BrainTrainUK Infection Control Policy & Coronavirus (COVID-19) Pandemic
Updated 5 January 2021
Our services continue to be available under the latest national lockdown.
Our Policy and Risk Assessment is below, but clients typically have three main questions:
Q1. Am I allowed to leave the home for neurofeedback therapy?
A1. Yes, access to and operation of our services is covered by The Health Protection (Coronavirus, Restrictions) (All Tiers) (England) Regulations 2020 Schedule 3A.
The relevant sections are the same sections that allow you to leave home to visit your GP or be admitted to hospital:
Paragraph 2 Exceptions: leaving home sub-paragraph 7(a) allows you to leave home to access services defined in 17(o) (see below).
Paragraph 17 Businesses allowed to remain open in Tier 4 area, sub-paragraph 17(o) lists “dental services, opticians, audiology services, chiropody, chiropractors, osteopaths and other medical or health services, including services which incorporate personal care services and treatments required by those with disabilities and services relating to mental health.”
Even if even more severe lockdown measures are introduced, we do not expect this to change.
Q2. Is it safe to leave my home and attend a BrainTrainUK clinic for neurofeedback therapy?
A2. There is an inherent risk of contributing to infection transmission in attending a clinic. Our Risk Assessment below describes the Risk Reduction Controls we have in place. Our controls avoid the government’s definition of “Close Contact” by avoiding face-to-face contact within 2 metres, and minimising contact within 1 metre to less than 15 minutes. If you are at risk of severe illness from COVID-19 or live with someone who is, you should not attend.
Q3. What difference does the new variant of the Cornavirus make?
A3. The new varient is reported as being more transmissable, but no more dangerous. This increases the likelihood risk, but not the impact risk of infection. We have reviewed our Risk Assessment in light of the new variant.
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.
The legislation is a little difficult to follow, as several changes have been made to recent regulations by even newer regulations, but at the time of writing (5 January 2021), access to and operation of our services is covered by The Health Protection (Coronavirus, Restrictions) (All Tiers) (England) Regulations 2020 (S.I. 2020/1374) Schedule 3A, as amended by: The Health Protection (Coronavirus, Restrictions) (All Tiers) (England) (Amendment) (No. 3) Regulations 2020 (S.I. 2020/1646); and The Health Protection (Coronavirus, Restrictions) (No. 3) and (All Tiers) (England) (Amendment) regulations 2021 (S.I. 2021/8).
Schedule 3A Paragraph 2 Exceptions: leaving home sub-paragraph 7(a) allows you to leave home to access services defined in 17(o) (see below).
Schedule 3A Paragraph 17 Businesses allowed to remain open in Tier 4 area, sub-paragraph 17(o) lists: “dental services, opticians, audiology services, chiropody, chiropractors, osteopaths and other medical or health services, including services which incorporate personal care services and treatments required by those with disabilities and services relating to mental health.”
In summary, you are permitted to leave your home to use our services, and we are allowed to operate our services. It is the same legislation that allows GPs and hospitals to stay open, and for you to attend them.
This webpage 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 (18/12/20 advice), isolating if they or a member of their household shows symptoms or tests positive, 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 not start neurofeedback sessions or 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, 5 January 2021.