Guidance for Implementing the Required Testing Order at Managed Isolation and Managed Quarantine Facilities Fifth revised version: 20 April 2021
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Document management and control Published by
Ministry of Health, New Zealand
Revision history Version Date 5.0 19 April 2021
Section/Appendix Full document
Summary of changes Changes to recognise new community cases and presence of more transmissible variants which: • Extend requirements to new worker groups • Increase testing frequency for some existing worker groups • Provide for flexibility in scope of sampling methods • Clarify testing cycle requirements. • Makes use of the Border Workforce Testing Register mandatory for recording keeping and tracking testing status.
Document approval Action Prepared by COVID-19 Testing Team Peer review
Sign-off Final approval
Responsibility Carol Hinton
Date March 2021
Graham Thomas Anthony Davies
March 2021
Clea Marshall
March 2021
Olivia Payne
March 2021
Giselle Wansa-Harvey Manager – COVID-19 Testing Team Darryl Carpenter
19 April 2021 19 April 2021
Group Manager – COVID-19 Testing and Supply
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Table of Contents 1.
Background .......................................................................................................................... 4
2.
Amendments to the Required Testing Order affecting workers in the managed isolation facility and managed quarantine facility contexts .................................................................. 5 New 7-day testing frequency for health practitioners at managed isolation facilities .................. 5 New requirement for workers handling ‘affected items’ to be tested........................................... 6 Clarification of requirements for spacing intervals between regular testing ................................. 8
3.
Additional requirements concerning the obligations of PCBUs/employers to keep records and track workers’ testing status ................................................................................................. 9 Requirements that must be met by PCBUs..................................................................................... 9 Requirements that must be met by workers ................................................................................ 10 The Border Workforce Testing Register........................................................................................ 10
4.
What process will be used to support implementation of required testing (for managed isolation and managed quarantine facilities)?...................................................................... 11
5.
Summary of Roles and Responsibilities ............................................................................... 12
6.
Frequently Asked Questions (FAQs) .................................................................................... 13
Appendix I: Required Testing Order – History............................................................................. 21 Appendix II: Draft template letter for employers to send employees .......................................... 23 Appendix III: Worker group testing requirements ...................................................................... 25 Appendix IV: Examples of “affected workers” handling “affected items” from managed isolation or managed quarantine facilities ......................................................................................... 27
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Guidance for implementing the COVID-19 Public Health Response (Required Testing) Amendment Order 2021 at managed isolation and quarantine facilities 20 April 2021
1.
Background
At 11:59 pm on 21 April 2021 changes to the COVID-19 Public Health Response (Required Testing) Order 2020 (‘the Required Testing Order’) will come into effect. The changes were introduced to further strengthen the border testing regime in response to the new community cases of COVID-19 detected in Auckland in February 2021, and the presence in New Zealand of more transmissible variants of COVID-19, first identified in the United Kingdom, South Africa and Brazil. This guidance explains the changes to the Required Testing Order. It updates the guidance issued on 27 November 2020, when the Required Testing Order was last amended.
The changes This amendment to the Required Testing Order: •
Extends mandatory testing requirements to new groups of border workers, including groups connected to managed isolation facilities and managed quarantine facilities.
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Increases the mandatory testing frequency for certain higher-risk border workers from 14 days to every seven days.
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Provides for flexibility in the scope of sampling methods that can be used.
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Clarifies testing cycle requirements to reflect that the time between tests must not exceed the length of the relevant testing cycle. o
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These changes apply from 22 April 2021.
Makes it mandatory that employers use the Border Workforce Testing Register (BWTR) kept, maintained, and monitored by the Ministry of Health to keep the required records of testing for workers subject to mandatory testing. o
This change applies from 27 April 2021.
This guidance This guidance focuses on explaining the changes to the Required Testing Order in the context of workers at managed isolation facilities and quarantine facilities. The Required Testing Order has been in place since 29 August 2020. Its purpose is to prevent, and limit the risk of, the outbreak or spread of COVID-19 by ensuring specified border workers at risk of exposure to COVID-19 are tested on a regular basis. Regular testing remains necessary due to the incubation period of COVID-19 and risks of re-exposure. The Required Testing Order been amended from time to time to ensure it meets ongoing needs in an ever-shifting environment. Appendix I provides an overview of the development of mandatory worker testing requirements under the Required Testing Order. 4
The decision now to require regular testing of additional groups of border workers, and increase the frequency of testing for some border workers, reflects the need for extra caution and vigilance with the emergence of new and more transmissible strains of the virus. The changes will help to ensure that the right people are being tested and at the right frequencies; and will support compliance with the testing requirements. The additional testing requirements will further strengthen the border, and help keep vulnerable border workers, their families, and communities, safe. The requirements for mandatory testing of border workers are in addition to ongoing public health measures at the border, including physical distancing, appropriate use of personal protective equipment (PPE), application of basic hygiene measures such as handwashing and sanitising, other health screening, and people staying home when sick. Voluntary testing for surveillance purposes will remain available at no cost to those border workers who are not covered by the mandatory requirements in the Required Testing Order.
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Amendments to the Required Testing Order affecting workers in the managed isolation facility and managed quarantine facility contexts
In respect of managed isolation facilities and managed quarantine facilities, the amendment to the Required Testing Order: •
now requires health practitioners at managed isolation facilities to be tested for COVID-19 every seven days (instead of every 14 days) beginning 22 April 2021;
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adds new groups of workers who must be tested every 14 days, beginning 22 April 2021. o
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they are workers who handle ‘affected items’ within 72 hours of their removal from a managed isolation facility or managed quarantine facility and who have contact with ‘affected workers’ at a managed isolation facility or a managed quarantine facility while both are working.
clarifies expectations in respect of testing cycles. The time between required tests must not exceed the length of the relevant testing cycle.
A table of all workers who are required to be tested under the Required Testing Order, and their testing frequencies, is provided in Appendix III
New 7-day testing frequency for health practitioners at managed isolation facilities Prior to this latest amendment to the Required Testing Order coming into force, all workers at managed isolation facilities, including health practitioners, have been on a mandatory 14-day testing cycle. The Required Testing Order has now been amended to increase the frequency of mandatory testing of health practitioners at managed isolation facilities from every 14 days to every seven days.
