HSPOL10 Lockdown Policy v5 by Provide Community

Lockdown Policy

Version: V5

Ratified by:

Finance and Investment Committee (FIC)

Date ratified: 25/05/2022

Job Title of author:

Health, Safety, Fire and Security Manager –Estates and Facilities

Reviewed by Committee or Expert Group Property Health and Safety Steering Group

Equality Impact Assessed by:

1. Introduction

Lockdown is the process of controlling the movement and access – both entry and exit – of people (staff, patients and visitors) around a site or other specific building / area in response to an identified risk, threat or hazard that might impact on the security of patients, staff and assets or, indeed the capacity of that facility to continue to operate.

A lockdown is achieved through a combination of physical security measures and the deployment of security personnel (where applicable).

A lockdown may be implemented by Provide as part of a security incident or the major incident plan. This may be in partnership with other organisations both NHS and external due to Police intelligence.

Ward Managers may also need to be able to lockdown their own area e.g. in the event of a missing or wandering patient or a possible incident of violence and aggression, where the manager decides to lockdown the area so other patients can’t be affected.

2. Purpose

The purpose of this policy is to provide managers and staff with a toolkit that will enable them to follow appropriate steps to develop a robust plan to achieve a lockdown of the site that they manage/occupy. It is important to remember that many sites/buildings have multi-occupancy arrangements and these must fit with the high level lockdown plan.

3. Definitions

In locking down a facility, there are three key elements; preventing the entry, exit and movement of people on a site, part of a building or in a building or site where Provide services are provided. In preventing the entry, exitor movement of people, or a mixture of the three, the overarching aim of implementing a lockdown is to either exclude or contain staff, patients and visitors.

A lockdown is the process of preventing freedom of entry to, exit from or movement within a site. In this way either contain or exclude staff, patients and visitors. A lockdown may be characterised as either partial (static or portable), progressive or full.

A lockdown can lead to an evacuation. For example, if a lockdown continues to the point at which the organisation can no longer adequately function, a partial or full evacuation of a site or building may be necessary. Therefore a lockdown plan and an evacuation plan are mutually supportive.

All visitors are requested to follow directionsto support a lockdown; however, it isnoted that the containment of any person against their will is prohibited

4. Duties

The Health, Safety, Fire and Security Manager as the Accredited Security Management Specialist (ASMS), is responsible for the development of this policy, following guidance from NHS England.

Engagement with the Police, Fire and Ambulance services along with the local authority will be needed during a lockdown. This will be developed as part of the business continuity plan.

Estates Managers and co-ordinators will be responsible for developing lockdown profiles for all their sites / buildings with help from the Health, Safety, Fire and Security Manager, as required.

5. Consultation and Communication

This policy will be dissemination through the electronic communications of Provide. It will also be published on My Compliance and be available to all staff.

6. Monitoring

The lockdown policy will be reviewed every 2 years, and in accordance with the following on an as and when required basis:

• Legislative changes

• Good practice guidance

• Case law

• Significant incidents reported

• New vulnerabilities

• Changes to organisational infrastructure

7. Controlling Access in the event of a Lockdown

When following assigned duties in the event of a lockdown all employees must remember that because all healthcare sites and buildings are usually open to the public, members of the public have an implied licence to enter them.

However, the owner of any such premises has the right to refuse access to any of these premises. In the absence of the police, who are able to enforce a containment cordon, it will be only lawful for an organisation to prevent the exit of a significant number of people from its premises by utilising specific legislative provision (e.g. emergency regulations under the Civil Contingencies Act and/or Public Health (Control of Infectious Disease) Act 1984) which provides for the protection of the public from notifiable disease.

Even when these specific regulations can be used,specific tenets of the Human Rights Act 1998 must be considered – for example a person’s right to liberty (Article 5) and an individual’s right to a family (Article 12). Without these regulations it is likely that exit could only be prevented in relation to specific individuals in certain circumstances, which are likely to be limited to the following situations:

• The individual is committing an offence or causing injury or damage to property which may lead to him being arrested.

• They are detained under the Mental Health Act or otherwise lawfully detained.

While staff can give direction within their premises (for example, stating which exit someone can use), it is unlawful to forcibly prevent exit from premises unless it is for the reasons stated above. Without these justifications, staff could be open to legal action under criminal and/or civil law if they prevent a person from leaving.

Nonetheless, there may be circumstances when a lockdown from existing premises (or part of them) is desirable. If this occurs, Provide staff can only appeal to individuals to stay in the site and/or building identified for lockdown. If individuals chose to leave then a safe route must be available for them to do so.

