Govt guidance – UK Govt / PHE / NICE etc                  A   B    C    D    E   F   G   Our guidance          Rationale for our
                                                                                                                                    recommendations
                     (some of which is contradictory)

                     (“Until you need to take a break” = “a session”)                  Page number             (Section number)
                                                                                                              should not be re-
                                                                                                              used. This is the
                                                                                                              same as PHE
                                                                                                              guidance.
                                                                                                              We are however
                                                                                                              recommending
                                                                                                              that heavy duty
                                                                                                              aprons can be
                                                                                                              reused if
                                                                                                              disinfected by
                                                                                                              soaking in chlorine
                                                                                                              solution as noted.

4.5 - PPE - Use of   The guidance on use of masks is a bit mixed:                  6    32   T2           5   (9)                   It is better to change
face masks                                                                         7    37   T4           6                         the mask between
                     •   (B) It recognises that surgical masks and fluid                                      We are
                                                                                                                                    each resident when in
                         repellent surgical masks (FRSM) are to protect            8                          recommending
                                                                                                                                    contact with them,
                         both the staff and the resident.                                                     that ideally masks
                                                                                                                                    wherever possible, as
                                                                                                              should be changed,
                     •   (B) States that the mask can be used continuously                                                          you do not know if
                                                                                                              after you have had
                         while providing care between patients, until you                                                           they have COVID or
                                                                                                              direct contact with
                         take a break in duties or at the end of your shift.                                                        otherwise.
                                                                                                              a resident.
                     •   (B) “There is no evidence to suggest that                                                                  However, the mask
                                                                                                              But that they can
                         replacing face masks and eye protection between                                                            itself does not touch
                                                                                                              be used for a
                         each resident would reduce risk of infection to                                                            the resident and hence
                                                                                                              session in the same
                         you. In fact, there may be more risk to you by                                                             it does not pose as
                                                                                                              zone, if stocks are
                         repeatedly changing your face mask or eye                                                                  much risk for the next
                                                                                                              too low for new
                                                                                                                                    resident, as gloves or
                                                                                                                                    apron. So, we agree
                                                                                                                                                             24
Issue   Govt guidance – UK Govt / PHE / NICE etc                 A   B    C    D   E   F   G   Our guidance          Rationale for our
                                                                                                                     recommendations
        (some of which is contradictory)

        (“Until you need to take a break” = “a session”)                 Page number            (Section number)
            protection as this may involve touching your face                                  ones between each     with the PHE that use
            unnecessarily”.                                                                    resident.             for sessions within
                                                                                                                     zones should be
        •   (B) “You can wear the same face mask between                                       If PPE stocks are
                                                                                                                     permissible.
            residents whether or not they have symptoms of                                     very low, we are
            COVID-19”. [this should depend on the order in                                     recommending          It is however more
            which you see them – it would not be good to                                       that FFP2/N95 kind    difficult to change an
            wear any PPE after seeing a person with COVID                                      of masks can be re-   apron if a mask and
            and then to a person without it – but the other                                    used but have         visor or goggles remain
            way around does not pose so much risk].                                            given a link to the   on, so this adds a
                                                                                               CDC                   complication.
        •   (B) Also remove and replace if damaged, soiled,
                                                                                               recommendation
            damp, uncomfortable, difficult to breathe                                                                For re-use at a later
                                                                                               for how they
            through                                                                                                  time, then this only
                                                                                               should be re-used.    applies for FFP2/N95
        •   (B) Do not dangle around your neck or put in a
                                                                                                                     masks and not the
            surface for later use
                                                                                                                     surgical or FRSM
        •   (B and G): The Health and Safety Executive                                                               masks.
            recommends that where face masks are to be re-
                                                                                                                     We also feel that the
            used (ones with elastic ear hooks) you should do
                                                                                                                     CDC guidance for re-
            the following: a) carefully fold your face mask so
                                                                                                                     using masks is better
            the outside surface is folded inward and against
                                                                                                                     than the HSE guidance.
            itself to reduce likelihood of contact with the
            outer surface during storage; b) store the folded
            mask between uses in a clean sealable bag/ box
            which is marked with your name and stored in a
            well-defined place; c) practice good hand hygiene
            before and after removal. [it is acknowledged
            that the availability of PPE is challenging and

                                                                                                                                             25
Issue   Govt guidance – UK Govt / PHE / NICE etc                   A   B    C    D   E   F   G   Our guidance        Rationale for our
                                                                                                                     recommendations
        (some of which is contradictory)

