Our responsibilities are
Our headline message to
Government is that the chemical industry needs to keep operating in this
unprecedented climate, so we can keep delivering the key solutions for the
economy, society and, most immediately the NHS and other public and emergency
services. Enabling that to happen requires continued access to raw materials,
the ability to make our products and to get them out of the factories and to
There has rightly been media attention focussed on the
Government on issues of testing and the availability of chemicals. We have said
“While there is of course an escalating demand, there are reagents being
manufactured and delivered to the NHS. Every business here in the UK and
globally is looking at what they can do to help meet the demand as a matter of
To clarify the exact NHS need
and meet it, all relevant UK
industries are continuing to work closely
with Government". We are rightly asked about it because of the word
chemical but it is more an In Vitro Diagnostic industry issue. They and others continue
to work with the NHS to deliver more reagent.
The Science Media Centre comments on this issue: https://www.sciencemediacentre.org/expert-comments-about-reagents-needed-for-covid-19-swab-pcr-testing/
Our key message to Government has been “We are here to help if Government tells us what is needed”
Offer COVID-19 support from your business
(Please use this service to tell the Government how your business might be able to help with the response to COVID-19)
CIA guidance - BPR Sanitiser issues and interpretation
Guidance and Specification from the Government for any manufacturers seeking to make ventilators
Key manufacturing sector employers and trade unions tell government to ‘Let us help’
Letter from Secretary of State for Business, Energy and Industrial Strategy, Alok Sharma MP, to those working in Manufacturing
The chemical industry's practical responses to the national emergency
These are some issues we are working on with member
companies and with Government:
• In the lockdown, the sector is still operating (CIA is working with the Government to ensure that this continues)
• Maintaining key activities when people are absent - difficulties in covering emergency response provision, not cross contaminating shifts and low numbers of first aiders were mentioned.
• Identifying and advising vulnerable staff - guidance on extremely vulnerable whom require ‘shielding’ is clear (1.5 million persons), vulnerable (reportedly 20 million persons) is less so. Some companies use a risk assessment flow chart, those whom are vulnerable can only work on site if the controls can be met.
• Risk assessments – changes made where close proximity working i.e. can the job be done by one person, if not PPE (air hoods), also being done for isolation rooms and management of contractors.
• Free movement of key workers - company letters issued by many companies and some have drafts in place just in case for contractors in the wider network such as cleaners and electricians.
• Recovery ‘restart’ strategies – Members continue with business planning strategies; CIA would like to hear what you are doing around this particularly your top 3 needs for us to take as a collective to government (this could be anything e.g. consistency/continuity…). The guidance from the European Commission and EU-OSHA on recovery, which we mentioned in last week’s call is not yet available.
• Social distancing – HSE have a regulatory role and have recently published a joint statement with the TUC and CBI. https://bit.ly/3apgp9r. Examples of some solutions include canteen use, relaxing timelines on production lines, two-stage risk assessment process reviewing the activity including essential maintenance.
• Shift Work Swaps – The government’s advice only goes so far in terms of the need for minimising social interaction of shift teams and if/when faced with high absenteeism, a pragmatic approach is needed. One member approached this by carrying out a risk assessment, sharing this with their HSE inspector who agreed it is safer to cover absenteeism with shift swops rather than not having enough numbers of competent staff, including emergency responders, on site.
• Temperature screening is being considered by some companies; practical aspects noted around legality (shouldn’t record), availability of thermometers, close proximity of persons needed to carry this out, also person having temperature taken needs to be indoors for 20 minutes first to obtain accurate reading.Some companies are looking to using thermal imaging cameras (hand-held and static). Reports from Italy had shown these were effective.
• Wearing of masks is being considered by some companies, especially for some activities where the 2m social distancing cannot be maintained; practical aspects noted around procurement difficulty in general, using correct type of mask, procedures for putting on/taking off/disposal, and face-fit testing (HSE has new advice related to coronavirus on this https://www.hse.gov.uk/news/face-mask-ppe-rpe-coronavirus.htm .
• Cleaning masks – Members have asked about FFP2/3 and HSE responded saying to contact RPE suppliers and that disposable FFP respirators are not generally intended to be reused. It has also been highlighted by members that manufacturers should be contacted to ensure cleaning guidelines are followed to prevent invalidation of any certification. The U.S. CDC has looked at cleaning of makes of N95 masks and a few P100 types, reporting that some processes such as disinfectant wipes and even soap & water can impair performance - https://www.cdc.gov/coronavirus/2019-ncov/hcp/ppe-strategy/decontamination-reuse-respirators.html
• Testing kits – Availability and reliability (in particular of private kits) were both mentioned in terms of being recognised as part of the government’s strategy for critical workers. Kits should be PHE approved and even if available, after NHS and other healthcare users, there are some implementation practicalities with employment law. On Friday 24/04 the government released details of testing in England, includes chemical manufacturing, for critical workers exhibiting symptoms though an employer referral or self-referral scheme. Ideally, we need the antibody testing as well.