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The change was made following a review of the risk settings for all workers covered by the Required Testing Order. A small number of worker groups, all within current larger worker groups under the Required Testing Order, were identified as potentially facing a higher risk of exposure to COVID-19 than originally assessed. That is because of the nature of their work and interaction with potentially infectious persons. Because there are likely to be instances where they spend 15 minutes or more in close proximity to a returnee, health practitioners at managed isolation facilities were identified as coming within this higher risk sub-group. What is a health practitioner? The Required Testing Order uses the definition of ‘health practitioner’ from the Health Practitioners Competence Assurance Act 2003: “a person who is, or is deemed to be, registered with an authority as a practitioner of a particular health profession”. A change to a 7-day testing cycle for health practitioners will align with the testing requirements for workers who spend more than 15 minutes on board an internationally arriving aircraft or ship. Other health workers at managed isolation facilities Health practitioners are one sub-group of health workers at managed isolation facilities. While the new 7-day mandatory testing requirement in the Required Testing Order applies to them, all other health workers at managed isolation facilities currently remain subject to the routine 14-day mandatory testing process. It is acknowledged, however, that some of those other health workers at managed isolation facilities may spend 15 minutes or more in close proximity to returnees at the facility. More frequent testing of other health workers at managed isolation facilities Despite the routine 14-day mandatory testing process, it is strongly recommended that health workers, other than health practitioners, who spend 15 minutes or more in close proximity to a returnee at a managed isolation facility are encouraged to be tested every seven days. This cannot be required of them; it is a voluntary option. Please note that the provisions of the Required Testing Order are regularly reviewed and that further amendments can be anticipated, including regarding the wider health workforce at managed isolation facilities.
New requirement for workers handling ‘affected items’ to be tested The Required Testing Order now includes two new groups of workers who handle certain items originating from managed quarantine facilities and managed isolation facilities. Depending on the nature and frequency of their work associated with affected workers at those facilities, these workers must be tested once every 14 days. Others may require more limited testing. Creation of this new group acknowledges that the possibility of fomite transmission of COVID-19 via surfaces has not been ruled out.
New worker groups You are an “affected worker” in the new worker group if you:
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have handled an affected item within 72 hours of its removal from a managed isolation facility or managed quarantine facility, and
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have contact with a member of a group of managed isolation facility or managed quarantine facility workers who are already required to be tested under the Required Testing Order, while both are working.
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“Have contact with”, in relation to the members of different groups, means: o
having face-to-face contact within 2 metres of each other for 15 minutes or more; or
o
being in a confined space within 2 metres of each other for 15 minutes or more.
These workers are required to be tested every 14 days, beginning 22 April 2021. “Members of a group” are all managed quarantine facility and managed isolation facility workers already required to be tested under the Required Testing Order. A table of all workers at or associated with managed isolation and managed quarantine facilities who are required to be tested is provided in Appendix III “Affected workers” can include third party contractors servicing managed isolation or managed quarantine facilities
People not included You are not within scope of this new requirement if: •
you are a worker who only has contact with a worker who has become an affected worker by handling an affected item and meets the ‘contact’ threshold; but
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you yourself have not had contact with a worker at either a managed isolation facility or managed quarantine facility who is already required to be tested.
Affected items An ‘affected item’ is an item removed for cleaning, disposal, and/or re-use from a managed quarantine facility or a managed isolation facility. •
“Re-use” refers to items that are to be re-used in a managed isolation facility or managed quarantine. The re-use does not have to be at the same managed isolation or managed quarantine facility from which the item was removed.
Examples of possible ‘affected items’ in regard to managed isolation facilities or managed quarantine facilities include: •
Laundry processed at an external location (such as but not limited to linen, blankets towels and other such items)
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Managed isolation and managed quarantine worker uniforms and other work clothing to be laundered at an off-site facility
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Rubbish or rubbish containers (including medical waste generated through diagnosis and treatment at the facility, used PPE, personal items discarded by returnees while in MIQF, papers needing to be destroyed as opposed to recycled)
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Materials for recycling (e.g. papers, plastics, glass, furniture office equipment/technology)
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Mail and courier packages (including diplomatic courier packages)
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Delivery baskets (for example, for groceries)
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Rental exercise equipment provided by external contractors
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Machinery, parts or equipment taken off site for service or repair
Note: this is not intended to be an exhaustive list. Appendix IV sets out some examples of situations where workers in the context of managed isolation or quarantine facilities are “affected workers” handling “affected items” and therefore subject to the new testing requirements.
Clarification of requirements for spacing intervals between regular testing The Required Testing Order has been amended to clarify how the requirement testing frequency must be implemented. It now specifies that the time between tests must not exceed the length of the relevant testing cycle. When it commenced in August 2020, the Required Testing Order required certain worker groups to be tested ‘once every 7 days’ or ‘once every 14 days’ from a specified date. The intent was for affected workers to be tested as close to the end of the applicable testing cycle as possible to maximise spacing and increase the chances that testing would detect the presence of COVID-19. It has since become apparent that requirements concerning spacing of tests were open to interpretation. This posed challenges for ensuring the accuracy of test results. The Required Testing Order allowed workers to get tested at any point in their cycle, and this introduced a risk that they may be getting tested before the test could detect infection. It was possible, for example, that an asymptomatic individual on a 14-day cycle might be tested on the first day of their first cycle and on the last day of their second cycle, allowing a gap of 27 days between tests.
New requirement To increase the likelihood of detection of the virus, the timing of tests and the interval between them is important. The Required Testing Order has therefore been amended to clarify that a period longer than 7 days or 14 days (whichever applies for the individual worker) between consecutive tests is prohibited. How intervals between regular testing must be implemented If the applicable testing period is every 7 days, and a person becomes an ‘affected person’ (that is, becomes a member of a worker group in the Required Testing Order who must be tested every 7 days) on 10 May, the affected person’s first test must be no later than 17 May. If recurring testing is required, and the affected person was first tested on 15 May, the second test may not be later than 22 May. If the second test was on 19 May, the third test may not be later than 26 May. The new requirement ensures testing will be spaced regularly and to a cycle that will give the best chance of detecting COVID-19. It does not mean, however, there is no scope for a little flexibility in the spacing of testing, for example for border workers on rosters, or those working irregular hours.
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Requirements concerning timing and spacing of regular tests are further explained in the Frequently Asked Questions (FAQ) section of this document.
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Additional requirements concerning the obligations of PCBUs1/employers to keep records and track workers’ testing status
It is now mandatory for PCBUs/employers of border workers subject to the Required Testing Order to use the BWTR kept, maintained and monitored by the Ministry of Health to keep the required records of testing for staff subject to mandatory testing. Use of the BWTR was previously voluntary.
Requirements that must be met by PCBUs Initial requirements concerning the obligations of PCBUs/employers to monitor and keep records of their workers’ testing status were introduced in the 25 November 2020 amendments to the Required Testing Order. These are summarised below and can be referred to in detail in the consolidated Guidance Manual for Border Worker Testing for COVID-19, available on the Ministry of Health website. PCBUs that employ or engage workers with testing obligations are required to comply with certain duties. Specifically, PCBUs/employers must: •
Notify each affected worker employed or engaged by the PCBU/employer of the requirement to undergo testing and the testing period that applies to the affected person
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Not prevent any affected worker from being tested during their working hours if testing is available during those hours
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Keep certain written records.
Record keeping The records required to be kept by PCBUs/employers are: •
The worker’s full legal name
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The worker’s date of birth
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The testing period that applies to the worker
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The worker’s contact phone number and email address (so they can receive test reminders)
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The dates on which the worker has undergone testing and medical examination
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If the worker has been given a medical exemption, the testing period to which the exemption relates (this does not require the collection of health information about the reason for the exemption).
