Policy GOV 28 May 2009 NHSN-JNT-GOV-09-62 Page 1 of 26
Document Management Title of document Type of document Policy GOV 28 Description Target audience This policy is to ensure awareness to all NHS employees of the procedures to be followed by Users of Display Screen Equipment. All staff Author Department Directorate Approved by Risk Management Team Governance Provider Services Governance Committee Date of approval 8 July 2009 Version Number 2 Logos and dates changed 04.08.09 Next review date July 2011 Related documents Health & Safety policy (GOV 02) Superseded documents Internal distribution External distribution Availability N/A All senior management Intranet site (primary care staff) Internet site (general public) Contact details (of main contact for this document) Name: George Shield Address: Bevan House, Kettering Parkway South, Venture Park Kettering, Northants NN15 6XR Tel: 01536 480340 E-mail: george.shield@northants.nhs.uk NHSN-JNT-GOV-09-62 Page 2 of 26
Contents 1. Statement of Intent 4 2. Introduction 4 3. Definitions.. 4 4. Organisational Responsibilities.. 5 5. Procedure for working with Display Screen Equipment (DSE). 7 6. Procedure for Provision of Eyesight Testing 9 7. Procedure for the Provision of New Equipment. 11 8. Right of Appeal 12 9. Review 12 Appendices A Display Screen Equipment Assessment 13 B Workstation Adjustment and Efficient Working Posture 17 C The Simple Deskology Guide 19 D Eye Test Form Certificate of Recommendation 21 5 Policy Impact Assessment 22 NHSN-JNT-GOV-09-62 Page 3 of 26
1. Statement of Intent 1.1 Northamptonshire Teaching Primary Care Trust (NtPCT) recognises and accepts its responsibilities as an employer under the Health & Safety at Work Act 1974 and relating EC directives, for ensuring so far as is reasonably practicable the Health, Safety and Welfare of all employees whilst at work and adopt corporate policies/procedures which set out safe systems of work to ensure compliance with relevant statutory provisions, with that duty extending to working with Display Screen Equipment (DSE). 1.2 The Trust has a duty to assess the risks that may affect the health, safety and welfare of their employees and anyone else who may be affected by their activities, so that necessary preventative measures can be identified and actioned. 1.3 With this in mind it will be policy that all managers will ensure that the suitable systems are put in place, appropriate to the risk. 2. Introduction 2.1 The Health & Safety (Display Screen Equipment) Regulations 1992 (amended 2002) cover the use of all DSE and the workstation as a whole, the job and surrounding area. 2.2 The Trust will ensure that the DSE, workstations and surrounding environment meet the appropriate standards and will provide any necessary Health & Safety training. 2.3 The Trust will make all reasonable adjustments in respect of DSE in order to comply with the Disability Discrimination Act (DDA) 2005 2.4 The policy is relevant to Staff, Agency Staff, Selfemployed/Contract Staff and Home Based Staff. 3. Definitions 3.1 Display screen equipment means any alphanumeric or graphic display screen, regardless of the display process involved. NHSN-JNT-GOV-09-62 Page 4 of 26
Includes VDU's, microfiche, LCD's and process control equipment - it does not include conventional televisions. 3.2 Operator means a person who habitually uses display screen equipment as a significant part of their normal job. 3.3 Use means use for or in connection with work (whether used at home, at a workstation or on the premises of another employer). 3.4 User means an employee who habitually uses display screen equipment as a significant part of their normal work. A user is generally regarded as someone who: uses the equipment continuously or nearly continuously for a period of one hour or longer. uses the equipment every day or most days. has no discretion on whether or when to use the equipment. cannot do the work without using the equipment. has to use the display screen equipment as part of their job description. 3.5 Workstation means an assembly comprising: display screen equipment. optional accessories to display screen equipment. any disk drive, telephone, modem, printer, document holder, work chair, work desk, work surface or any other item peripheral to the DSE. the immediate work environment around the DSE. 4. Organisational Responsibilities 4.1 Chief Executive The Chief Executive is accountable for ensuring that the policy is implemented and that the Trust is compliant with standards to ensure that the requirements of the Health & Safety (Display Screen Equipment) Regulations 1992 are adhered to. 4.2 Directors The Directors are responsible for ensuring that the policy is implemented within their Directorates and that specific roles and responsibilities are clarified with respective managers. 4.3 Managers NHSN-JNT-GOV-09-62 Page 5 of 26