        (“Until you need to take a break” = “a session”)                   Page number            (Section number)
            hence why the re-use of masks is being
            promoted, but one challenge with this method is
            that the mask may be wet / damp and hence risks
            not drying when in a sealed bag or box. There are
            also risks that the virus still remains on it, so
            there is some risk of contamination when
            handling. The CDC guidance of having a number
            of masks that mean they are left for the natural
            virus die off responds to this issue before re-use].
        •   (C) “A fluid resistant (Type IIR) surgical facemask
            (FRSM) should be worn whenever a health and
            social care worker enters or is present inpatient
            area (for example, ward) containing possible or
            confirmed COVID-19 cases, whether or not
            involved in direct patient care. For undertaking
            any direct patient care, disposable gloves, aprons
            and eye protection should be worn”.
        •   (C.) “FRSMs are for single use or single session use
            (section 5.6) and then must be discarded. The
            FRSM should be discarded and replaced and NOT
            be subject to continued use in any of the
            circumstances outlined for respirators”.
            [contradicts the statement above from the HSE]
        •   (G) There is insufficient evidence to consider
            homemade masks or cloth masks in health and
            care settings.

                                                                                                                                         26
Issue                Govt guidance – UK Govt / PHE / NICE etc                  A   B    C    D   E   F   G   Our guidance           Rationale for our
                                                                                                                                    recommendations
                     (some of which is contradictory)

                     (“Until you need to take a break” = “a session”)                  Page number            (Section number)

4.6 - PPE - Use of   •   (B) [Bit confusing re continued use or re-use as it       7    35                   (9)                    We also re-used
goggles / visors         states you can use the eye protection                     8                                                goggles / visors after
                                                                                                             We are
                         continuously while providing care, until you need                                                          disinfection during the
                                                                                                             recommending
                         to take a break between duties. But then it says it                                                        Ebola response.
                                                                                                             that ideally,
                         must be decontaminated between uses].                                               goggles/visors
                     •   (B) Also remove and replace if damaged, soiled,                                     should be changed
                         damp, uncomfortable, difficult to breathe                                           between residents
                         through                                                                             after you have had
                                                                                                             direct contact with
                     •   (B) Do not dangle around your neck or put in a
                                                                                                             a resident. But can
                         surface for later use
                                                                                                             be used for a
                     •   (C) “For direct care of possible or confirmed cases                                 session in the same
                         in facilities such as care homes, mental health                                     zone if stocks are
                         inpatient units, learning disability and autism                                     too low for
                         residential units, hospices, prisons and other                                      multiple use.
                         overnight care units, plastic aprons, FRSMs and
                                                                                                             We are
                         gloves should be used. Need for eye protection is
                                                                                                             recommending
                         subject to risk assessment (section 5.7) meaning
                                                                                                             goggles and visors
                         dependent on whether the nature of care and
                                                                                                             can be washed,
                         whether the individual symptoms present risk of
                                                                                                             disinfected and
                         droplet transmission. For further information,
                                                                                                             dried throughout
                         refer to guidance on residential care provision”.
                                                                                                             the day for re-use.
                                                                                                             But that this should
                                                                                                             be done by a
                                                                                                             separate staff
                                                                                                             member, rather
                                                                                                             than the person
                                                                                                                                                              27
Issue                Govt guidance – UK Govt / PHE / NICE etc               A   B    C    D   E   F   G   Our guidance          Rationale for our
                                                                                                                                recommendations
                     (some of which is contradictory)

                     (“Until you need to take a break” = “a session”)               Page number            (Section number)
                                                                                                          themselves taking
                                                                                                          them off, cleaning
                                                                                                          and disinfecting
                                                                                                          them and putting
                                                                                                          them down and
                                                                                                          back on later.

4.7 - PPE – Use of   •   (G) Further work is being done on validating                                 3   (9)                Adds another layer of
gowns or lab coats       methods to safely reprocess masks and fluid                                                         protection to cover the
                                                                                                          We have
                         repellent gowns and future updates will be                                       recommended that scrubs or uniforms,
                         circulated when available.                                                       long-sleeved gowns particularly when
                                                                                                                             handling / touching an
                     •   (G) Says that alternatives to gowns are reusable                                 or washable lab
                                                                                                                             infected or suspected
                         gowns, reusable washable laboratory coats,                                       coats would be
                                                                                                                             resident, as the aprons
                         reusable washable patient gowns or reusable                                      useful where
                                                                                                                             do not cover all areas
                         coveralls.                                                                       possible, with
                                                                                                                             of the staff members
                                                                                                          laundry in house,
                                                                                                                             clothes.
                                                                                                          as part of PPE to
                                                                                                          protect scrubs or  Particularly important
                                                                                                          uniforms when      when being near and
                                                                                                          handling patients. touching a COVID+
                                                                                                                             resident.
                                                                                                          PHE have also
                                                                                                          made this             Logically most useful if
                                                                                                          suggestion in their   these coats get
                                                                                                          working safely in     changed when PPE is
                                                                                                          case homes            changed.
                                                                                                          document (B).