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A PCBU means a Person Conducting a Business or Undertaking (source: WorkSafe). It is a broader term than ‘employer,’ recognising the variety of employment situations and workplace arrangements. Most New Zealand businesses, whether large corporates, sole traders, or self-employed, are classed as PCBUs. In comparison, an ‘Undertaking’ refers to activities and services such as Government agencies, local councils, school or early childhood education service or charities.
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From 27 April 2021, records are required to be entered by PCBUs/employers on a Register specified by, and kept, maintained and monitored by or on behalf of, the Ministry of Health. Records must be made available as soon as practicable to an enforcement officer if requested. (See information on the BWTR below.)
Requirements that must be met by workers All workers with testing requirements must, as soon as practicable, provide the PCBU/employer that employs or engages them with the following information, or access to this information: •
The worker’s full legal name and date of birth
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The worker’s telephone number
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The testing period that applies to the worker
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The dates on which the worker has undergone testing and medical examination
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If the worker has been given a medical exemption, the testing period to which the exemption applies.
Where any of the worker’s information (above) changes, they must inform their PCBU/employer as soon as practicable once they have been tested. They must also inform their PCBU/employer if they have received a medical exemption for a given testing period, including when it ends.
The Border Workforce Testing Register From 27 April 2021 it will be mandatory for PCBUs to enrol on and use the BWTR to keep the required records of testing for staff subject to mandatory testing under the Required Testing Order. The Ministry of Health developed the BWTR to support PCBUs and workers to meet their obligations under the Required Testing Order in regard to ongoing record keeping and information sharing. The BWTR is an automated secure online tool that tracks and records a border worker’s COVID-19 testing dates and activity. It keeps PCBUs/employers and workers informed about: •
when the worker needs to be tested
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and if the worker has completed a test.
The BWTR records the date a test was undertaken and the date a result was returned. It does not record the results of a test. PCBUs/employers must input into the BWTR the affected worker information specified above on behalf of their affected workers. Workers must supply all specified information to their employers to enable them to do this. The Ministry of Health will monitor the BWTR, review reporting recorded by PCBUs on it, and use its reporting features to identify if a PCBU appears to have failed to keep records and ensure workers are being tested within the timeframes identified in the Register. Mandatory use of the BWTR by PCBUs/employers will support them in fulfilling their obligations to ensure all affected border workers are tested in accordance with their regular cycles. Specifically, mandatory and consistent use of the BWTR by PCBUs/employers will: 10
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ensure they meet their obligations to keep records that can be easily accessed and converted into written form, and to
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ensure their workers know they are required to be tested and their applicable testing cycle.
Mandatory use of the BWTR will also be helpful to: •
increase the accuracy of data held on testing frequency due to its automation function anonymously linking the affected workers test results to their NHI number
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support COVID case investigation. It facilitates early detection of potential transmission linked to an ‘affected worker’ during contact tracing by generating a list of close or casual work contacts who might also have been exposed to the same source.
The BWTR is easy to use and has been designed for all PCBUs/employers to operate quickly, while providing uniform information back to the Ministry of Health. Ministry of Health staff are available to provide ongoing technical support to PCBUs/employers on use of the Register. Demonstrations on how the Register works can be arranged by contacting bwtrsupport@health.govt.nz.
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What process will be used to support implementation of required testing (for managed isolation and managed quarantine facilities)?
The Ministry for Business, Innovation and Employment (MBIE) will notify management of managed isolation and managed quarantine facilities, other PCBUs/employers of workers who work in or for those facilities, or who transport people required to be in isolation or quarantine under a COVID-19 order to or from these facilities, about the changes to the Required Testing Order and this guidance. MBIE will provide guidance and information to support PCBUs/employers to communicate the new duties to their employees and workers. A suggested letter for employers to send their employees /contractors is attached as Appendix II. PCBUs/employers engaging or employing affected workers will implement systems and processes to ensure that they meet their obligations under the Required Testing Order on an ongoing basis: These obligations are to: •
notify each affected person employed or engaged by the relevant PCBU/employer of the requirement to be tested, and the testing period that applies to the affected person
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meet record keeping requirements
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ensure that, where testing is available during work hours, workers are not prevented from accessing that testing.
If requested, DHBs will report in writing the number of workers who are tested, by centre, to the Ministry of Health.
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Summary of Roles and Responsibilities
Ministry of Business, Innovation and Employment (MBIE)
DHBs/PHUs
PCBUs/Employers
Affected Workers
Notifies PCBUs/ employers (including MIQF management) of the Amendment Order and provide guidance material.
Provide the health testing staff and arrange schedules to provide testing at facilities.
Keep records via the Ministry of Health’s Border Workforce Testing Register about workers employed or engaged by them who are required to be tested.
Provide employer with information that will enable them to meet the duties of a PCBU/ employer.
Links PCBUs/ employers to resources for supporting workers who are dealing with logistic or hardship issues that act as a barrier to getting a test completed on time.
Ensure testing data is collected and reported to the Ministry of Health in accordance with the prevailing arrangements
As PCBUs that employ or engage affected workers, DHBs also have the same duties Also has the same and responsibilities as responsibilities as all other relevant other PCBUs/ PCBUs/employers in employers on site at relation to affected managed isolation and workers engaged or quarantine facilities. employed by the DHB working at a managed General Health and isolation or Safety responsibilities. quarantine facility.
Make records available to an enforcement officer if requested. Notify workers of their responsibility to have COVID-19 tests and medical exams, and their required testing frequency.
Present yourself for testing every 7 or 14 days (as applicable). Self-employed/sole trader workers or contractors may need to consider their responsibilities both as an affected worker and as a PCBU.
Must not prevent their workers from being tested during their working hours, if testing is available during those workers’ hours. Self-employed/sole trader workers or contractors may need to consider their responsibilities both as an affected worker and as a PCBU/ employer.
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Frequently Asked Questions (FAQs)
This section sets out responses to frequently asked questions. It is intended to assist understanding and implementation of the requirements of the Required Testing Order. Please direct any further questions not covered by these FAQs to: COVID-19testing@health.govt.nz. 1.
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Why should border workers be tested?
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The aim of these testing measures is to increase the safety of border workers, and to strengthen barriers to prevent COVID-19 entering New Zealand across the border. Workers at borders all have an increased risk of exposure to COVID-19 through interaction with travellers and cargo arriving from overseas. Regular testing of border workers provides assurance that use of personal protective equipment (PPE), practising good hygiene and other public health protection measures are effective.
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It is important to remember that the appropriate use of PPE and other public health measures remain the best ways for border workers to protect themselves from exposure to COVID-19. What types of COVID-19 testing are available to border workers?
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The nasopharyngeal swab, or deep nasal swab, is the preferred option due to its effectiveness in detecting the virus. However, as border workers are undergoing testing regularly, they may ask for the new ‘alternative swab option’, the oropharyngeal and bilateral anterior nasal swab (ONS). This involves a less invasive swab of one nostril and a throat swab.