Managers have a responsibility to ensure that all employees are aware of this policy and comply with procedures to protect the health and safety of themselves and of all other persons, whether they work on or off-site, or in other people s homes or premises. Managers are to review each DSE assessment carried out by employees to ensure that any remedial action needed is identified and carried out appropriately. Managers must ensure that employees have access to, and attend, appropriate training to receive guidance and support. Managers must also ensure that they have undertaken relevant training to ensure competence within this area. Managers are responsible for developing and implementing local procedures to help protect all workers for whom they are responsible. Managers will carry out regular monitoring and evaluation, by use of Risk Assessments to highlight any circumstances, which could produce a higher level of risk. Managers will make provisions for the immediate reporting of accidents/incidents as and when they occur, in line with Trust policies. This will be followed by an investigation and recommendation to prevent recurrence. 4.4 Risk Team The Risk Team is responsible for: Ensuring the development and implementation of appropriate risk assessment tools to help protect all workers. Providing informative training sessions to ensure that staff are competent to carry out assessments. Supporting managers by offering guidance, advice and support in relation to aspects of DSE, including workstation layouts and assessments. They are to offer advice in relation to the legislation and to refer or suggest visits to other professional organisations. 4.5 Employees NHSN-JNT-GOV-09-62 Page 6 of 26
Employees will ensure that they are familiar with and understand the and the local procedures that have been produced. Employees will carry out a DSE Self-Assessment in relation to their equipment and workstation as stated within the policy. The self assessment form can be found on the trust intranet under: Forms & Stationery Employees will take reasonable precautions for their own health and safety and for others who may be at risk. Any new hazards or high-risk situations must be reported to the appropriate line manager to enable them to be assessed. 5. Procedure for working with Display Screen Equipment (DSE) 5.1 The relevant manager should identify all staff within their department who are DSE users using the following criteria: The use of display screen equipment is part of the employees working practice and job description. Does the individual use DSE continuously or nearly continuously for an hour or more on a regular basis Does the use of the DSE require the individual to have a high concentration level for long periods 5.2 A workstation assessment is to be carried out by the user or an appointed assessor as require when an employee first starts employment and will be reviewed in the light of changes to the DSE worker population, or changes in individual capability, or where there has been some significant changes to the workstation, such as: A major change to software used A major change to any equipment (screen, keyboard, input devices etc) A major change in workstation furniture A substantial increase in the amount of time spent using the DSE A substantial change in other task requirements (e.g. greater speed or accuracy) If the workstation is relocated (even if all equipment and furniture remain the same) If major features of the work environment, such as lighting, are significantly modified NHSN-JNT-GOV-09-62 Page 7 of 26
Following an individual s illness or injury, where the workstation may be part of the cause or may prevent rehabilitation in the future (contact the Risk Management Team to carry out this assessment) Upon declaration by an individual that they are pregnant (Contact Human Resources for advice). Note: Contact details for the appointed assessors are available from the Risk Management Team. 5.3 All line managers and supervisors are responsible for ensuring that an assessment of an employee s workstation has been completed and that subsequent follow up assessments are done in line with changes indicated above. 