                                                                                                                                                           28
Issue                 Govt guidance – UK Govt / PHE / NICE etc                    A   B    C    D   E   F   G   Our guidance          Rationale for our
                                                                                                                                      recommendations
                      (some of which is contradictory)

                      (“Until you need to take a break” = “a session”)                    Page number            (Section number)

4.8 - PPE for         •   (C) This is noted for staff in operating theatres [so            18                   (9)
aerosol generating        not related to care homes – but interesting point                                     We have included
procedures                raised] - “Staff should wear protective clothing                                      the PHE T2 on PPE
                          (see table 1) but only those within 2 metres of an                                    requirements for
                          aerosol generating procedure, such as performing                                      AGPs.
                          intubation, need to wear FFP3 respirators,
                          disposable fluid repellent coveralls or long sleeved
                          gowns, gloves and eye protection”. – [noted here
                          out of interest that even with an aerosol
                          generating procedure they are saying only those
                          within 2m of the procedure where you need the
                          better PPE. Whereas it is understood that
                          aerosols hang around in the air for quite a while –
                          so this comment does not seem reasonable?]

4.9 - Re-use of PPE   •   (B) “Advice approved by the Health and Safety               9                     5   (9 & 11)              Some is the same
                          Executive on strategies for optimising the use of                                 7   We have suggested recommendation as
                          PPE and consideration for the re-use of PPE when                                  8   that goggles, visors, the PHE.
                          in short supply may be found here:                                                    lab coats/coveralls, Differences:
                          https://www.gov.uk/government/publications/w                                          heavy-duty
                          uhan-novel-coronavirus-infection-prevention-                                                                • You can re-use
                                                                                                                waterproof re-
                          and-control/managing-shortages-in-personal-                                                                     heavy-duty rubber
                                                                                                                usable aprons and
                          protective-equipment-ppe”                                                                                       gloves + a strong
                                                                                                                heavy-duty rubber
                                                                                                                                          waterproof apron
                      •   (G) States that goggles and visors can be re-used,                                    gloves for cleaners
                                                                                                                                          as long as they are
                          but not aprons and gloves.                                                            can be re-used
                                                                                                                                          disinfected
                                                                                                                after suitable
                      •   (G) FRSM and FFP2/3 masks can be used for                                                                       between residents
                                                                                                                disinfection
                          sessional use “in one work area”.
                                                                                                                                                                29
Issue   Govt guidance – UK Govt / PHE / NICE etc              A   B    C    D   E   F   G   Our guidance           Rationale for our
                                                                                                                   recommendations
        (some of which is contradictory)

        (“Until you need to take a break” = “a session”)              Page number            (Section number)
        •   (G) Further work is being done on validating                                    process for the PPE        – we re-used them
            methods to safely reprocess masks and fluid                                     in question.               for Ebola
            repellent gowns is under way and future updates                                 We have also said      •   We don’t think you
            will be circulated when available.                                              that the                   should be
        •   (G) Says that various items can be re-used in                                   googles/visors and         commonly re-using
            these exceptional circumstances but then says …                                 masks can be used          masks in care
            but you should consider the conditions of each                                  by session if not          settings – although
            individual place of work and comply with all                                    enough.                    agree they can be
            applicable legislation including the Health and                                 Strong waterproof          used for sessional
            Safety at Work Act, 1974 [a get out of                                          re-usable aprons           use if not taken off
            responsibility clause for the UK Govt?]                                         must be changed            and not damaged
                                                                                                                       as per PHE
        •   (G) Says that single use PPE should not be re-                                  between residents
                                                                                            if you have handled        guidance.
            used/reprocessed and that reusable PPE should
            be reprocessed in accordance with the                                           a resident in the   •      We have suggested
            manufacturer’s instructions                                                     amber or red               if there is no
                                                                                            zones, but can be          option as PPE is
                                                                                            disinfected.               very low, that CDC
                                                                                            We have                    logic-based
                                                                                            recommended not            guidance on re-use
                                                                                            re-using fluid-            of the higher-grade
                                                                                            repellent surgical         FFP2/N95 type
                                                                                            masks (FRSM/Type           masks is probably
                                                                                            IIR). But we have          the better option.
                                                                                            suggested that             This is where
                                                                                            masks for AGPs (i.e.       masks are
                                                                                            FFP2/N95) can be           allocated to staff
                                                                                            re-used based on           and stored

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