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Saliva testing is currently available on a voluntary basis for workers in quarantine facilities and in dual purpose facilities functioning in dual roles because this group of workers is at higher risk of exposure to people with COVID-19. It is intended to supplement, but not replace, the two currently available testing methods. Saliva testing has a lower sensitivity than nasopharyngeal swabbing.
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Nasopharyngeal swabs remain the ‘gold standard’ and preferred means of testing for COVID-19 because of their sensitivity.
Most border workers are being vaccinated as a priority group. Will they still need to be tested once they are vaccinated? •
Yes. At this stage border workers will still need to be tested once they are vaccinated. The vaccines will protect individuals from the effects of the virus, however, it is too early for researchers to determine whether a vaccinated person could still transmit the virus to someone else. Until the evidence is clearer, and until we have more individuals in the community vaccinated, the mandatory testing of our border and managed isolation and quarantine workforce needs to continue.
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It is also an important reminder that the vaccines are not a substitute for staying at
home if unwell, as well as using good hygiene practices such as washing hands, coughing and sneezing into your elbow, and wearing PPE while working.
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Where should workers be tested? •
Either at testing sites available at the place of work (i.e. onsite testing facilities at ports, airports, or MIQ facilities), a community testing centre, or another healthcare facility, such as a GP.
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Workers must provide their employer with information about their test to allow the employer to keep the records required by the Required Testing Order. To ensure a record is kept, if a worker goes to a community testing centre, or another healthcare facility to get tested, they should ensure their test is recorded using the appropriate identifier (SURV code) unique to their place of work. Some employers use a voucher system for referring workers to a GP or a community testing centre, which includes the appropriate SURV code. Workers should contact their employer for information.
How does a worker get their test results? •
The worker will be advised of their test results by their testing service provider. This is likely to be by text message.
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If a worker returns a positive test result, they will receive a call from the local Medical Officer of Health and will need to follow the instructions given.
Is there any requirement for an employer to pay workers to be tested when testing must be done in their own time? •
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Payment of workers who are tested in their own time is a matter for individual employers, taking into account their general employment, workplace health and safety obligations and contractual requirements. Employers are encouraged to support staff to be tested.
Do workers need to be off work until they get their test results? •
If you are a border or other worker testing under a mandatory testing requirement such as the Required Testing Order, and you are NOT sick or symptomatic or sick, you can continue working while you wait for your test results.
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Workers should stay home if they are sick and contact Healthline or their medical professional to arrange a test if they are displaying flu-like symptoms. In this situation, they should self-isolate until they get their test results.
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Notwithstanding this advice, if you are a border worker who becomes a close contact of a community case, and are tested on that basis, you required to follow public health advice, including self-isolating at home until you received a negative test result.
What assistance is available to a worker who cannot work due to COVID-19? •
Work and Income administers a leave subsidy scheme to help employers pay their employees who need to self-isolate due to COVID-19 and can’t work from home, in certain situations.
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Details are available at: https://www.workandincome.govt.nz/covid-19/leave-supportscheme/
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Can a worker be exempted from the requirement to be tested? •
10.
How should the mandatory 7-day or 14-day testing cycle be implemented? •
Worker testing must be done at least once within 7 days or 14 days of the work occurring, depending on the applicable testing cycle. Testing dates are calculated as follows:
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In order to increase the likelihood of detection of the virus, timing of the tests and the interval between them is important. Therefore, worker testing:
• 11.
A person can be exempted from the mandatory testing requirements by a suitably qualified health practitioner at the testing site based on medical grounds. A GP or qualified health professional at the testing site, if available, are examples of people who could provide an exemption.
o
should be done on each 7th or 14th day as applicable, rather than earlier in the cycle.
o
must not be done later than the 7th or 14th day on which it is normally due. A worker can be tested slightly earlier than the 7th or 14th day of their usual testing cycle if necessary, but not on or after the 8th or 15th day. The Required Testing Order has now been amended to clarify that a period longer than 7 or 14 days between consecutive tests is prohibited.
o
should occur at evenly spaced 7- or 14-day intervals, and the interval between tests must not be more than 7 or 14 days, depending on the applicable testing cycle.
Notwithstanding this advice, if a worker develops symptoms at any time, they should get tested urgently regardless of when their last test took place or their next one is due.
What happens if a worker is absent from their workplace at the required testing time? •
If workers are absent from their workplace at the required testing time (for example, they are on holiday or not rostered to work during the required testing period), they must still comply with their testing obligations under the Required Testing Order.
•
If such a worker is able to be tested at a location other than their usual workplace testing site (e.g. a community testing centre or at a medical practice), they must advise their employer of the date and location of their test.
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There may be situations, however, where a worker is away from the workplace and is unable to access testing at an alternative location at the required time. In such cases: o
a test a little earlier in the cycle is acceptable but this must be as close to the end of the 7 or 14-day cycle as possible.
o
the test must not be done later than the 7th or 14th day on which it is normally due. To specify, a worker can be tested slightly earlier than the 7th or 14th day of their usual testing cycle, but not on or after the 8th or 15th day. The Required Testing Order has now been amended to clarify that a period longer than 7 or 14 days between consecutive tests is prohibited.
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o •
12.
In this situation the worker’s testing clock would re-set, and the next test would be due on each 7th or 14th day after the latest test.
to access testing at an alternative location at the required time. In such cases: o
a test a little earlier in the cycle is acceptable but this must be as close to the end of the 7 or 14-day cycle as possible.
o
the test must not be done later than the 7th or 14th day on which it is normally due. To specify, a worker can be tested slightly earlier than the 7th or 14th day of their usual testing cycle, but not on or after the 8th or 15th day. The Required Testing Order has now been amended to clarify that a period longer than 7 or 14 days between consecutive tests is prohibited.
o
In this situation the worker’s testing clock would re-set, and the next test would be due on each 7th or 14th day after the latest test.
How do the requirements apply to one-off or intermittent work in affected roles? •
Where someone works in an affected role on a one-off basis, the requirement to be tested is also a one-off. The worker must get tested within the required testing period – i.e. within 7 or 14 days, depending on the applicable testing cycle.
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A further testing round is not triggered unless and until the worker next performs work in a role that brings them in scope of the Required Testing Order.
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Workers that only infrequently or intermittently work in affected roles are required to be tested within 7 days or 14 days, depending on the applicable testing cycle, each time they undertake the work. o
Unlike the situation in question 10 where workers are required to be tested on a regular and ongoing cycle, the optimal time for testing when someone works in an affected role on a one-off or intermittent basis is between day 5 or 7 of that exposure, regardless of the applicable testing cycle. Most people who have been infected would test positive by day 7, whether they are due to be tested on day 7 or day 14 after performing one-off or intermittent work in an affected role.
o
Therefore, it is recommended that in the case of work in an affected role requiring a one-off or intermittent test within 7 or 14 days, it is recommended that the test be done between days 5 and 7.
o
As an additional precaution, it is recommended that a worker subject to a oneoff or intermittent test within 7 days of performing work in an affected role, be tested again within 7 days of that test. This is advised as a prudent approach to ensure that the worker has not been incubating the virus despite returning a negative test between day 5 and 7. However, this additional test is not a legal requirement.
o
An additional test is not considered useful in the case of a worker subject to a 14-day testing cycle, undertaking one-off or intermittent work in an affected role.