5.4 The assessment will be carried out using the standard assessment form (see Appendix A). The user will initially complete the assessment Form. 5.5 The completed assessment is to be reviewed by the line manager to ensure that any remedial action needed is identified and carried out appropriately. Responsibility for implementation lies with the line manager and the user. 5.6 Employers Duties Ensure that DSE and workstation, which has been assessed, meets the minimum requirements given in the schedule to the Regulations to avoid postural and visual problems, fatigue and stress. This should include Screen, Keyboard, Desk and Chair, Working Environment, Task Design and Software (see guidance at Appendix B and C). All new starters will undertake H&S training when attending their induction which will include information on DSE self assessment. The Manager will ensure that employees who use DSE continuously over long periods are instructed to take breaks from such work. Where possible their work will include a mixture of display screen and other work. These breaks should be short and often if possible and users should be free to use discretion in arranging how they achieve their tasks. The Manager will ensure that: DSE is included on the Maintenance Schedule (PAT testing) NHSN-JNT-GOV-09-62 Page 8 of 26
DSE workstations, including screens, tables and chairs are regularly maintained and adjustment mechanisms are fully operational, and that records of this maintenance are kept. 5.7 User Entitlements A screen, which is readable, has a stable image, is adjustable and glare free. A keyboard, which is useable, adjustable, and has legible key tops. A work surface, which allows flexible arrangement, is spacious and glare free. A work chair, which is appropriately adjustable, and a foot rest where necessary. Adequate legroom and clearance facilities for postural change. Lighting which has the provision of adequate contrast, with no direct or indirect glare or reflections. Distracting noise eliminated. No excessive heat, and adequate humidity. Software, which is appropriate to the task and adapted to user capabilities, and provides feedback on the system status. 6. Procedure for Provision of Eyesight Testing 6.1 User Entitlement The Trust will provide all employees that qualify by definition as a user, an appropriate eyesight test. Any such test being carried out by a competent person. Where a user experiences visual difficulties, which may reasonably be considered to be caused by DSE at work, an eyesight test will be provided after a DSE self assessment is carried out. NHSN-JNT-GOV-09-62 Page 9 of 26
To be provided with special corrective appliances appropriate for the work being done by the user concerned where: - Normal corrective appliances cannot be used. - The result of any eyesight test, which the user has been given in accordance with this regulation, shows provision to be necessary. An eyesight test will be given to any member of staff upon request who is a VDU user. Reimbursement for corrective equipment will only be given in a situation where normal corrective appliances (glasses) are not appropriate, i.e. if a person normally wears glasses in order to carry out normal daily living activities, it is unlikely that reimbursement for corrective appliances will be issued. Any member of staff who is advised by the Trust s Occupational Health Advisors to have an eyesight test as the result of using DSE will be eligible to claim reimbursement 6.2 Procedure The employee is to take Eyetest Form - Certificate of Recommendation - Sep 07 (Appendix D) to their optician. The employee is to pay for the eyesight test, obtain a receipt and ensure that that the form is signed and stamped by the optician. If the optician has signed against (a) on the form, confirming that an eyesight test has been carried out, the employee will be entitled to reimbursement of the eyesight test. If the optician has signed against (b) on the form, there will be no employer contribution due. If the optician has signed against (c) or (d) on the form then the employee will be entitled to a contribution of up to 55.00 towards their corrective appliances (glasses) in addition to the cost of their eyesight test. The employee completes form PCF4, Business Mileage and Subsistence/Expenses Claim Form, (monthly travel claim form), attaching the completed Eyetest Form - Certificate of NHSN-JNT-GOV-09-62 Page 10 of 26