- Letter from DSHC to essential worker employers.
- Guidance: Coronavirus testing for essential workers
- Essential workers: How to book a coronavirus test
• Isolation guidance – there is a difference in the advice issued by PHE and that by the WHO relating to the timelines for those who have been ill; several callers said they were using PHE’s guidance as their point of reference.
• First Aiders – how to protect your first aiders treating someone who may have symptoms of COVID-19 was raised; some companies are referring to government advice for first responders https://www.gov.uk/government/publications/novel-coronavirus-2019-ncov-interim-guidance-for-first-responders/interim-guidance-for-first-responders-and-others-in-close-contact-with-symptomatic-people-with-potential-2019-ncov and others have contacted their first aid provider for advice.
• PPE Resource saving – Members have strategies for resource saving of PPE through applying a set of questions e.g. can work be postponed, can it be done by a few persons. For RPE, some have put in place temporary procedures to enable re-use according to manufacturer guidelines but only where there is strict managerial management and the wearer receives training instruction on removing, storage, re-applying and disposal with responsibility being down to the individual to look after their own mask and not to use disinfectant as can impair performance.
• Mental health and mental wellbeing – There is a continued concern on mental wellbeing of society from COVID-19. NHS have renewed their Every Mind Matters campaign following Office National Statistics reporting 4 out of 5 adults are worried and have published specific advice together with a short film narrated by their Royal Highnesses, the Duke and Duchess of Cambridge which is being broadcast on national television – see https://www.nhs.uk/oneyou/every-mind-matters/ .
Legal / Regulatory
• HSE guidance during COVID-19 – Guidance has been issued on inspection / examination / testing of plant and equipment through COVID-19 https://www.hse.gov.uk/news/work-equipment-coronavirus.htm .
• Regulators (HSE, EA, SEPA and NRW) reported as being pragmatic when approached by businesses with interventions being postponed in some cases, reporting requirements being delayed, making use of Skype calls instead of site visits and also ‘virtual site tours’. Importance of discussing issues directly with the Regulator was highlighted.
• Statutory inspections of related pressure systems (PSSR) was raised in terms of needing more guidance.
• Deferred inspections - insurance cover implications was raised; also, knock on effect to process safety and Safety Integrity Levels (SIL) & and Safety Instrumented Systems (SIS).
• Scottish Environment Protection Agency has a full website dedicate to guidance on regulations during the pandemic: https://coronavirus.sepa.org.uk/. And they published a COVID-19 Philosophy
• Natural Resources Wales' response to the coronavirus pandemic
• To help businesses cope with disruption, the Environment Agency has published temporary COVID-19
regulatory position statements: https://www.gov.uk/government/collections/covid-19-regulatory-position-statements
• Waste storage limits continue to be a concern and it is hoped that once the construction industry is back working, the cement kilns will be back in operation, this will be alleviated.
• Maintaining and recognition of supply chains – keeping contact with both customers and suppliers to ensure they are still open, use of letters demonstrating they are key workers has helped with this; also vital that borders remain open and importance of governments to recognise all levels of these chains in terms of the raw materials needed.
• PPE – Difficulties remain with sourcing PPE for both healthcare and non-healthcare use. Where suppliers have been found, orders placed need to be for large numbers (often in the thousands) and the cost is often much higher that prior to COVID-19; in addition, close attention to specification is needed to ensure the right level of protection is met. It was recommended that a trusted agent / representative or UK government office located in the country is used (China was reported as having stocks). An idea for companies to join together in placing PPE orders was mentioned and CIA will consider what it can do in this respect.
• Request for providing any spare PPE to the NHS volunteers (this is happening already) was identified as a risk in ensuring PPE available for workers.
• Critical supplies stuck at borders particularly those related to maintenance equipment.
• Relaxing competition law to allow delivery companies to work together.
• Risk assessments – some companies using a traffic light approach for assessing supply chains; important to also look for those in the chain who may supply to a critical industry as may impact on your own operations.
• Raw materials / products - No issues were raised.
ICCA Be Smart : Safe Restart
Re-Starting Chemical Production Facilities Post COVID-19 Restrictions.