Policy responses and statements

Name of organisation:: Department of Health
Name of policy document:: NHS Emergency Planning Guidance 2005 - Mass Casualties Incidents: A Framework for Planning - Best Practice Guidance
Deadline for response:: 31 December 2006

Background: The purpose of this best practice guidance is to give guidance to National Health Service (NHS) organisations in planning, preparing and responding to all types of emergencies arising from any accident, infectious epidemic, natural disaster, failure of utilities or systems or hostile act resulting in an abnormal casualty situation or posing any threat to the health of the community or in the provision of services that involve significant numbers of evacuated patients.

This is an underpinning section of the NHS Emergency Planning Guidance 2005 and must be used in conjunction with this and other relevant underpinning sections.

The Department of Health welcomed views on this guidance and its usefulness to NHS organisations in fulfilling their statutory requirements. Comments regarding any issues related to equality and diversity in implementing the guidance were especially welcome.

COMMENTS ON
DEPARTMENT OF HEALTH
NHS EMERGENCY PLANNING GUIDANCE 2005 - MASS CASUALTIES INCIDENTS: A FRAMEWORK FOR PLANNING - BEST PRACTICE GUIDANCE

The Royal College of Physicians of Edinburgh is pleased to respond to the Department of Health on its consultation on NHS Emergency Planning Guidance 2005on Mass Casualties Incidents: A Framework for Planning - Best Practice Guidance.

COMMENTS ON STRUCTURE AND DESIGN OF DRAFT GUIDANCE

It is acknowledged that it is a difficult task to provide a document which will cover the whole range of possible incidents and provide a framework for dealing with the many different aspects which may arise from these incidents. Within this context, this document does give a useful outline of the more likely problems which may face planners and the potential solutions.

In common with a number of consultation documents, particularly dealing with emergency planning, there was a preponderance of unsubstantiated sweeping statements and excessive use of jargon. On the plus side, the use of examples is strongly commended, and particular mention is made of the very useful section on the recognition of the effect of such incidents on staff and their families.

The College recognises that this document is intended primarily for use in England, but given the possible cross border implications of a relevant emergency incident, it would be helpful to cite any relevant equivalent guidance available in Scotland, Wales and Northern Ireland.

There are a number of uncommon abbreviations used throughout the text which, to aid reading, should be printed in full, at least at the first mention.

The document fails to acknowledge that potential issues, particularly those of an infective nature (Avian flu or SARS) present a very different planning challenge from ‘conventional’ mass casualty incidents, and it is likely that these will be more dependent on a national response than the conventional incidents.

Chemical, Biological, Radiological and Nuclear (CBRN) clearly present a major threat but receive scant mention. Relevant planning issues such as the process of identification of agents and access to information should be included. Should Monitor rather than the SHAs be responsible for ensuring Foundation Trusts have MoUs with local fire and emergency and rescue providers in the event of a CBRN?

Traditional telecommunication systems may be of questionable value in such traumatic incidents and the College feels that specific mention could be made of this and possible solutions offered.

A summary of the principles of generic planning would be very useful at the end of the document. This summary would need to include specifics and be jargon free.

SPECIFIC COMMENTS ON SECTIONS OF THE DRAFT GUIDANCE

Introduction

Paragraph 6. The term Category 1 responder requires definition.

Paragraph 8. There is a lack of clarify here between the terms ‘Major Incidents’ and ‘Mass Casualty Incidents’.

Background and Context

Figure 1. The dates of listed incidents should be included for reference purposes.

Paragraph 14. There is no definition of ‘resilience planning’ and we do not know what this term means.

Structure of the Framework

Paragraph 16. It may be helpful to include the well established MIMMS Course as this provides some of the structures which are highlighted in this paragraph.

Definition of a Mass Casualty Incident

Paragraph 19. We are unsure if it is realistic to expect the NHS to have contingency plans to prevent mass casualty incidents, given that most result from the activities of other agencies. If it is felt that this is realistic in any way, perhaps an example could be listed here to provide clarity.

Paragraph 19. There should be some expansion of how to establish clear arrangements for ‘health mutual aid’.

Paragraph 19. It would be useful to emphasise that some ‘normal’ services are likely to be suspended for the duration of the mass casualty incident.

Some Particular Challenges

Paragraph 20. Define ‘preplanning work’.

Paragraph 20. Mention should be made of planning and exercising between the other agencies and the Health Service.

Paragraph 23. There is a lack of clarity over what is meant by the term ‘remodelling triage protocols’. Few clinicians will recognise this concept.

Paragraph 24. The ‘rising tide’ incident is of particular relevance to physicians and greater attention should be given to the necessary operational response that will have to be mounted. Further detail on training and exercising could be added.

Paragraph 30. What is meant by ‘sleeping algorithms’?

Developing Capacity and Sustaining Patient Care

Paragraph 45. Jargon such as ‘real time point of criticality’ should be avoided and, if this is impossible, such terms require to be defined.

Managing Clinical Care

Paragraph 46. Further detail on communication, in particular how ‘stand down’ is communicated and how to overcome the loss of normal telecommunications.

Staffing and Workforce Planning

Paragraph 49. Comments relating to the effect on staff are to be commended.

Creating Additional Capacity

No comment.

Mutual Aid and Wider Support

Paragraph 62. What is MERIT team? This needs to be defined.

Paragraph 74. This should read ‘clinical personnel’ rather than ‘medical personnel’.

Strategic Co-ordination

Paragraph 82. This is another opportunity to emphasise potential communication problems.

Co-ordination and Communication

Largely appropriate, but more could again be made of the widely acknowledged communication difficulties in such incidents.

Summary