Recommendation - Sep 07 (Appendix E) with receipts for their eyesight test and glasses, if applicable. The expenses claim form is signed by the manager and forwarded to payroll for reimbursement in the employees pay the following month. Staff can claim for eyesight test and contribution towards glasses, but only if: glasses have been purchased optician has signed against (a) (confirming that a sight test has been carried out), or (c), or (d) on the form the form is stamped by the optician receipts are provided and the manager has signed the Claim form. If any employee wishes to purchase corrective appliances above the basic cost then the additional cost shall be paid in full be the employee at the time of purchase. The users will be allowed reasonable access for appointments at the service / departmental manager s discretion. Where corrective appliances are provided, it is the employee s duty to wear them. It will be the responsibility of all employees to ensure the safe keeping of the corrective appliances provided, where these appliances are lost, broken, stolen it will be at their manager s discretion as to whether the cost of replacement will be will be borne by the Trust. 7. Procedure for the Provision of New Equipment 7.1 User Entitlement Workstations that are compliant with the Regulations, as stated in Procedure for Working with DSE (see section 5). 7.2 Procedure The Trust will accept its responsibility to provide the legal requirements for workstations. NHSN-JNT-GOV-09-62 Page 11 of 26
8. Right of appeal Following an assessment where new items of furniture or equipment have been identified to be purchased, the following procedure will apply: The Risk Management office should be contacted to assess the request. A requisition for the purchase of the goods will be prepared and presented to the Budget Holder for signature. This will then be forwarded to Supplies at Princess Marina Hospital for processing. In the event that a manager rejects a member of staff s request for an eye test, the right of appeal will be through the Trust s Grievance Policy (HR03) and the Risk Management Team will be asked to carry out a work place assessment. 9 Review This policy will be reviewed bi-annually. NHSN-JNT-GOV-09-62 Page 12 of 26
Appendix A DISPLAY SCREEN EQUIPMENT SELF-ASSESSMENT This checklist will enable you to carry out a self-assessment of your own workstation. Your views are essential in order to enable us to meet our obligation under the Display Screen Equipment Regulations 1992. Please tick the relevant box to select the most appropriate answer that best describes your opinion. This form is to be reviewed by your line manager upon completion who will take remedial action as necessary. Name: Date Completed: Job Title: Workstation Location: For the office. use only: Assessment Checked By: Any further action needed: ENVIRONMENT YES / NO Date: Follow up action completed on: 1. Lighting Describe the lighting at your usual workstation. about right too bright too dark Do you get distracting reflections on your screen? never sometimes constantly 2. Temperature & Humidity At your workstation, is the temperature: comfortable too warm too cold Is the air around your workstation: comfortable too dry 3. Noise Are you ever distracted by noise from work equipment? never occasionally constantly NHSN-JNT-GOV-09-62 Page 13 of 26
4. Space Describe the amount of space around your workstation. adequate inadequate FURNITURE 5. Chair Can you adjust the height of your chair? don t know Can you adjust the height and angle of the backrest? don t know Is the chair stable? Does it allow movement? Is the chair in a good state of repair? If your chair has arms, do they get in the way? not applicable 6. Desk Is the desk surface large enough for you to have all your equipment where you want it? Is the height of the desk suitable? Does the desk have a matt surface (non-reflecting)? 7. Footrest If you cannot place your feet flat on the floor when keying, has a footrest been supplied? not applicable NHSN-JNT-GOV-09-62 Page 14 of 26
8. Document Holder If it would be of benefit to use a document holder, has one been supplied? not applicable If you have a document holder, is it adjustable to suit your needs? not applicable DISPLAY SCREEN EQUIPMENT 9. Display Screen Can you easily adjust the brightness/contrast between the characters on screen and the background? Does the screen tilt and swivel freely? Is the screen image stable and free from flicker? Is the screen at a height which is comfortable for you? 10. Keyboard Is the keyboard separate from the screen? Can you raise and lower the keyboard height? Can you easily see the symbols on the keys? Is there enough space to rest your hands in front of the keyboard? 11. Software Do you understand how to use your software? 12. Training Have you been trained in the use of your workstation? Have you been trained in the use of the software you use? NHSN-JNT-GOV-09-62 Page 15 of 26
If you have a problem with display screen work, would you know the correct procedures to follow? Do you understand the arrangements for eye and eyesight tests? Any additional comments you may have regarding your workstation: Signature: Date: NHSN-JNT-GOV-09-62 Page 16 of 26