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Once the worker has been tested for work performed in an affected role on a one-off or intermittent basis, once they take a break from performing that work, their requirement to be tested pauses and is not triggered until they next perform work in an affected role.
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As for question 10, notwithstanding this advice, if a worker develops symptoms at any time, they should get tested urgently regardless of when their one-off, or intermittent test is due.
What happens if a worker does not get a test at the required intervals? •
It is the responsibility of an affected worker to present themselves for regular testing at the required intervals.
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If a worker does not comply with the mandatory testing requirements, and if the worker is not exempted by a suitably qualified health practitioner based on medical grounds, the worker would be in breach of clause 7 of the Required Testing Order. The individual might receive an infringement notice of $300 for not complying with their obligations. Alternatively, a Court could impose a fine of up to $1000.
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If a worker does not comply with their mandatory testing requirements or the requirement to provide information, we expect their employer would follow up with them in the first instance.
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If the worker still fails to comply with the Required Testing Order, the case can be referred to the Ministry of Health or WorkSafe. These agencies can undertake an enforcement role to ensure PCBUs and individuals meet their obligations.
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A complaint about non-compliance can be made as set out below, and an investigation would then be commenced: o
via email to H&SConcerns@worksafe.govt.nz
o
via the 105 police non-emergency reporting line, or
o
(anonymously) via the Ministry of Health’s Integrity Line (0800 424 888).
How will the new requirements be enforced? •
Enforcement officers are appointed to enforce compliance under the Required Testing Order. This includes Medical Officers of Health for individual enforcement, or WorkSafe inspectors, who are authorised to carry out the functions and powers of an enforcement officer in workplaces which are regulated by WorkSafe.
•
Authorities are taking a graduated approach to enforcement of the Required Testing Order. In the case of non-compliance by a PCBU or a worker, the focus is on encouraging compliance through education.
Do workers need to pay for their COVID-19 test? •
There is no charge for the test for border workers required to be tested under the Required Testing Order, or for their employers. This includes tests accessed through a community testing centre or GP.
•
Voluntary testing is also available to border workers who are not covered by the mandatory requirements, and this is also at no cost to the worker or their employer.
17
16.
17.
What is a PCBU? •
A PCBU means a Person Conducting a Business or Undertaking (source: WorkSafe). It is a broader term than ‘employer,’ recognising the variety of employment situations and workplace arrangements. Most New Zealand businesses, whether large corporates, sole traders, or self-employed, are classed as PCBUs. In comparison, an ‘Undertaking’ refers to activities and services such as Government agencies, local councils, school or early childhood education service or charities.
•
In the context of this guidance a PCBU is essentially the employer of workers at managed isolation facility or quarantine facility, including third party employers of contractors, selfemployed contractors or sole traders working at the facility. Do PCBUs/employers have obligations under the Required Testing Order? •
•
•
Yes. The Required Testing Order imposes obligations on PCBUs/employers to: o
Notify each affected worker employed or engaged by the PCBU/employer of the requirement to undergo testing and the testing period that applies to the affected person,
o
Not prevent any affected worker from being tested during their working hours if testing is available during those hours,
o
Keep certain written records.
The records that are required to be kept by PCBUs/employers are: o
The worker’s full legal name
o
The worker’s date of birth
o
The testing period that applies to the worker
o
The worker’s contact phone number and email address (so they can receive test reminders)
o
The dates on which the worker has undergone testing and medical examination
o
If the worker has been given a medical exemption, the testing period to which the exemption relates (this does not require the collection of health information about the reason for the exemption).
o
From 27 April 2021, records are required to be entered by PCBUs/employers on a Register which is kept, maintained and monitored by, or on behalf of, the Ministry of Health. Records must be made available as soon as practicable to an enforcement officer if requested.
o
See information on the BWTR below.
The Ministry of Health will monitor the BWTR, review reporting recorded by PCBUs on it, and use its reporting features to identify if a PCBU appears to have failed to keep records and ensure workers are being tested within the timeframes identified in the Register.
18
18.
19.
What systems are in place to support implementation of these record keeping and information sharing requirements? •
The Ministry of Health has developed the BWTR which is a secure database that records and tracks workers’ testing dates.
•
From 27 April 2021 it is mandatory for PCBUs/employers to be enrolled on the BWTR, and to use it to meet these record-keeping and testing tracking obligations.
•
The BWTR keeps PCBUs/employers and workers informed about: o
when workers need to be tested, and
o
whether they have completed a test.
•
The BWTR does not record the results of any worker’s test. It only records the date that the swab was taken, and the date that the result was returned. Protecting the privacy of workers’ health information is important so any positive test results will be managed separately by the contact tracing team.
•
The BWTR is easy to use and has been designed for all PCBUs/employers to operate quickly, while providing uniform information back to the Ministry of Health.
•
Ministry of Health staff are available to provide ongoing technical support to PCBUs on use of the Register. Demonstrations on how the Register works can be arranged through bwtrsupport@health.govt.nz.
How does the Required Testing Order affect self-employed people who are affected workers? •
Someone who is self-employed is a PCBU in their own right and will need to consider how they comply with the Required Testing Order as both an employer and as an affected worker.
Questions specific to workers in or associated with managed isolation and managed quarantine facilities 20.
Which workers in managed isolation and managed quarantine facilities must be tested, and how often must they be tested? •
•
You are required to be tested every 7 days if you: o
are a worker in a managed quarantine facility.
o
are a worker who transports persons required to be in isolation or quarantine under a COVID-19 Order to or from managed quarantine facilities.
o
are a health practitioner working at managed isolation facilities.
You are required to be tested every 14 days if you: o
are a worker in a managed isolation facility.
o
are a worker who transports persons required to be in isolation or quarantine under COVID-19 Order to or from managed isolation facilities.
19
o
are a worker: ▪
who handles affected items that have been removed from a managed isolation facility or a managed quarantine facility within 72 hours of the item being removed from the facility, and
▪
who has contact with a worker at a managed quarantine facility or managed isolation facility already required to be tested under the Required Testing Order’ and both are working at the time of “contact.”
A table of affected workers in managed solation or quarantine facilities is provided in Appendix III. o
•
21.
are a third-party contractor servicing managed isolation or quarantine facilities, who meets the conditions described above. •
To determine if a worker in a managed isolation or quarantine facility comes under this category, “affected items” are items that have been removed from the facility for cleaning, disposal and/or re-use.
•
For instance, “affected items” might include items such as: laundry (if processed at an external location), rubbish (including medical waste generated through diagnosis and treatment at the facility), materials for recycling (paper, plastics, glass), machinery or equipment taken off site for service or repair.
“Have contact with”, in relation to the members of different groups, means: o
having face-to-face contact within 2 metres of each other for 15 minutes or more; or
o
being in a confined space within 2 metres of each other for 15 minutes or more.