8. Partial Lockdown (Static or Portable)

A partial lockdown is the locking down of a specific building or part of a building. The decision to implement a partial lockdown will usually be response to an incident. This response will help to ensure that identified critical assets such as personnel and property are protected.

A partial lockdown which may have been static in nature may evolve into a portable lockdown whereby an ongoing lockdown is moved from one location to another.

9. Progressive Lockdown

A progressive or incremental lockdown can be a step-by-step lockdown of a site or building in response to an escalating scenario.

10.Full Lockdown

A full lockdown is the process of preventing freedom of entry to and exit from either an entire site; specific building or premises that offer Provide services.

It is important to take into consideration that preventing freedom of access to premises at a particular entry point may result in attendees seeking other points of access.

In order to ensure a safe and secure environment it is essential that all relevant stakeholders engage in the development of a robust action plan.

11.Guidance on developing plans for a lockdown

By using the details held within the clinichandbookon site, the Estates/ Ward Manager of each site, in conjunction with the ASMS, will develop and review the lockdown profile:

Key factors in the handbook include:

Identification of local Stakeholders

Identify and complete a critical asset inventory and establish vulnerabilities, for example walk in clinics and generators. This should be done by the business continuity lead in conjunction with the clinical staff that will need to identify specific vulnerabilities surrounding patients.

Categorise the vulnerability of the property or assets:

High Risk – site or part of site/building is a high profile area/building as it contains a critical asset, either physical or non-physical, and the site/building security profile is inadequate to lock it down.

Moderate risk – site or part of site/ building is a moderate-profile area / building, the asset is important but not critical and the building and security profile is marginally adequate but could be improved.

Low risk - site or part of site/ building is not a high profile area/building as it does not contain a critical asset, and the existing building and security profile is adequate.

Develop a Site Profile taking into account the physical geography of the healthcare site – for example, the size of the site, marking out its perimeter, access and egress points, the location and route of communications and the number of buildings on the site. Up to date site maps, floor plans and aerial maps in conjunction with a live walk through should facilitate the development of this profile. This should be done in conjunction with a member of the facilities team and the LSMS.

Create a Building Profile to review the functionality and capability of the buildings to lockdown either fully, partially or progressively. This will include a full inventory of doors and windows and their locations, the ratio of glazing and the ability to control access either manually or automatically. The condition of the premises, its shape and height, whether it has air conditioning and where power supplies are housed will all need to be documented.

Security Profile - This will concentrate on existing security measures and it is important to establish where there are vulnerabilities that may threaten the ability to lock down fully, partially or progressively. In simple terms when reviewing the site it should be considered in concentric rings, the outer perimeter, building perimeter and interior of the buildings. It is recommended that these rings enclose the critical asset so that the robustness of security measures increase towards it. In this way we may have multiple sets of concentric rings within a single site depending on the location of critical assets.

Review of staff support for a lockdown - This will enable Managers to establish who is available to support a lockdown. Consideration should be given to neighbouring locations as arrangements may be put in place to allow staff to be released to support a lockdown.

Following the review of the site, building and security of the premises, managers will be able to develop a planned approach to implementing a lockdown whether it is partial, full or progressive. Using the Lockdown scenario and evaluation framework Appendix I will assist in this task. The local stakeholders should assist and the LSMS will be able to provide support over security issues. When developing a lockdown plan managers should refer to the NHS Security Management Service Lockdown Guidance (LSMS Manual Section 20b).

Equipment review to establish if appropriate equipment is held to support a lockdown. The equipment documented is not exhaustive and the level of equipment required will be dependent on the profile of the building/site and its vulnerability and the likelihood of potential numbers involved in a lockdown situation.

Once a plan has been developed, it is appropriate to test the plan to ensure that it is effective; to identify and to capture any areas of weakness and to feed these into the development of improved procedures. When testing, it is important to consider the implications of a real event taking place at different times and whether in different circumstances the plan would have succeeded.

EQUALITY IMPACT ASSESSMENT TEMPLATE: Stage 1: ‘Screening’

Name of project/policy/strategy (hereafter referred to as “initiative”):

HSPOL10 – Lockdown Policy

Provide a brief summary (bullet points) of the aims of the initiative and main activities:

Project/Policy Manager: Health, Safety, Fire and Security

Date:

This stage establishes whether a proposed initiative will have an impact from an equality perspective on any particular group of people or community – i.e. on the grounds of race (incl. religion/faith), gender (incl. sexual orientation), age, disability, or whether it is “equality neutral” (i.e. have no effect either positive or negative). In the case of gender, consider whether men and women are affected differently.

