I have reviewed the proposed amendments to the Health Protection (Coronavirus Restrictions) (Wales) Regulations 2020 and I believe they constitute a suitably cautious approach to the re-opening of public life in Wales.
My advice continues to be informed by the outputs of the UK Scientific Advisory Group on Emergencies (SAGE) and the Welsh Technical Advisory Cell (TAC), and through discussions with Chief Medical Officers in the 4 Nations and the Chief Economic Advisor in Wales. The proposed amendments are supported by a continued reduction in transmission of the coronavirus in Wales, by improved surveillance, by the successful establishment of our Test Trace Protect (TTP) Programme, and by the successful identification and management of recent coronavirus outbreaks and incidents in Wales.
It is likely that we will need to live with the prospect of a resurgence of coronavirus infection for a considerable time and our best protections against this continue to be the promotion of appropriate public behaviour, monitoring of international experiences, effective surveillance to identify disease resurgence, effective case and contact management, and robust outbreak identification and management.
I recommend that the proposed amendments are adopted.
I note that making these changes to ease restrictions constitutes an acceptable risk at this time as the prevalence of coronavirus is low and waning; any increased viral transmission should lead to a re-evaluation and we should plan and prepare for the partial or full reversal of these easements if necessary.
Specific advice on social distancing
A number of the amendments involve a reduction in social distancing below the current guidance of 2m. The evidence for 2m social distancing is quite clear with regard to immediate health impacts; maintaining 2m provides more protection than 1m (approx. 2-5 times the protective value in the absence on mitigations). I recognise, however, there are strong economic and social arguments for reducing the 2m distance in some settings, and that the adverse socio-economics effects resulting from restrictions are likely themselves to have negative effects on health and well-being over the longer term, and I understand that Ministers will need to take account of these consequences. I also acknowledge the difficulties which the public experience in understanding different policy decisions in Wales compared with the other UK Nations.
To be managed safely such reductions require a renewed emphasis on public responsibility and behaviour, coupled with the creation of supportive environments. Factors which will support reduced social distancing include:
- Making the necessary adaptations to workplaces and public spaces so that they are Covid-19 protected with related guidance for a range of settings.
- Provision of on-going public education to support compliance with protective actions; hand hygiene, avoidance of social contact during illness, and avoidance of more risky environments. The easement of restrictions must not be allowed to instil a false assurance of safety in the public.
- Having effective contact tracing mechanisms and incident management processes in place to identify and manage new outbreaks.
Further advice on face coverings
With regard to the use of face coverings by the public there is nothing new in the scientific literature which changes my view that there may be both potential benefits and risks in mandating the use of face coverings in circumstances where it is not possible to maintain 2m social distancing. My advice therefore remains that face coverings should be recommended in crowded indoor settings where adequate social distancing cannot be maintained.
I am conscious however, that any decision on mandatory use of face coverings in Wales should be informed by broader social science considerations including the benefits of cross border policy consistency (which is particularly relevant to the transport sector), and recent public engagement (which shows strong support for a more directive approach). If, on balance, these factors lead Ministers to mandate the use of face coverings in a particular sector, then the following considerations will apply:
- The definition of a face covering will need to be clear; WHO specifies a three layer construction and the evidence that a single layer of cotton provides any protection is particularly lacking.
- There will be some circumstances where face coverings would clearly not provide any utility for example in empty vehicles, waiting areas etc.
- Enforcement issues will need to be clarified.
- Discarded face coverings may constitute a biohazard and consideration will need to given to their safe disposal.
- Public communication will need to be crafted to avoid risk compensation both by symptomatic individuals and to ensure that the use of face coverings does not increase more risky behaviour.
- A consistent message and approach will need to be considered for non-transport sectors including retail outlets, hospitals, workplaces, cinemas, schools etc.
- As we are likely to be living with the coronavirus for some time it will be important to consider how and when we might move away from mandatory use.
Chief Medical Officer
8 July 2020