BrainTrainUK Infection Control Policy & Coronavirus (COVID-19) Pandemic
Our policy is to follow UK Government advice and regulations, be transparent about risks and risk mitigation, and adopt policies and processes to mitigate risks.
Our service is within para 37 of Schedule 2 of the “health services” definition on businesses allowed to continue under the The Health Protection (Coronavirus, Restrictions) (England) Regulations. This also means that attending an appointment is a “reasonable excuse” for clients to leave their homes to their homes under Regulation Part 6.2 (c).
This forms the Risk Assessment as required by Management of Health and Safety at Work Regulations 1999.
Risks and Hazards
There is an inherent risk that our active Practitioners can contribute to the virus spreading, either by picking it up through travel, or from clients, and taking it back to their communities/households, or by unknowingly carrying the virus from their households/communities and spreading it further through travel or to clients.
There is also a risk of transmission from client to client through contact with objects such as electrodes, furniture, door knobs.
There is a further risk that we may need to suspend services with no notice either because government advice changes, practitioner(s) become ill, our premises is shut because of infection or government direction, a practitioner decides to suspend their practice, or other reasons beyond our control or prediction.
Impact Risk Reduction Controls
We can reduce the risk of the impact of spreading the virus by:
• Practitioners following government advice, for example (24/3/20 advice), 7 days isolation if they are the first in their household to show symptoms, or 14 days isolation from the point another member of their family shows symptoms, or withdrawing from practice if they or a member of their household is at increased risk of severe illness from coronavirus (COVID-19), including all over 70s.
• Advising and expecting that clients with an increased risk of severe illness from coronavirus (COVID-19), or who have someone in this category in their household, will consider suspending their sessions as part of the governments advice to protect them from infection.
If clients and their households are not at risk of severe illness, practitioners need to make a judgement about whether they are comfortable continuing to practice. BrainTrainUK will support whatever practitioners decide.
Likelihood Risk Reduction Controls
The likelihood of the risk of spreading the virus can be mitigated by following good infection control practices for infection transmission risks:
Hand-borne infection transmission risk mitigation:
• Frequent hand-washing
• Practitioner hand-washing before each client arrives
• Asking clients to wash their hands when arriving at the clinic
• Avoiding contact with surfaces of unknown cleanliness (e.g. public door handles)
• One-time use cotton buds
• Disinfecting electrodes between clients using saline solution or UV sterilisers
• Not using tactile toys (that are hard to clean), or avoiding direct contact (introducing an additional layer such as a tea towel), or using UV sterilising light sources between clients.
• Cleaning surfaces that may be touched by multiple people, e.g. clean furniture that client may have touched after each client, clean internal door handles
Airborne infection transmission risk mitigation:
• Using masks
• Maintaining a distance of 1m or more face to face*
• Maintaining a distance of 2m or more between client and practitioner, where possible. Attaching and removing electrodes requires a distance of less than 2m, however this should be for less than 15 minutes per session, including double sessions**.
We can also reduce the likelihood of risks occurring by reducing the number of times our practitioners travel, so we will be requesting flexibility from clients regarding appointment times.
NHS test and trace “Close Contact” definition
Government guidelines on the NHS test and trace programme define “Close contact”, which requires notification and self-isolation, as:
• * having face-to-face contact with someone (less than 1 metre away)
• ** spending more than 15 minutes within 2 metres of someone
• travelling in a car or other small vehicle with someone (even on a short journey) or close to them on a plane
This should provide reassurance to Clients and Practitioners that neurofeedback sessions that avoid face-to-face contact within 1m and contact within 2m for less than 15mins, fall short the threshold of “Close contact”.
However, we would expect that if Clients experience symptoms they would notify their Practitioner, and vice-versa.
Purchased Sessions and Return to Normal Service
Purchased sessions will not expire if a programme of neurofeedback sessions is interrupted as a result of the pandemic.
In the event of a suspension of services, BrainTrainUK will endeavour to return to normal operation as soon as is reasonably possible.
Updated by Stuart Black, 28 May 2020.