Our revised COVID-19 Testing Strategy for Wales was launched on 28 January 2021. It sets out how we will deliver on the testing priorities going forward including a focus on testing to support and maintain key services in the public and private sector.
The Welsh Government support for regular asymptomatic testing in private and public sector workplaces in Wales will focus on workplaces with more than 10 employees that cannot work from home.
The approach will include working jointly with the DHSC and engaging with social partners and local public heath teams to agree and support workplace testing with Welsh businesses and organisations.
New testing technology including Lateral Flow Tests (LFT) have started to be deployed more widely and there has been increasing interest from employers about the opportunities these rapid tests could provide in testing asymptomatic employees to reduce the spread of the virus and support employees. Equally, Trade Unions are interested in being reassured that such testing is used responsibly and that trade unions and workers are fully involved in any roll-out of workplace testing. Welsh Government recognises the benefits and through this framework aims to work and support Welsh organisations interested in implementing workplace testing schemes.
Daily contact testing
We are still assessing the role and benefits of Daily Contact Testing (previously referred to as serial testing) in workplaces. This involves testing contacts of positive cases on a daily basis for 7 days as an alternative to self-isolation. We are not currently under the framework including roll out of Daily Contact Testing schemes as work is still on-going on assessing the benefits. We may consider pilots to support evaluation work. These will require agreement of Welsh Government in line with the self-isolation regulations.
Private sector testing schemes
Employers have also introduced their own internal testing programmes outside of the Testing Programme schemes supported by UK and Welsh Governments. It is a voluntary decision for employers to run testing programmes for their staff. Employers must make sure that the test kits they or their provider is procuring is legal in the UK, either through having the CE mark or an exemption. Test kits in the UK are regulated by the MHRA, which is responsible for administering and enforcing the law on medical devices in the UK. It has a range of investigatory and enforcement powers to ensure their safety and quality.
In order for NHS Wales Test, Trace, Protect to undertake contact tracing, anyone with COVID-19 symptoms and/or a positive lateral flow test result from an internal testing programme is asked to book a test and required to self-isolate.
We will further develop guidance and consider if changes are required in regulations in relation to reporting of private testing, especially in the context of the development of new technology and tests. We will also work closely with employers and trade unions to ensure that employees are aware of and can access any support if they are required to self-isolate including the Self-Isolation Support Scheme.
Welsh Government under this framework is looking to work and support employers in Wales on rolling out schemes for regular testing of employees to increase surveillance and find asymptomatic cases faster.
Welsh Government support for workforce testing
The support available for organisations in Wales to introduce a testing scheme includes:
- on-going guidance and support from initial design phase to delivery
- provision of Lateral Flow Devices (LFDs) that have been developed in accordance with scientific validation of lateral flow devices for a time-limited period (initially up to June 2021) to enable workplace testing
- a clinical standard operating procedure (SOP) and guidebooks for workplace testing that covers:
- the worker testing journey tailored to suit the need of the workplace for both sites and self-testing
- the end-to-end process for the workplace with guidance on how to conduct the testing process, including quality assurance and clinical governance processes
- the digital support for the testing process. The online testing portal provides digital solutions covering user registration, results capture and delivery guidance where an employer covers multiple sites. This also enables the lateral flow test results to flow into the Test, Trace and Protect system and for individuals with a positive result to be contact traced
- training – online training covering all aspects of the skills and knowledge required to deliver lateral flow testing.
- follow-up PCR testing will be made available for all lateral flow test positive cases from our testing infrastructure via Regional Testing Sites/Local Testing Sites, Mobile Testing Units, Community Testing Units or home test kits
- support for employees to self-isolate including financial and wider Protect offer activities.
The employer/workplace will be required to resource and fund the testing facilities at sites including PPE, waste management, administration and supervision of the tests and distribution including traceability management for self-test kits.
To access workplace testing support organisations will need to demonstrate:
- they are a recognised body/ registered with companies house & trading
- a clear purpose and plan for testing that is in addition and support Covid-safe working environment, social distancing, good hygiene measures
- they have the resources, capacity and capability to deliver the testing site/ process according the standard operating procedures
- working arrangements with the workforce/ trade unions
The process stages to agreeing and implementing a workplace testing scheme under the framework is set out in Annex A.
Working arrangements for testing schemes
- Before deciding to establish a testing scheme, employers are advised that they are clear on the approach and benefits, who the testing will cover, purpose of the testing, testing process and facilities.
- The scheme is focused on protecting public health. This will include PHW agreement to the operating procedures of schemes supported.
- The scheme is compatible with the employer legal responsibilities to staff including under health and safety, equalities, data protection and employment law.
- Testing is an additional measure and does not replace the need for on-going measures to support Covid secure environments in the workplace and critical measures to safely enable staff to attend the workplace. This includes good social distancing and hygiene measures in the workplace and any other measures agreed with PHW.
- Effective clinical governance is in place according to the standard operating procedure including systems and processes that deliver testing and care to the required standards.
- Risk and incident management systems are in place including audit to reduce risk of errors
- A clear model and end-to-end description should be in place to ensure people and organisations managing the testing have clear accountabilities and handover points.
- Workforce and Trade Union engagement is critical to the success of testing- the employer will work with the workforce and trade unions on the development of the schemes and consulted on the approach outlined in the operating procedures and guidance.
- Before deciding to test staff, it is essential employers and workers understand test reliability and limitations, what a test result actually means and protocols are clearly set out and communicated with the workforce including identification of a positive case and the legal requirement to self-isolate for 10 days.
- Testing of staff to focus on those unable to work from home.
- The introduction of a testing scheme is not used to compel staff to return to the workplace when they are able to work effectively from home
- Testing provided is voluntary. Staff are able to exercise personal choice and decline a test and should not be penalised by their employer for doing so.
- Where a collective agreement exists, there must be a clear statement on how the scheme will operate within this, particularly in relation to sick pay and absence. No worker should be forced to undertake a test or participate in the scheme or else face a financial penalty, as this amounts to compulsion. Clear accessible information on financial support available will be provided.
- Language and communications used to promote the pilot and engage with staff is representative and inclusive.
- An employer must ensure that any lists of members of staff made from collecting their sensitive health data, including their test results, does not result in any unfair or harmful treatment of workers. It would also not be fair to use, or retain, information for purposes staff members were not told about or would not reasonably expect.
- Results are reported into the Test, Trace, Protect system to enable surveillance of the virus and for contact tracing of positive cases and support their employees to comply with the public tracing system.
- Review and feedback from the workforce must be built into the scheme.
If you have any questions on the framework or wish to discuss further please contact: Covid19.WorkplaceTesting@gov.wales
Annex A: Process chart
Initial enquires and expressions of interest on workplace testing to be submitted to the COVID-19 Workplace testing mailbox.
Due Diligence and criteria checks. For the food sector this will involve Food Innovation Wales.
Approvals to progress a workplace testing scheme, including engagement with PHW/LHB/LA and Trade Unions.
Set-up Workplace ATS on DHSC Egress system and workplace leads attend mobilisation webinar.
Risk assessment completed and engage workforce (including TU side) on agreeing and disseminating workplace documents.
Accept T&Cs and mobilise resources including submitting order for tests.
Set up testing site, secure workforce/ supervision for testing and undertake on line training.
Go live with testing.
Continual review and evaluation.