key: cord-0980733-41ayoe2n authors: Kalman, Christopher John title: Management of Vulnerability to Occupational Hazards (Covid-19) date: 2021-04-09 journal: Occup Med (Lond) DOI: 10.1093/occmed/kqab036 sha: 010adb75351136dc1088814551c73059590240b2 doc_id: 980733 cord_uid: 41ayoe2n nan Dear Sir, I am grateful to the Covid Age team for their reply [1] to my letter [2] . With a second Covid-19 emergency phase, it is clear that we will need to face the hazard for some time, and coupled with the inclusion of occupational disease into the concept of Vision Zero [3], I suggest that both Occupational Medicine and Health & Safety communities need to continue discussion on the issue of individual susceptibility or vulnerability to occupational hazards. In my editorial [4] , I praised the Scottish Government's issue of an emergency phase Covid-19 risk assessment for NHS Scotland before the end of March 2020. It is typical in emergency planning to achieve some stability and safety with emergency measures, before returning to normal rules and regulations. A good example being the use of Emergency Reference Levels of dose averted to determine urgent protective actions in the emergency exposure situation in Radiation Emergencies [5] . I previously acknowledged [2] the Covid Age team for their ongoing evaluation of the science, which is vastly more comprehensive than that included in that very early NHS Scotland process; however, to my mind, Occupational Medicine's role is more than epidemiology, and the lack of evidence of ethical and equality dialogue determines we should also regard Covid Age as an emergency phase process. It may be useful in the second emergency phase we have found ourselves in, but does not form a model for the longer term consideration of Covid-19 vulnerability into the future, or provide the model for required consideration of the control of individual susceptibility to other occupational hazards. There are complex conflicting considerations and laws to be considered here, before some consensus can be reached. Looking at Health & Safety legislation, the Covid Age tool specifies that employers must control risk, and directs readers to the Returning to the Workplace Covid-19 toolkit promulgated by the Society of Occupational Medicine. This references the statement from the Health and Safety Executive, which in its opening line, indicates the employers legal duty, as well as the need to consider risk to those who are particularly vulnerable [6] . In terms of Equality legislation the Equality and Human Rights Commission, are clear that employers should not make decisions based on protected characteristics, and indicate that the Scottish Government had updated their guidance on Covid Age Nationally to reflect this [7] . I am sure that many Occupational Physicians have been involved in recent discussions with employers in relation to what could or should be done where there are employees in the very highest risk groups who do not accept workplace restriction. I have previously suggested a need for a set of Covid at Work Regulations to include occupational risk assessment based on susceptibility. This would require a UK National process on the science, as well as a true stakeholder dialogue. This needs to involve the guardians of the various legal and ethical elements, employers and crucially the various groups of workers affected. Occupational Health Physician (retd) e-mail: christopher.kalman@nhs.net Discussion on Covid Age Covid 19 individual susceptibility: health and safety management Public health protection. Radiation emergencies. PHE-CRCE-049 Protect vulnerable workers during the coronavirus Equality and Human Rights Commission. Kalman: handling of protected characteristics in considering health and safety risks to Covid 19