Fit Testing of Respiratory Protective

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Equality, Good Relations and Human Rights
SCREENING TEMPLATE
***Completed Screening Templates are public documents and will
be posted on the Trust’s website***
See Guidance Notes for further background information on the relevant
legislation and for help in answering the questions on this template (follow the
links).
Completion of screening should lead to one of the following three outcomes:
1. The policy/proposal has been ‘screened in’ for equality impact assessment;
2. The policy/proposal has been ‘screened out’ with mitigation or an alternative
policy/proposal proposed to be adopted;
3. The policy/proposal has been ‘screened out’ without mitigation or an
alternative policy/proposal proposed to be adopted.
The third outcome above will include some policies which are ‘technical’ in
nature and will have no bearing in terms of their likely impact on equality of
opportunity and/or good relations for people within the equality and good
relations categories. Screening will help to identify these types of policies at an
early stage, thus enabling them to be ‘screened out’.
Some policies/proposals may be subject to ongoing screening and further
scrutiny to determine the impact on those directly affected. They are not being
ruled out for a more detailed EQIA but it is not possible at the early stages to
determine the full impact of the policies/proposals, but there is a commitment to
an ongoing assessment. A full EQIA will be carried if at any stage it is deemed
appropriate and necessary to do so.
1.
Information about the Policy/Proposal
Name of the policy/proposal
Fit Testing of Respiratory Protective Equipment (RPE) masks.
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Is this a new, existing or revised policy/proposal?
This is a revised policy. This policy has been updated in line with regional
guidance.
What is it trying to achieve (intended aims/outcomes)?
This policy and procedure is designed to provide a clear, comprehensive and
consistent approach to fit testing of RPE within the BHSCT.
Are there any Section 75 categories which might be expected to benefit
from the intended policy/proposal?
If so, explain how
Not applicable.
Who owns and who implements the policy/proposal - where does it
originate, for example DHSSPS, HSC Board?
Belfast Health and Social Care Trust.
Are there any factors that could contribute to/detract from the intended
aim/outcome of the policy/proposal/decision?
(Financial, legislative or other constraints?)
Availability of a Trust wide fit testing service and availability of respirator masks.
Who are the internal and external stakeholders (actual or potential) that the
policy/proposal/decision could impact upon? (staff, service users, other
public sector organisations, professional bodies, independent sector,
voluntary and community groups, trade unions etc)
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All staff working directly with patients in an environment which requires the
Health Care Worker (HWC) to wear appropriately fitting respiratory protective
equipment, agency staff, nominated visitors
Self-employed persons or contractors working in the Trust in conjunction with
the delivery of the Trust’s Services i.e Estates Services .
Other policies with a bearing on this policy/proposal (for example regional
policies) - what are they and who owns them?
 Management of Tuberculosis (TB) BHSCT Policy 2012
 FFP3 Respirators and Fit Testing Guidance for Health and Social Care
Organisations. Circular Reference:HSC (PHD) Communication 03/2011.
October 2011
 Management of Seasonal Flu 2011/12. DHSSPSNI. HSS (MD) 19/ 2011.
September 2011
 Northern Ireland Regional Infection Control Manual.
 UK Influenza Preparedness Strategy 2011. DoH
 Control of Substances Hazardous to Health (COSHH) BHSCT Policy
March 2011
 BHSCT Interim Flu Guidance. November 2011
 HSE Operational Circular 282/28 (2010)
 Health & Safety Policy 2009
 BHSCT Infection Prevention and Control Management Arrangements
Policy. 2008.
 Clinical Management of TB and measures for prevention and control,
NICE, 2006