WORKSTATION ADJUSTMENT AND EFFICIENT WORKING POSTURE Appendix B Healthy sitting to avoid back pain Ideal Posture When working with a screen The Head The head is held over the shoulders and is in line with the buttocks The Chair Seat The seat should tilt forwards and have a rocking action. Adjust seat height so the hip joint is higher than the knee joint. The Advance Two Step Place one foot in front of the other, try alternating feet position during the day Movement is essential, exercise throughout the day, by rocking three to four times at half hourly intervals. Desk Height The middle row of the keyboard is level with the elbow. Eye Height The top of the VDU screen should be level with the eyes, and not lower than 21 degrees at the base Ideal Posture When writing The Head The head is held over the shoulders and is in line with the buttocks The Chair Seat The seat should tilt forwards and have a rocking action. Adjust seat height so the hip joint is higher than the knee joint. The Advance Two Step Place one foot in front of the other, try alternating feet position during the day Movement is essential, exercise throughout the day, by rocking three to four times at half hourly intervals. The Writing Angle A writing slope helps stop the body from leaning forwards, keeping the head upright to reduce neck and shoulder strain. Elbow Height The elbow should be just below the desktop. NHSN-JNT-GOV-09-62 Page 17 of 26
Remember: To maximise health benefits and avoid back pain, sit correctly. The chair should be comfortable throughout the working day. The controls should be easy to reach Adjust the seat and back frequently to suit the task and maintain support. If you have adjusted your workstation and are following the advice but experience persistent symptoms (e.g. pain or pins and needles, you can be referred to a Physiotherapist via your GP. NHSN-JNT-GOV-09-62 Page 18 of 26
The Simple Deskology Guide: Seven Small Steps to a Less Stressful, More Productive Office Desk-Life This guide shows how small changes to your desk set-up can make a significant difference to your well being at work in a short space of time. Step 1 Posture: adjusting the way you sit can improve back posture. To improve posture the following is recommended. Chairs should be tested at a desk If a footrest is needed, get one first as the chairs height needs adjustment to set the elbow height to the desk, not your height from the floor. Make sure you can sit fully back against the backrest before the knees hook the front of the cushion. Adjust the back height to get the best support in the area between the shoulder blades and the back of the pelvis. Roll the chair forward so that when typing or using the mouse, the elbows are vertically under the shoulders. If armrests get in the way by hitting the desk, remove them Step 2 Setting Up: paying more attention to the way the desk is set up reduces stress and health risks. Changes to set up of your desk can be done by the following. Adjust monitor height so that you are looking horizontally, not down at it. Check the distance of the monitor for most people to view the screen comfortably it should be 55 65cm away. Eliminate any glare or reflections on the monitor Remove any papers from in front of the keyboard and pull the keyboard and mouse near the edge of the desk. If paperwork is used while typing, arrange a document holder either to one side of the screen or angled in front of or below the screen, between it and the keyboard. Step 3 Taking five to stretch: desk stretching reduces injury from routine activities and increases circulation. It can help relax muscles, as well as strengthen them to help prevent future injury. A few stretches during the working day will help keep you free from hand, wrist, arm and back pain. Step 4 Changing scenery: taking regular breaks away from the desk improves concentration, overall health and colleague interaction. The following is recommended. Talking to a colleague rather than sending an email or calling them on the phone. NHSN-JNT-GOV-09-62 Page 19 of 26 Appendix C
Eating lunch away from the desk helps avoid germs, encourages more exercise and gives you a break from the computer screen. Step 5 Expressing yourself: giving your desk individuality reminds you of life outside work. It is believed that the professional work environment can suppress individualism. People are happier and more productive at work when they are able to express themselves. It is recommended that taking desk ownership by adding an individual touch such as photos. Step 6 Keeping cool: preventing dehydration and over-heating at work promotes higher energy levels. Take regular breaks in a cooler environment, even if it is a corridor. Ensure sufficient water is drunk. Step 7 Being clutter free: organising your desk reduces stress and increases productivity. To avoid clutter the following measures are recommended. Take five minutes at the start of each day to consider your work objectives. Ensure that you have, within easy reach, all the information necessary to do your work. If possible, clear your main work area to give yourself as much free space as you can. NHSN-JNT-GOV-09-62 Page 20 of 26
