CIRC 078: HMPPS NATIONAL H AND S ARRANGEMENTS FOR FIRST AID AT WORK AND EMERGENCY FIRST AID AT WORK

Since 2015 the NEC has been involved in negotiations to introduce a new policy on First Aid at Work and Emergency First Aid at Work. A new policy was introduced in August 2023 by HMPPS, but it is vital that local committees ensure compliance to the policy by their Governors/Managers. All sections of the policy are mandatory actions.

More detailed information is available in the policy and annexes. However, a number of key points have been lifted from the policy which management will be required to address as a matter of urgency. The NEC urges all local committees to raise the content of the policy with management and demand that the mandatory actions are in place immediately.

The role of emergency and first aiders within prisons is a voluntary task which requires requalification on a cyclic basis. HMPPS has a statutory duty under the Health and Safety (First Aid) Regulations 1981(HSFAR81) to make arrangements to ensure that its employees receive immediate attention if they are injured or taken ill whilst at work. HMPPS also has legal duty through common law, the Prison Rules 1999 and the European Convention on Human Rights to look after the health and wellbeing of prisoners and people on probation which extends to ensuring they receive immediate attention in an emergency.

All sites must have in place suitable numbers of adequately trained staff and suitable equipment and facilities to adequately meet the needs for first aid provision as identified in their First Aid Needs Assessment where staff are injured at or become ill whilst at work.

When formulating their First Aid Needs Assessments, Governors/Senior Managers (or their delegated authority) must consult the recognised Trade Union Health and Safety Representatives (amongst others).

The First Aid Needs Assessment must stipulate that there is;

At least one (but sufficient) first aid kits suitably located and adequately equipped.

Signage as to emergency and first aid injury arrangements.

A briefing or induction process for new staff to inform them of these arrangements.

In prisons the assessment of first aid needs will consider prisoner and visitor needs, in addition to local staff needs and be subject to the following minimum levels of first aid staffing at all times of the day and night:

At least one First Aid at Work trained staff member.

What is a First Aid at Work trained staff member?

A member of staff who is trained (three-day initial course or two-day requalification course) and in date and able to recognise and treat a wider range of injuries and medical conditions, as well as understand how to administer emergency treatment and life support to preserve life and limb in the immediate term, pending access to professional clinical treatment. 

Sufficient numbers of Emergency First Aid at Work trained staff members, as determined by the local first aid needs assessment.

What is an Emergency First Aid at Work trained staff member?

A member of staff who is trained (one-day initial course or one-day requalification course) and in date and able to administer emergency treatment to maintain life and prevent the situation from worsening in the immediate term pending access to professional clinical treatment.

First Aiders must be staff volunteers who have achieved a level of competence through formal training to undertake the role.

Staff should not be forced to undertake either a First Aid at Work or Emergency First Aid at Work Course as a pre-requisite of undertaking a task e.g. nights.

Senior managers in prisons must take particular care to ensure that night contingency plans offer the optimal capability to co-ordinate a casualty response. Plans must ensure first aider or healthcare access to the casualty to enable treatment to reach the casualty at the earliest opportunity bearing in mind security risks. In addition, consideration must be given to enabling emergency services and personnel access to the casualty.

Unless specific local contractual agreements have been entered into with a prison’s healthcare provider, staff in prison healthcare should not be included in specific first aider allocation provision. However, their availability on site either at day or night is a factor to consider in how prisoner casualties are planned for and managed and resources deployed.

Governors must ensure that a first aid coordinator is designated. The role must be supported, facilitated and monitored by management as it ensures that first aiders who leave or transfer can be replaced and is therefore critical to having a legally suitable and adequate provision in place.

Invision (or another suitable detailing system) must be used to ensure adequate first aid cover in line with the findings of the needs assessment. The detail office staff must be consulted about the needs assessment and how it must work and given the opportunity to consider how the identified provision can be best integrated with the detailing system. Senior Management must ensure that the detail office is detailing adequate numbers of suitably trained first aiders in operational environments.

Local branch officials should ensure that the minimum levels of first aid staffing are detailed at all times of the day and night as per the Needs Assessment. If minimum levels of first aid staffing are not met, this should be raised immediately with the Governor/Senior Manger as a health and safety issue. The POA is entitled to make representations to management in relation to any concerns that its members may have about their health and safety. Local management must arrange to meet POA officials to discuss the issue as soon as is reasonably practicable. Local management must then endeavor to agree a resolution of the concerns with the POA officials and will in any event consider the concerns when deciding what regime should apply, what instructions should be given to staff members and any other relevant actions/steps. Local management should then afford reasonable facilities for POA officials to communicate with its members in order to seek their views about any proposed resolution to the issue.

Given the potential for serious incidents to both staff and prisoners and the scale of many prisons, the availability of a radio is a major advantage in enabling the best response time from a range of staff who may be at distant parts of the prison when their services are needed.

Any staff who are first aiders and are frequently in the operational environment should therefore carry a radio and be suitably trained in their use.  Local arrangements should ensure that designated first aiders can be reached, such as the use of designated call signs.  

Should the policy not be implemented in full local disputes must be registered under PSO8525. An example of a Suggestion for Change is below. (This may not apply in all cases).

 

SUGGESTION FOR CHANGE

The First Aid Policy has recently been introduced which contains mandatory instructions.

The POA have a number of concerns which are;

We have not been consulted on the First Aid Needs Risk Assessment.

We believe that the minimum levels of first aid staffing are inadequate.

We believe that the first aid staffing levels have not been considered on night staffing.

We are unaware who the First Aid Co-Ordinator is.

No provision of radios for First Aiders.

There is no record of detailed First Aiders on InVision.

There are insufficient trained staff in Emergency First Aid at Work to provide cover.

We have not been informed what equipment and facilities have been provided.

First Aid provision has not been included in the induction for new staff.

We therefore insist that the mandatory instructions in the policy are implemented, and meaningful consultation takes place with this Union. I would insist that the mandatory instructions in the policy are the ‘status quo ante’.

Please bring this circular to the attention of all members. Thank you for your anticipated support.

 

Yours sincerely

   

JOE SIMPSON
Deputy General Secretary