2.
Management of Health & Safety at Work (NI) Regulations 2000.
Available evidence
Evidence to help inform the screening template can take many forms, for
example Trust’s own information systems, previous consultations, Audit of
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Inequalities, statistics, research, surveys, Equality Impact Assessments (EQIAs),
complaints or service monitoring.
Using the evidence/information (both qualitative and quantitative) that you
have gathered to inform this screening, please specify details/make up for
each of the Section 75 categories and for both service users and staff.
Category
Gender
Age
Details of evidence/information
Staff
Service Users
All staff who are required to wear
No
appropriately fitting respiratory protective
equipment (RPE) as determined by the
outcome of a COSHH risk assessment.
The proportion of staff employed in the
Belfast Trust is Female 78.4% and Male
21.6%
This Policy does not identify specific
groups of staff thought to be RPE users.
The groupings affected by the Policy
would therefore be the groupings of staff
within the Belfast Trust under section 75.
It is for local managers complete
appropriate COSHH risk assessments to
identify staff who use of RPE in
connection with the delivery of care to
specific patients for part of the working
day.
All
16-24 - 5.4%,
25-34 - 26.0%
35-44 - 27.4%
45-54 - 28.3%
55-64 - 11.6%
65+ - 1.3%
Religion
All
5.5% Not known
45.3% Protestant
49.2% Roman Catholic
Political
Opinion
All
4
Marital
All
Status
Dependent All
Status
Disability
All
Ethnicity
Sexual
All
Orientation
Provide details of how you have involved stakeholders, views of
colleagues, service users and staff etc when gathering evidence.
This policy has been developed in collaboration with the BHSCT Fit Testing
Committee, BHSCT Pandemic Planning Committee and the Trust Joint Health
and Safety Committee which is made up of representation from Directorates
within the BHSCT.
Consultation with employees and Trade Union representatives during the
development of this policy is a legal requirement.
The Trust’s Joint Trust Health & Safety committee and service groups have been
consulted on this policy and procedure.
This consultation process was complete on May 2012
A record of all comments and agreed amendments has been retained.
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3.
Needs, experiences and priorities
Taking into account the information referred to in Table above, what are the
different needs, experiences and priorities of each of the following categories, in
relation to the particular policy/proposal/decision? Specify details for each of the
Section 75 categories and for both service users and staff.
For example if you are relocating a service you will need to consider accessibility
of location, needs of staff with caring responsibilities or reasonable adjustments
for people with disabilities. Is the new location perceived to be welcoming to all
sections of the community? Think about possible unmet need and health
inequalities, for example can people from minority ethnic communities access
your service?
This should not deter the Trust from taking action to address disadvantage
amongst particular sections of society in order to address health and social care
inequalities.
Category
Gender
Details of needs, experiences/priorities
Staff
Local managers will assess the
necessity for staff to complete a
fit test on completion of a
COSHH risk assessment within
their department/facility. They
will also be required to monitor
and review the outcome of the
COSHH risk assessment and
the necessity for staff to wear
RPE and the implementation of
supporting infection control
measures and problems arising
out of this process.
Age
No
Religion
No
Political
Opinion
No
Service Users
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Marital
No
Status
Dependent No
Status
Disability
No
This policy is in line with the
Disability discrimination Act
1995 which places a duty on the
Trust to make reasonable
adjustments when required.
Ethnicity
No
Sexual
No
Orientation
4.
Screening questions
You now have to assess whether the impact of the policy/proposal is major,
minor or none. You will need to make an informed judgement based on the
information you have gathered. Here are some guidelines that might be useful.
In favour of a ‘major’ impact
a) The policy is significant in terms of its strategic importance;
b) Potential equality impacts are unknown, because, for example, there is
insufficient data upon which to make an assessment or because they are
complex, and it would be appropriate to conduct an equality impact assessment
in order to better assess them;
c) Potential equality and/or good relations impacts are likely to be adverse or are
likely to be experienced disproportionately by groups of people including those
who are marginalised or disadvantaged;
d) Further assessment offers a valuable way to examine the evidence and
develop recommendations in respect of a policy about which there are concerns
amongst affected individuals and representative groups, for example in respect
of multiple identities;
e) The policy is likely to be challenged by way of judicial review;
f) The policy is significant in terms of expenditure.
In favour of ‘minor’ impact
a) The policy is not unlawfully discriminatory and any residual potential
impacts on people are judged to be negligible;
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b) The policy, or certain proposals within it, are potentially unlawfully
discriminatory, but this possibility can readily and easily be eliminated by making
appropriate changes to the policy or by adopting appropriate mitigating
measures;
c) Any asymmetrical equality impacts caused by the policy are intentional
because they are specifically designed to promote equality of opportunity for
particular groups of disadvantaged people;
d) By amending the policy there are better opportunities to better promote
equality of opportunity and/or good relations.
In favour of none
a) The policy has no relevance to equality of opportunity or good relations.
b) The policy is purely technical in nature and will have no bearing in terms of its
likely impact on equality of opportunity or good relations for people within the
equality and good relations categories.
4.1 What is the likely impact of equality of opportunity for those affected
by this policy/proposal, for each of the Section 75 equality categories?
Minor/major/none
Section 75 Details of policy/proposal impact
Level of impact?
category
Minor/major/none
Staff
Service Users
Gender
This Policy does not None
No
identify specific
groups of staff
thought to be RPE
users.. The
groupings affected
by the Policy would
therefore be the
groupings of staff
within the Belfast
Trust under section
75. It is for local
managers to identify
staff who use RPE
for a part of the
working day in
connection with the
delivery of care to
specific
patients.However
there is a
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significantly higher
percentage of
female staff to male
staff and therefore
more females will be
affected by this
policy.
Age
No
None
No
Religion
No
None
No
Political
Opinion
Marital
Status
Dependent
Status
Disability
No
None
No
Yes. The majority of None
staff are married
No
None
No
No
None
No
Yes. The majority of None
staff are white with
3.04% from an
ethnic minority
background
Sexual
No. The sexual
None
Orientation orientation of 56.6%
of staff is unknown
No
Ethnicity
No
No
For example does the policy/proposal or proposal disproportionately impact on
men or women? Think about multiple identities, for example women with caring
responsibilities, or older people with disabilities.
4.2 Are there opportunities to better promote equality of opportunity for
people within Section 75 equality categories?
Section 75 If yes, provide details
If no, provide reasons
category
Gender
Not applicable
Age
Not applicable
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Religion
Not applicable
Political
Opinion
Marital
Status
Dependent
Status
Disability
Not applicable
Ethnicity
Not applicable
Sexual
Orientation
Not applicable
Not applicable
Not applicable
Not applicable
For example, when relocating a service has there been engagement with service
users, is there flexibility for staff with caring responsibilities, is there assistance
for additional travel?
4.3 To what extent is the policy/proposal likely to impact on good
relations between people of different religious belief, political opinion or
racial group? minor/major/none
Good
Details of policy/proposal
Level of impact
relations
impact
Minor/major/none
category
Religious
None
belief
Political
opinion
Racial
group
None
None. Details are provided in the
policy regarding translation
services.
For example, is your service/facility welcoming to the whole community?
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4.4 Are there opportunities to better promote good relations between
people of different religious belief, political opinion or racial group?
Good
If yes, provide details
If no, provide details
relations
category
Religious
Not applicable
belief
Political
opinion
Not applicable
Racial
group
Not applicable
For example, have staff been trained on good relations (anti racism and
anti sectarianism)?
5.
Screening decision
A full equality impact assessment (EQIA) is usually confined to those policies or
decisions considered to have major implications for equality of opportunity.
How would you categorise the
impacts of this decision or
policy/proposal? (refer to
guidance notes for guidance on
impact)
Please tick:
Do you consider that this
policy/proposal or decision needs
to be subjected to a full equality
impact assessment?
Please tick:
Major impact
Yes
Minor impact
No
√
No further impact √
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Do you consider the policy/proposal needs to be subjected to ongoing
screening?
Please tick:
Yes
No
√
Please give reasons for your decision.
This policy is designed to ensure that it relates to Trust staff who on the basis of
their role and COSHH risk assessment require a fit test to wear RPE and
provides guidance on how a fit test should be undertaken. This policy and
procedure is designed to provide a clear, comprehensive and consistent
approach to fit testing of RPE within the BHSCT. There is no evidence to
suggest that it would have an adverse impact on any of the Section 75 groups.
does not exclude any particular groups.
If you have identified any impact, what mitigation have you considered to
address this?
Not applicable.
6.
Consideration of disability duties
In what ways does the policy/proposal or decision encourage disabled people to
participate in public life and what else could you do to do so? For example, have
you engaged with disabled people in relation to this policy/proposal/proposal?
How does the policy/proposal or
decision currently encourage
disabled people to participate in
public life?
What else could you do to
encourage disabled people to
participate in public life?
The policy states that it can be
provided in alternative formats and
measures will be taken to assist in
communicating this policy when
required.
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In what ways does the policy/proposal or decision promote positive attitude
towards disabled people and what else could you do to do so?
How does the policy/proposal or
decision currently promote positive
attitudes towards disabled people?
What else could you do to promote
positive attitudes towards disabled
people?
Not required.
None
For example, have your staff received disability equality training or training on
the Trust’s Patient and Client Experience Standards?
7.
Consideration of Human Rights
Does the policy/proposal or decision affect anyone’s Human Rights?
Complete for each of the articles
Article
Positive
impact
Negative
impact =
human
right
interfered
with or
restricted
Neutral
impact
Article 2 – Right to life