Q1. Who will benefit from this initiative? Is there likely to be a positive impact on specific groups/communities (whether or not they are the intended beneficiaries), and if so, how? Or is it clear at this stage that it will be equality “neutral”? i.e. will have no particular effect on any group.

Neutral

Q2. Is there likely to be an adverse impact on one or more minority/under-represented or community groups as a result of this initiative? If so, who may be affected and why? Or is it clear at this stage that it will be equality “neutral”?

Neutral

Q3. Is the impact of the initiative – whether positive or negative - significant enough to warrant a more detailed assessment (Stage 2 – see guidance)? If not, will there be monitoring and review to assess the impact over a period time? Briefly (bullet points) give reasons for your answer and any steps you are taking to addressparticular issues, including any consultation with staff or external groups/agencies.

Neutral

Guidelines: Things to consider

Equality impact assessments at Provide take account of relevant equality legislation and include age, (i.e. young and old,); race and ethnicity, gender, disability, religion and faith, and sexual orientation.

The initiative may have a positive, negative or neutral impact, i.e. have no particular effect on the group/community.

Where a negative (i.e. adverse) impact is identified, it may be appropriate to make a more detailed EIA (see Stage 2), or, as important, take early action to redress this – e.g. by abandoning or modifying the initiative. NB: If the initiative contravenes equality legislation, it must be abandoned or modified.

Where an initiative has a positive impact on groups/community relations, the EIA should make this explicit, to enable the outcomes to be monitored over its lifespan.

Where there is a positive impact on particular groups does this mean there could be an adverse impact on others, and if so can this be justified? - e.g. are there other existing or planned initiatives which redress this?

It may not be possible to provide detailed answers to some of these questions at the start of the initiative. The EIA may identify a lack of relevant data, and that data-gathering is a specific action required to inform the initiative as it develops, and also to form part of a continuing evaluation and review process.

It is envisaged that it will be relatively rare for full impact assessments to be carried out at Provide. Usually, where there are particular problems identified in the screening stage, it is envisaged that the approach will be amended at this stage, and/or setting up a monitoring/evaluation system to review a policy’s impact over time.

EQUALITY IMPACT ASSESSMENT TEMPLATE: Stage 2:

(To be used where the ‘screening phase has identified a substantial problem/concern)

This stage examines the initiative in more detail in order to obtain further information where required about its potential adverse or positive impact from an equality perspective. It will help inform whether any action needs to be taken and may form part of a continuing assessment framework as the initiative develops.

Q1. What data/information is there on the target beneficiary groups/communities? Are any of these groups under- or over-represented? Do they have access to the same resources? What are your sources of data and are there any gaps?

N/A

Q2. Is there a potential for this initiative to have a positive impact, such as tackling discrimination, promoting equality of opportunity and good community relations? If yes, how? Which are the main groups it will have an impact on?

N/A

Q3. Will the initiative have an adverse impact on any particular group or community/community relations? If yes, in what way? Will the impact be different for different groups – e.g. men and women?

N/A

Q4. Has there been consultation/is consultation planned with stakeholders/ beneficiaries/ staff who will be affected by the initiative? Summarise (bullet points) any important issues arising from the consultation.

N/A

Q5. Given your answers to the previous questions, how will your plans be revised to reduce/eliminate negative impact or enhance positive impact? Are there specific factors which need to be taken into account?

N/A

Q6. How will the initiative continue to be monitored and evaluated, including its impact on particular groups/ improving community relations? Where appropriate, identify any additional data that will be required.

N/A

Guidelines: Things to consider

An initiative may have a positive impact on some sectors of the community but leave others excluded or feeling they are excluded. Consideration should be given to how this can be tackled or minimised. It is important to ensure that relevant groups/communities are identified who should be consulted. This may require taking positive action to engage with those groups who are traditionally less likely to respond to consultations, and could form a specific part of the initiative. The consultation process should form a meaningful part of the initiative as it develops, and help inform any future action.

If the EIA shows an adverse impact, is this because it contravenes any equality legislation? If so, the initiative must be modified or abandoned. There may be another way to meet the objective(s) of the initiative.

Further information:

Useful Websites www.equalityhumanrights.com Website for new Equality agency www.employers-forum.co.uk – Employers forum on disability www.disabilitynow.org.uk – online disability related newspaper www.womenandequalityunit.gov.uk – Gender issues in more depth www.opportunitynow.org.uk - Employer member organisation (gender) www.efa.org.uk – Employers forum on age www.agepositive.gov.uk – Age issues in more depth

EQUALITY IMPACT ASSESSMENT TEMPLATE: Stage One: ‘Screening’