COVID-19: GOsC statement on use of PPE while treating patients

Osteopaths must ensure that their practice is safe, clean and hygienic, and complies with health and safety legislation and this includes taking all necessary steps to control the spread of communicable diseases.¹

The GOsC has published infection control guidance, as has the professional membership body, the Institute of Osteopathy (iO).² Both sets of infection control guidance highlight the approaches necessary to minimise the risk to patients, osteopaths and others in a clinical environment and include use of PPE.

Our infection control guidance signposts UK public health guidance as, in the context of a global pandemic and a highly infectious disease, it is crucial that public health guidance on infection control is implemented. You can refer to the advice published by the iO for support on how to apply the UK public health guidance.

Key steps for osteopaths to take prior to seeing patients face-to-face include:

1. Undertake an updated health and safety at work assessment. This risk assessment should take into account risks to patients and the public, the osteopath, staff, and any others who come into contact with the practice. The osteopath should then consider ways to mitigate these. Specifically, the risk assessment should be informed by public health guidance and professional guidance in relation to PPE as well as other infection control procedures and it should be kept up-to-date as guidance changes.³
2. Triaging patients prior to attendance to ensure that they do not have relevant symptoms and that a face-to-face appointment is appropriate and the patient has given fully informed consent.
3. Ensuring that stringent infection control procedures are implemented (informed by UK public health guidance and professional guidance) where you are practising and that there are policies in place to reduce the transmission of any diseases with face-to-face appointments.

The UK public health guidance COVID-19: Guidance for the remobilisation of services within health and care settings⁴ contains detailed advice on standard infection control precautions in a range of settings. Relevant aspects in the guidance to inform osteopaths’ risk assessments include:

• Care pathways for high risk, medium risk and low risk cases (p11). Osteopathic care is most likely to be in the medium risk category.
• Standard infection control precautions (p15).
• Appropriate personal protective equipment (PPE) (p15-18). Tables are shown for the various risk categories indicating PPE required for low risk (p22), medium risk (p27) and high risk (p32). In relation to PPE, COVID-19: Guidance for the remobilisation of services within health and care settings states: ‘All staff and other care workers must maintain social/physical distancing of 2 metres where possible (unless providing clinical or personal care and wearing PPE)’.
• Management of equipment (p27).
• Environment (p28).

To assist with interpreting and applying the UK Public Health Guidance, the Institute of Osteopathy has published updated guidance on the use of PPE and room aeration² and this should be kept under review.

Exercising your professional judgement

The Osteopathic Practice Standards set out the expectations of osteopaths as regulated healthcare professionals. Patients must be able to trust osteopaths with their health. To justify that trust osteopaths must meet the standards expected in the Osteopathic Practice Standards. Osteopaths are personally accountable for their professional practice and must always be prepared to justify their decisions and actions, explaining how they have exercised their professional judgement.

If a complaint is made regarding an osteopath’s approach to infection control, for example if they had chosen not to use PPE in a specific clinical scenario, then the osteopath will be required to explain and justify why the guidance had not been applied. Failure to be able to justify the decision may put patients and registration at risk.

If an osteopath is unable to wear PPE

If an osteopath is unable to wear the required PPE because of health reasons, they must consider Standard D11 of the OPS, which provides that: ‘You must ensure that any problems with your own health do not affect your patients. You must not rely on your own assessment of the risk to patients’. If an osteopath is unable to protect patients by wearing appropriate PPE taking into account their risk assessment informed by UK public health guidance then they may not be able to practise. Further advice on this can be obtained from the Institute of Osteopathy (iO) and the local public health team if necessary.

If osteopaths are unable to practise during the pandemic for health reasons, it may be helpful for the osteopath to contact the iO to get an understanding of whether there is any government or other financial support available as a result of being unable to practise.

If a patient is unable to wear PPE

As well as following strict infection control guidance and undertaking a risk assessment, when you are considering treating a patient, you are also expected to continue to use your professional judgement. When making decisions, it is right that you should consider the needs and wishes of your patients. In particular, the potential benefits to them in choosing face-to-face treatment against the risks posed by undertaking that treatment, in the specific context. This includes the risks to the patient, yourself, others in your practice, your other patients, and the wider public, in the current context of transmission of COVID-19.

We would encourage you to discuss this issue with the patient and to raise any concerns you have. You could take into account the following from Theme C: Safety and quality in practice of the Osteopathic Practice Standards:

Osteopaths must deliver high-quality and safe healthcare to patients. This theme sets out the standards in relation to the delivery of care, including … safeguarding of patients, and public health.

C5.5: You should take all necessary steps to control the spread of communicable diseases.

C6.1: You should be aware of public health issues and concerns, and be able to discuss these in a balanced way with patients, or guide them to resources or to other healthcare professionals to support their decision-making regarding these.

Another option you may want to explore is to recommend the patient seeks advice if they have an urgent medical problem from NHS 111.

¹ See Standard C5 and C5.5 of the Osteopathic Practice Standards.
² This guidance is available to all, not just members of the Institute of Osteopathy.
³ NB: Review of current UK public health guidance and profession guidance is good CPD for osteopaths and meets the requirements of Theme A: Communication and patient partnership, B: Knowledge, skills and performance, C: Safety and quality and D: Professionalism of the Osteopathic Practice Standards.
⁴ Issued jointly by Public Health England, NHS, Public Health Scotland, Public Health Agency (NI), Public Health Wales and Health Protection Scotland (as at 19 January).