Article 3 – Right to freedom from torture,
inhuman or degrading treatment or
punishment
Article 4 – Right to freedom from slavery,
servitude & forced or compulsory labour
Article 5 – Right to liberty & security of person

Article 6 – Right to a fair & public trial within a
reasonable time
Article 7 – Right to freedom from retrospective
criminal law & no punishment without law
Article 8 – Right to respect for private & family
life, home and correspondence.





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Article 9 – Right to freedom of thought,
conscience & religion
Article 10 – Right to freedom of expression

Article 11 – Right to freedom of assembly &
association
Article 12 – Right to marry & found a family

Article 14 – Prohibition of discrimination in the
enjoyment of the convention rights
1st protocol Article 1 – Right to a peaceful
enjoyment of possessions & protection of
property
1st protocol Article 2 – Right of access to
education





If you have identified potential negative impact in relation to any of the Articles in
the table above, speak to your line manager and/or Equality Unit. It may also
be necessary to seek legal advice.
Please outline any actions you will take to promote or raise awareness of human
rights or to ensure compliance with the legislation in relation to the
policy/proposal or decision. For example, staff training and evidence that human
rights have been taken into consideration in decision making processes.
Training is provided on Equal Opportunities to all staff – part of
Statutory/Mandatory Training Matrix
8.
Monitoring
What data will you collect in the future in order to monitor the effect of the
policy/proposal or decision on any of the categories (for equality of opportunity
and good relations, disability duties and human rights?
Equality & Good
Relations
See Below
Disability Duties
See Below
Human Rights
See Below
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The COSHH risk assessment for the use of RPE in the clinical setting facilitates
the identification of staff who are required to complete a fit test and wear RPE as
a significant part of their normal work for the Trust.
Local Managers will be required to monitor and review the implementation of the
required control measures and problems arising out of this process in line with
infection control guidance and COSHH Risk Assessment.
Approved Lead Officer:
Mary Carey
Position:
Senior Manager, Emergency Planning
Date:
16th May 2012
Policy/proposal screened by:
Veronica McEneaney
Please forward completed screening template to the Equality Unit.
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