When do workers in managed isolation and quarantine facilities have an exemption from being tested under the Required Testing Order? •
When a health practitioner at the place of testing decides that it would be inappropriate for the person to undergo that testing and medical examination.
20
Appendix I: Required Testing Order – History The COVID-19 Public Health Response (Required Testing) Order 2020 (the Required Testing Order) has been amended several times since it commenced. This appendix provides a brief overview of the history of the Required Testing Order for additional context.
The Required Testing Order as originally made The Required Testing Order commenced at 11.59 pm on 27 August 2020. It aimed to prevent, and limit the risk of, the outbreak or spread of COVID-19 by requiring testing and medical examination of certain higher risk border workers, being those who work in managed isolation and quarantine facilities, as well as workers at ports and airports at higher risk of exposure to COVID-19. Specifically, the Required Testing Order required one-off testing of higher-risk workers at Auckland International Airport, certain higher-risk workers at the Ports of Auckland and Port of Tauranga, and workers at managed isolation and quarantine facilities.
Overview of main changes to the Order The first set of amendments The COVID-19 Public Health Response (Required Testing) Amendment Order 2020 came into force from 11.59 pm on 6 September 2020 and amended the Required Testing Order to require regular routine testing of certain higher-risk border workers at Auckland International Airport, Ports of Auckland and Port of Tauranga, The second set of amendments The COVID-19 Public Health Response (Required Testing) Amendment Order (No 2) 2020 came into force at 11.59 pm on 6 September 2020. The amendments extended the testing and medical examination requirement to specified groups of affected persons at all airports and ports unless exempted. The third set of amendments The COVID-19 Public Health Response (Required Testing) Amendment Order (No 3) 2020 came into force at 11.59 pm on 25 November 2020. This amendment to the Required Testing Order introduced further changes to mandatory testing requirements: •
new duties on PCBUs to keep records and facilitate compliance,
•
requirements for workers to give certain information to their PCBU,
•
changes to some of the groups required to be tested and frequency of testing for some affected workers.
This fourth set of amendments The COVID-19 Public Health Response (Air Border, Isolation and Quarantine, and Required Testing) Amendment Order 2021 came into force at 11.59 pm on 18 April 2021. This amendment to the Order enables quarantine-free travel (QFT) flights between New Zealand and Australia, the Cook Islands and Niue involving designated airlines and airports. To fly on a QFT flight, passengers need to meet a range of pre-boarding requirements, including health requirements such as not having any pre-existing condition that causes symptoms consistent with COVID-19. 21
This fifth set of amendments At 11:59 p.m. on 21 April 2021 the COVID-19 Public Health Response (Required Testing) Amendment Order 2021 comes into effect. This introduces changes to strengthen the border testing regime as a result of the new community cases announced in Auckland in February 2021, and the presence in New Zealand of more transmissible variants of COVID-19. The changes in this amendment: •
extend mandatory testing requirements to new groups of border workers;
•
increase the mandatory testing frequency for certain higher-risk border workers to every seven days;
•
allow flexibility in the scope of sampling methods that can be used;
•
clarify testing cycle requirements to reflect that the time between tests must not exceed the length of the relevant testing cycle.
These changes will take effect from 22 April 2021. A further change makes it mandatory for PCBUs/employers to use the BWTR kept, maintained and monitored by the Ministry of Health to keep the required records of testing for workers subject to mandatory testing. This change will take effect from 27 April 2021. The changes that affect workers at managed isolation facilities or quarantine facilities are explained in more detail in this guidance.
22
Appendix II: Draft template letter for employers to send employees Important note: To meet the duty of a PCBU/employer to facilitate compliance with testing and medical examination requirements, PCBUs/employers must provide specific information to their worker, which informs them of: •
The requirement to undergo testing and medical examination; and
•
The testing period that applies to the affected person.
This draft letter does not meet this requirement, as it is not specific to the individual worker – it is provided to assist PCBUs/employers with communicating the newly amended Required Testing Order requirements to their workers only. Dear [Name of employee] The COVID-19 Public Health Response (Required Testing Order) 2020 (the Required Testing Order) requires certain workers at higher-risk of workplace exposure to COVID-19 to undergo regular testing. As of 11.59 pm on 21 April 2021 changes have been made to the Required Testing Order to further strengthen the border testing regime. These changes are in response to the new community cases detected in Auckland in February 2021, and the presence in New Zealand of more transmissible variants of COVID-19, first identified in the UK, South Africa and Brazil. Workers in many roles have been required to be tested for some time. They continue to need to be tested. We thank you for your continued co-operation if you work in one of the roles. Under the Required Testing Order the following new group of workers must be tested every 14 days: •
•
workers who handle affected items within 72 hours of the item’s removal from: o
a managed isolation facility or
o
a managed quarantine facility, and
who have contact with any managed isolation facility worker or managed quarantine facility worker subject to routine testing under the Required Testing Order and both are working.
Note: In the context of managed isolation facilities and managed quarantine facilities, an “affected item” is an item removed from such a facility for cleaning, disposal, and/or re-use •
“Re-use” refers to items that are to be re-used in a managed isolation facility or managed quarantine. The re-use does not have to be at the same managed isolation or managed quarantine from which the item was removed.
•
“Have contact with”, in relation to contact with a managed isolation facility worker or managed quarantine facility worker already subject to the Required Testing Order, means:
•
o
having face-to-face contact within 2 metres of each other for 15 minutes or more; or
o
being in a confined space within 2 metres of each other for 15 minutes or more.
If you are a third-party contractor providing services to managed isolation facilities or managed quarantine facilities who meets the conditions described above, you will be included in this category. 23
•
The frequency of mandatory testing of Health Practitioners working at managed isolation facilities is increased from every 14 days to every seven days.
•
Testing cycle requirements are clarified to reflect that the time between tests must not exceed the length of the relevant testing cycle.
More information about the groups of workers required to be tested can be found in the accompanying FAQ sheet. [Include this sentence if the employer is attaching the FAQ sheet.] If you perform work in an affected role, you must get tested, unless you have a particular physical or other need that a suitably qualified health practitioner at the testing site determines would make it inappropriate for you to be tested. We will be providing further information on how and where to get tested. [The employer can insert specific requirements applying to the worker here. The Required Testing Order requires that, as your employer, we must notify you of the requirement to be tested and keep certain written records that enable us to check that you are being tested. The records we are required to keep are: •
Your full legal name and date of birth,
•
Your telephone number,
•
The testing period that applies to you,
•
The dates on which you have undergone testing and medical examination in accordance with the testing period that applies to you,
•
If you are exempted from testing and medical examination on medical grounds, the testing period to which the exemption relates.
You will need to provide us with this information, or enable us to access this information, so that these records can be kept. You will receive further information about how this information will be collected at our workplace [or employer can insert information here]. If you have questions about how you should provide this information, please discuss these with me. The purpose of these mandatory testing requirements is to ensure that the measures we have in place to keep you safe are working and to keep COVID-19 out of New Zealand communities. Please continue to use your PPE properly, practise good hygiene, use physical distancing where possible and stay alert to the symptoms of COVID-19. You play a vital role in keeping our workplace, communities and whānau safe. I thank you for your efforts so far and for your ongoing co-operation with the testing requirements.
