Memorandum from the North Wales Health
Emergency Planning Group (NWHEPG)
Representation on the group is from the:
National Public Health Service (NPHS).
Local Health Boards (LHB).
Welsh Ambulance Services NHS Trust.
The North Wales Health Emergency Planning Group
considers that the proposed measures as detailed within the Bill
are a positive and welcomed move towards a greater integration
and resilience to disruptive challenges. However, we also consider
that the final determination and response to the Bill can only
be authoritative when the guidance and regulation that will eventually
underpin the Bill are published. With this in mind, we do believe
that the structures currently in place including the working practices
and partnerships established across the region are evidence of
existing good practice and essentially in character with the proposed
The NWHEPG considers that the categorisation
of health agencies is one that requires careful consideration
on the basis that the NHS structure within Wales does not equate
easily to the categorisation of NHS bodies, where a Pan region
disruptive challenge might identify the need for the Regional
Office to effectively co-ordinate the NHS response. The Regional
Office does not believe that it is required to be categorised
as a category 1 responder.
In terms of the Ambulance Service,
Trusts, Local Health Boards and National Public Health Service
in Wales we consider that the duties required of the Bill, are
those currently being delivered and an integral part of the activities
of these agencies, and therefore suggest that they should be considered
as category 1 responders. However, we offer the following observation,
the Bill suggests that utilities and telecommunications organisations
to name but a few are regarded as category 2 responders. The NWHEPG
feels that the organisations, which support the NHS such as the
Pharmaceutical companies, Medical Gas organisations and health
supply organisations equally have a role to play therefore we
recommend that organisations who would be heavily called upon
in response to a large disruptive challenge are categorised in
In terms of funding the NWHEPG consider
that the change from grant specific funding for the Local Authorities
could potentially result in a disparity of service provision across
health regions. However, it was not felt that this would result
in an insurmountable issue should performance management be addressed
at the multi-agency level, therefore ensuring parity of service
across said regions.
A larger concern was that the Bill
will place greater responsibilities and onus upon health organisations
and should the Government wish to enhance the UK resilience, then
appropriate funding streams for all contributing organisations
must be identified.
The NWHEPG questions the role of
the Regional Nominated Co-ordinator and considers that the current
co-ordination role that falls to the Chief Constable is appropriate.
However, the group also accepted that the changing timescale and
essentially the nature of the incident could require a different
co-ordinator. Therefore, we suggest that the Regional Nominated
Co-ordinator is pre-identified, equipped with the local knowledge
and essentially the expertise to undertake such a role.
The group considered that the use
of "Emergency Powers" would only be effective if regarded
as "Primary" legislation and therefore accepts that
breaches of Human Rights legislation might be necessary.
In terms of the guidance and regulations
the group reserves its right to withhold comment until a time
when the full impact will be evident. However, we considered that
interpretation of guidance could be regarded as subjective dependent
upon varying organisational perspective.
In terms of devolved administrations
the group accepts that major constitutional and political issues
would need to be addressed for a workable legislative platform
to be developed, this coupled with the very diverse geographical
nature of Wales resulting in the need for cross border arrangements.
Therefore, it was accepted that the role of the devolved administration
in Wales would unlikely exceed current constitutional powers.