‘UK Legal Position
Biological Agents (such as SARS-CoV-2) are covered under the Control of Substances Hazardous to Health (COSHH) Regulations 2002.
COSHH provides a framework of actions designed to control risk. from exposure to hazardous substances.’
#AFRSMisNotPPE
/1
‘The Approved Code of Practice (ACOP) to COSHH Regulation 7 states that if employers cannot prevent exposure to a biological agent, they should take steps to ensure that it is controlled adequately & consider all the requirements set out in regulation 7(3), (4), (6) and (7).’
/2
‘They [employers] should apply the principles of good practice and use each requirement where, and to the extent that:
• it is applicable;
• the assessment carried out under regulation 6 shows that it will lead to a reduction in risk.’
/3 #AFRSMIsNotPPE
‘HSE guidance document HSG53 states ‘when in an airborne state, micro-organisms can be classed as particles, so can usually be removed by filter-type Respiratory Protective Equipment (RPE).’
/4
#AFRSMIsNotPPE
‘You should always use equipment fitted with the highest efficiency filter possible (protection factor of at least 20) to control exposure down to the lowest levels.’
Therefore HSE recommends the use of an FFP3 for use against viruses.’
/5
#AFRSMIsNotPPE
Miss that?
‘Therefore HSE recommends the use of an FFP3 for use against viruses.’
‘Therefore HSE recommends the use of an FFP3 for use against viruses.’
‘Therefore HSE recommends the use of an FFP3 for use against viruses.’
/6
#AFRSMIsNotPPE
‘Whilst FFP3 is the usual recommended control measure, it may not be reasonably practicable to use these if global supplies of FFP3 masks are low during a pandemic.
In this scenario, an FFP2 could be used as an alternative, as this is consistent with WHO guidance.’
/7
17 Nov 2021
IPC Cell guidance - unknown members, within @UKHSA
Droplet IPC precautions for SARS2 as it is not ‘wholly’ airborne, unless during an AGP, or in an AGP hotspot.
/8
#AFRSMIsNotPPE
Conclusions:
☣️ UK IPC guidance is in breach of COSHH
☣️ When employers are known to be unable to ‘reasonably question’ IPC guidance, its authors should also be legally accountable.
☣️ The health & safety regulator has failed in its duty to regulate.
/9
#AFRSMIsNotPPE
☣️ 1,600 🇬🇧 HCW deaths isn’t enough to change HMG-linked IPC Cell’s approach, who are *still* more interested in saving their own skin & covering up past errors.
☣️ #Omicron immune escape with greater transmissibility: ready for round 4 of Red Zone Russian roulette?
/10
Summary:
🇬🇧 HCWs 😇
vs
☣️ IPC guidance writers @UKHSA
☣️ @H_S_E
☣️ @CMO_England (all 4 nation CMOs)
☣️ SAGE, NERVTAG,
☣️ @DHSCgovuk (they all know)
☣️ @WHO
‘Pile the bodies high’ 😷🙏🏻💙@YouAreLobbyLud
⚰️ A FRSM is not PPE 🪦
/end.
@mvankerkhove
blogs.bmj.com/bmj/2021/01/29…
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