Your sincerely
[Name of employer] Recommended attachment: FAQs drawn from this guidance
24
Appendix III: Worker group testing requirements Excerpt from COVID-19 Public Health Response (Required Testing) Order 2020: Schedule 2: Groups of affected workers at managed isolation facilities (part 2), managed quarantine facilities (part 1) and affected items (part 6) Item
Group
Testing centre
Testing period
Part 1: Groups in relation to managed quarantine facilities 1.1
Workers at managed quarantine facilities
Community testing centre, testing centre at quarantine facility, or other healthcare facility
Once every 7 days starting on 7 September 2020
1.2
Workers who transport to or from managed quarantine facilities persons required to be in isolation or quarantine under a COVID-19 order
Community testing centre, testing centre at quarantine facility, or other healthcare facility
Once every 7 days starting on 7 September 2020
Part 2: Groups in relation to managed isolation facilities 2.1
Workers at managed isolation facilities
Community testing centre, testing centre at isolation facility, or other healthcare facility
Once every 14 days starting on 7 September 2020
2.2
Workers who transport to or from managed isolation facilities persons required to be in isolation or quarantine under a COVID-19 order
Community testing centre, testing centre at isolation facility, or other healthcare facility
Once every 14 days starting on 7 September 2020
2.3
Health practitioners working at managed isolation facilities
Community testing centre, testing centre at isolation facility, or other healthcare facility
Once every 7 days starting on 22 April 2021
Part 6: Groups in relation to affected items 6.1
Workers who handle affected items within 72 hours of their removal from managed quarantine facilities and who, while working, have contact with members of groups specified in Part 1 or 2 of this table
Community testing centre, testing centre at quarantine facility, or other healthcare facility
Once every 14 days starting on 22 April 2021
6.2
Workers who handle affected items within 72 hours of their removal from managed isolation facilities and who, while working, have contact with members of groups specified in Parts 1 or 2 of this table
Community testing centre, testing centre at isolation facility, or other healthcare facility
Once every 14 days starting on 22 April 2021
25
Explanatory note: Health practitioners working at managed isolation facilities can fall under two worker groups in this Schedule i.e. general ‘workers at managed isolation facilities’ (a 14-day testing requirement applies) and the new group of ‘health practitioners working at managed isolation facilities (a 7-day testing requirement applies). However, because clause 7(2) of the Required Testing Order requires that workers who fall under two groups must be tested at the most frequent testing period, health practitioners working at managed isolation facilities must be tested once every 7 days.
26
Appendix IV: Examples of “affected workers” handling “affected items” from managed isolation or managed quarantine facilities 1.
Summary of new testing groups required to be tested in relation to affected items
A worker will need to answer “YES” to all of the item questions AND all of the interaction questions to fall within the new “affected workers handling affected items” group and be under a requirement to be tested. Item Question:
A: Have you handled an item that meets the following requirements? the item has been removed from a managed isolation facility or managed quarantine facility for the purposes of: ▪ disposal ▪ re-use at any facility ▪ cleaning
YES
NO
Move to question B
No test required Item Question:
B: If you answered yes to question A, have you handled the item which satisfies all elements of question A within 72 hours of the item being removed from the managed isolation facility or managed quarantine facility?
NO
YES
C
Move to question C
No test required Interaction Questions:
C: In addition to answering “yes” to Question A and B in the item questions, have you: o
Spent 15 minutes or more, either in face to face contact (within 2 metres) with, or in a confined space (within 2 metres) with someone who is required to be tested because they: ▪ are a worker at a managed isolation or managed quarantine facility ▪ transport to or from managed quarantine facilities persons required to be in isolation or quarantine under a COVID-19 order ▪ a health practitioner working at a managed isolation facility
NO
No test required
C YES
If Yes to A, B & C, a test is required
27
Example 1: A health worker at a hotel being used as a managed quarantine facility needs to replenish off-site a medical kit for future use at that facility. The hotel is subject to the “affected items: provisions of the Required Testing Order. The medical kit is being removed for the purpose of “re-use” even though some items will be new The medical kit is an affected item. The health worker has arranged for the replenishment work to be done at the local hospital. In the course of their routine work at the managed quarantine facility the health worker collects the medical kit for transportation and removes them from the managed quarantine facility. Is the health worker within scope of the mandatory requirements of the Required Testing Order?
Yes: The health worker is a person who works at a managed quarantine facility and is already subject to the Required Testing Order (under item 1.1 of Schedule 2) Contact with the health worker another worker who subsequently handles the medical kit may bring that worker within scope of the new testing requirement.
The health worker transports the medical kit to the hospital within 72 hours of removing it from the managed quarantine facility. They enter the hospital and deliver the kit to a technician at the medical equipment logistics department. The two have a face to face conversation for over 15 minutes, standing within 2 metres, discussing life at the managed quarantine facility and equipment-related matters, dealing with paperwork and arranging for the medical kits to be picked up for return to the managed quarantine facility once replenishment is complete. The technician handled the medical kit within 72 hours of their removal from the managed quarantine facility The technician spent more than 15 minutes in contact within 2 metres of the health worker (1)(2) Is the technician within scope of the mandatory requirements of the Required Testing Order?
Yes. The technician meets the test of being an affected worker who handles an affected item. They handled affected items within 72 hours of their removal from a managed quarantine facility, and had face-to-face contact for more than 15 minutes within 2 metres of the health worker who is already a member of a group who is required to be tested under the Required Testing Order, while both were working. The technician is an affected worker
Another technician in the logistics department assists the first technician to replenish the medical kit. The second technician has had contact with the first technician. (3) But, the second technician did not have contact with a member of a group already required to be tested under the Order (no direct contact with the managed quarantine facility health worker who removed the medical kit for replenishment). (3) Is the second technicians within scope of the mandatory requirements of the Required Testing Order?
No: The second technician does not meet the test of being an affected worker who handles an affected item. They have not had contact with a member of a group who is already required to be tested under the Required Testing Order The second technician is not an affected worker
28
Example 2: Audio-visual equipment at a managed isolation facility requires refurbishment. The hotel is subject to the “affected items: provisions of the Required Testing Order. The audio-visual equipment will be removed for refurbishing and will be returned to the facility for “re-use”. The audio-visual equipment is an affected item. Management at the managed isolation facility has arranged for the boxed-up audio-visual equipment to be collected from the front of the facility for transport to the off-site business. People at the front desk at the managed isolation facility do not physically handle the audio-visual systems at any stage. Are the staff at the front desk of the managed isolation facility within scope of the mandatory requirements of the Required Testing Order? Yes: The front desk staff are already subject to the Required Testing Order (under item 2.1 of Schedule 2) Contact with a front desk worker at the managed isolation facility by another worker who subsequently handles the audio-visual equipment may bring that worker within scope of the new testing requirement.