Appendix D EYE TEST FORM CERTIFICATE OF RECOMMENDATION FORM TO BE COMPLETED IN ALL CASES FOLLOWING EYE EXAMINATION, AND THEN PASSED TO PATIENT. CLIENT S NAME I CONFIRM THAT I HAVE EXAMINED THE ABOVE CLIENT S EYES AND RECOMMEND THE FOLLOWING (Please Tick): * Spectacles Are Not Required..(A) * Spectacles Are Required For General Use (B) * Spectacles Are Required for General Use, Incorporating a Special Prescription for VDU Use (C) * Spectacles are Required Solely for VDU Use. (D) Type of Spectacles Required Single Vision (1) Bifocals (2) Multifocals (3) SIGNED (Optometrist) Print Name... Date Practice Stamp Form amended 04 August 2009 NHSN-JNT-GOV-09-62 Page 21 of 26
Appendix 5 - Equality Impact Assessment Department/Team: Governance Risk Management Team Lead Officer: David Thomas Contact details: 01536 480378 A. Function (policy, strategy, plan etc) Aims/Purpose/objectives Policies, Strategies and Procedures used to carry out the above function Groups who the function should benefit; B. Patients C. Staff D. Other internal or external stakeholders This policy sets out to ensure that the Trust is compliant with the relevant statutory provisions relating to working with Display Screen Equipment (DSE). DSE policy and its associated suite of policies and documents All staff directly employed by the Trust from all our population. Step 1 Question 1 Tips Who should be served by the function? Baseline information on the general population and the groups the function should benefit, e.g.: This policy seeks to protect all those who come into contact with or use DSE within the Trust who might be affected by our actions and activities regardless of background. o o o Census data (or more up to date population projections) Other survey data Information of social and economic factors, such as age, income levels, health etc which are indicators of need. NHSN-JNT-GOV-09-62 Page 22 of 26 Population - In 2007 the estimated county population was 678,300 with a higher population under 20 years than the national average and a lower population over 65 years. Migration - Over 8000 overseas nationals were allocated a NI number in 2007/2008. A considerable proportion of these people are Polish. Gypsy/traveler community There are 207 caravan pitches across the county and slightly more caravans than the average for the East Midlands. Ethnicity From experimental statistics
NHSN-JNT-GOV-09-62 Page 23 of 26 in 2005 the population of Northamptonshire is 90.2% white British. However in Northampton and wellingborough the figures are 85.4% and 86.4% respectively. Children - The schools census (2007) shows that Northampton has the highest number of children and young people from a non-white British ethnicity (24.47%) and Wellingborough has the second highest (19.12%). In comparison. Older People and children living in deprivation. Deprivation is constructed and weighted from 7 domain indices: - Income 22.5% Employment 22.5% Health/Disability 13.5% barriers to housing 9.3% crime 9.3% living environment 9.3%. There are 41 Lower Super Output Areas in the county which are in the bottom 20% in the county (28 areas in Northampton). Hearing/visual impairment County RNID estimates for hearing impairments 2006 are 96,000 aged between 16and 80. RNIB facts: - 70% of blind or partially sighted adults have other disabilities or long term conditions. The majority of people with sight problems are older people 2006 figures for our county are 1525 people registered blind 1,190 people registered as partially sighted. Learning/Physical Disabilities estimated prevalence in the county s adult population is approximately 1718 (0.3% - the figure may be higher as it is estimated that 2% of the national population has a learning disability). There are approximately 5043 children and young people with a learning disability in the county (under 1% - the national average is between 1-3% depending on whether IQ or adaptive functioning is used) Physical disability In November 2007, there were 26,210 people aged between 16-89 who were registered as receiving Disability Living Allowance (DLA). Of these, 17,000 people were receiving DLA for physical conditions. In 2007 5,120 children and young people were in receipt
of disability benefits. The public health paper used in this report gives a breakdown of conditions. Step 2 Question 2 Tips Do you have monitoring data? o Workforce Data o Audit or Review Information o Satisfaction survey results o Workforce or service user profile broken down into:, Gender, Race, Disability, Religion, Sexual Orientation, Age The effectiveness of the policy can be measured in a number of ways including: o Mandatory Risk Assessments for all DSE users. o Staff Survey o Follow up action from the Risk Team on any occupational health DSE requests and outstanding issues that cannot be resolved by line management Step 3 Question 3 Tips Who is using the function/policy? o o o What does your monitoring data on your service users tell you? Are any groups under or over represented compared to what you would expect to see from the baseline data What does your monitoring data outcomes tell you? E.g. are some groups more likely to be served better by your function, service and policies etc compared to what you would expect to see from the baseline data on their needs? Ongoing monitoring of DSE assessments shows that the situation regarding DSE use in the trust is not of major concern, the incidents common to most primary care organisations require continual monitoring. These affect the staff group in particular. Accordingly the Trust has put in place training and awareness sessions at induction. Step 4 Question 4 Tips What evidence do you have that your service is accessible equitably to all groups taking into account sexual orientation, gender, age, race, religion, belief and disability. o Potential sources of evidence: o Customer Satisfaction Survey results o Local and national research o Consultation o Observation o User Groups This DSE and associated policies are accessible to all who use our services on the PCT intranet and are referred to in induction training programs. No specific monitoring takes place with regard to equitable access. NHSN-JNT-GOV-09-62 Page 24 of 26
Step 5 Question 5 Tips What action have you taken to ensure that your users are all served equitably? o Staff training in how to treat individuals with specific needs Training is given to all at trust induction and thereafter when specifically requested. o Ensured information is produced in a range of formats to assist all In addition, Trust mandatory Equality and groups Diversity training highlights individual need in a o Changes made directly to reflect broad sense and should help all staff to be aware changes in the user profile. of equality issues. o Users consulted prior to planned changes to the service being Staff consultation takes place on policy change at implemented Risk Group and JCNC. o Staff groups made aware of user groups who may be being disadvantaged by existing policy, practice and procedure. o Staff being consulted to assess how new policies and procedures may impact on them Step 6 Question 6 Tips Based on the evidence gathered in Steps 2-5, have you identified any potential differential impact for any of the equality groups (Sexual Orientation, Gender, Race, Religion, and Belief & Disability)? o If yes, go to Step 7 o If No, go to Step 9 No, In general the law, and therefore the policy, applies equally to all. Step 7 Question 7 Tips Is the differential impact as a result of indirect or direct discrimination? If the impact is a result of direct discrimination, this is unlawful and the organisation must decide how to ensure they act lawfully (go to Step 8). If the differential impact is a result of indirect discrimination, is this objectively justifiable or proportionate in meeting a legitimate aim? If yes, NHSN-JNT-GOV-09-62 Page 25 of 26
provide details here: If no, go to Step 8. Step 8 Consider alternatives (Proposing actions) Step 9 Consult on those likely to be affected by the policy. Follow the organization s consultation process. Step 10 Tips Base your decision on four factors: o The aims of the policy o The evidence you have collected o The results of public involvement and consultations o The relative merits of alternative approaches Actions; Information Information Consultation takes place on policy change at Risk Group and JCNC. Research and consultation with health & safety professionals based at other Trusts takes place in order to identify problem areas and to inform how the functions of the DSE policy and associated policies will be produced to enable equitable accessibility. Question Decide whether to adopt the policy Make monitoring arrangements Complete EIA Summary Form The author is looking for endorsement of the EIA action plan. Collate the actions identified and complete the Equality Impact Assessment Action Plan below; Issues identified Action required to be taken How will the impact be measured Lead/timescales Please forward a copy of the Equality Impact Assessment template to Narinder Kaur, nkaur@nhs.net; NHSN-JNT-GOV-09-62 Page 26 of 26