A courier driver arrives to uplift the box containing the audio-visual equipment. The driver has a fleeting, at-adistance interaction with a front desk worker of the managed isolation facility, who points to the box. That worker has not handled the box. The courier uplifts the boxed-up audio-visual equipment and puts it into the van to take to the refurbishment facility. The courier driver handles the box when putting it into the van. During this operation the driver has no more than a short, fleeting and at-a-distance interaction a managed isolation facility worker. Is the courier van driver within scope of the mandatory requirements of the Required Testing Order?
No: The courier van driver does not meet the test of being an affected worker who handles an affected item. While the driver did handle the boxed-up audio-visual equipment, they have not spent 15 minutes or more within 2 metres of a worker at the managed isolation facility or any other already affected worker who is required to be tested under the Required Testing Order and who has handled the boxed-up audio-visual equipment. The courier van driver is not an affected worker and is not subject to the new mandatory testing requirement from 22 April 2021 Does the service agent become an affected worker who handles affected items?
29
2.
Diagrammatic examples of “affected workers who handle affected items” in the managed isolation and managed quarantine facility context
Explanatory notes for examples 1. Being “in contact” with another person involves being face-to-face within 2 metres of each other for 15 minutes or more, or being in a confined space within 2 metres of the other person for 15 minutes or more. 2. If the contact between the technician and the health worker had been for less than 15 minutes, or they were standing at a distance of more than 2 metres of each other, then the technician would not come within scope of the new requirements. This would be a feasible scenario if arrangements for replenishment could be made in advance between the health worker and the hospital equipment logistics department, for example by email. Any contact between the technician and the health worker when the medical kit was delivered would then likely be minimal. 3. The first technician is not a worker who is already subject to testing under the Required Testing Order (i.e. they are not a member of one of the groups of managed isolation facility workers described in question C in the table on page 28.
3.
Examples of possible “affected items”
In all examples, it is taken as a given that the items have been handled within 72 hours of their removal from a managed isolation facility or managed quarantine facility. Example 1: Parts from equipment at a managed isolation facility need replacing. A worker at the managed isolation facility gives the parts to a third-party contractor to source a replacement part at a supplier in town. The contractor may need to try several outlets to acquire a replacement part. Is the equipment part an “affected item”? Has the equipment part been removed from the managed isolation facility for cleaning? No. •
The part is not being removed from the managed isolation facility for cleaning and return.
Has the equipment part been removed from the managed isolation facility for the purpose of being returned to the managed isolation facility for re-use? No. •
The part will not be returned to a managed isolation facility or managed quarantine facility for re-use in the future. It needs replacement, not repair, and cannot be re-used.
•
It has been removed from the managed isolation facility for the purpose of identifying an identical replacement part.
•
The new, replacement part will be taken back to the managed isolation facility and used in the equipment. The new part is not an affected item – it was not removed from the managed isolation facility.
30
Has the part been removed from the managed isolation facility for disposal? Yes. •
Once the replacement part has been sourced the old, worn or faulty part is obsolete and will be disposed of – either left with the parts supplier for subsequent disposal or returned to the managed isolation facility for disposal.
•
The equipment part is an affected item.
Example 2: Machinery or equipment, or parts, need repair or refurbishment. Small pieces of equipment or parts might be carried off the managed isolation facility premises by hand by a contractor. Larger items, however, might need dismantling and removal mechanically. The amount of physical handling of that item will be relevant. Has the equipment or parts been removed from the managed isolation facility for cleaning? No. •
The equipment or parts might be cleaned in the process of its repair or refurbishment, but this is not the primary purpose of its removed from the managed isolation facility.
Has the machinery, equipment or part been removed from the managed isolation facility for disposal? No. •
It has been removed for repair / refurbishment for re-use at the managed isolation facility.
Has the equipment or parts been removed from the managed isolation facility for the purpose of being re-used at a managed isolation facility? Yes. •
The equipment or parts will be returned to a managed isolation facility, in this case the managed isolation facility from which it was removed, for re-use in the future.
•
The equipment or parts is an affected item.
Example 3: Expired medical stores or medical waste. These may be put into the managed isolation facility’s garbage for disposal. Some medical waste items might require special handling and disposal (e.g. bio-hazard material, used sharps, expired prescription medication). In this case they would be removed from the managed isolation facility for disposal (e.g. at a bio-hazards depot, or pharmacy). Is the expired medical stores or medical waste an “affected item”? Has the expired medical stores or medical waste been removed from the managed isolation facility for cleaning? No. •
The expired medical stores or medical waste is not an item removed from the managed isolation facility for the purpose of being cleaned.
Has the expired medical stores or medical waste been removed from the managed isolation facility with the purpose of being returned to a managed isolation facility for re-use? No. •
The expired medical stores or medical waste has not been removed for the purpose of being returned to that or any other managed isolation facility or managed quarantine facility for re-use in the future.
Has the expired medical stores or medical waste been removed from the managed isolation facility for disposal? Yes. •
It has been removed specifically for the purpose of disposal. 31
•
In these circumstances, the expired medical stores or medical waste is an affected item.
32
Example 4: Courier packs. These might contain items such as official documents or outgoing returnee mail being picked up by a courier company. Are the courier packs “affected items”? Have the courier packs been removed from the managed isolation facility for cleaning? No. •
The courier packs are not items removed from the managed isolation facility for the purpose of being cleaned.
Have the courier packs been removed from the managed isolation facility for disposal? No. Have the courier packs been removed from the managed isolation facility with the purpose of being returned to the managed isolation facility for re-use? No. •
The courier packs have not been removed for the purpose of being returned to that facility or any other managed isolation or managed quarantine facility for re-use in the future.
•
The courier packs are not “affected items”.
Example 5: Quarantine garbage at a managed quarantine facility. Is quarantine garbage an “affected item”? Has the quarantine garbage been removed from the managed quarantine facility for cleaning? No. Has the quarantine garbage been removed from the managed quarantine facility with the purpose of it being returned to any managed quarantine facility or managed isolation facility for re-use? No. •
The quarantine garbage has not been removed for the purpose of being returned to any managed quarantine facility or managed isolation facility for re-use in the future.
Has the quarantine garbage been removed from the managed quarantine facility for disposal? Yes. •
The quarantine garbage is an “affected items”.
Example 6: Items taken into a managed quarantine facility by a worker carrying out an essential task and removed on completion of that task. Are these tools and equipment “affected items”? Have the tools and equipment been removed from the managed quarantine facility for cleaning? No. •
The tools and equipment may be cleaned before they are use elsewhere, but that is not the purpose for which it was removed.
Have the tools and equipment been removed from the managed quarantine facility for disposal? No. •
The tools and equipment themselves have not been removed for disposal.
Have the tools and equipment been removed from the managed quarantine facility for the purpose of re-use? Yes. •
The contractor will re-use the tools and equipment, potentially including other managed quarantine facilities or managed isolation facilities.
•
The tools and equipment are “affected items”.
33