Scotland’s Deputy First Minister and Education Minister John Swinney has published long awaited revised guidance for the higher education sector on Covid-19.
(It also notionally covers Scotland’s colleges, students’ associations, institution-run halls of residence and purpose-built student accommodation providers – although weirdly, there’s no advice for landlords looking after student HMOs).
We’ve been awaiting this for some time – and depending on your point of view, it’s either a huge relief or a major disappointment that there’s probably nothing in here that universities won’t already have thought about.
Here we’ve focussed on what’s new. You’ll see that there is an important difference between “what’s new in this document” and that which is actually… new.
The first thing to note is that the central recommendation from one of her key advisors on testing (mandatory testing on arrival and 5 days later) hasn’t been taken up. That’s interesting because Sturgeon intimated that testing would form a big part of the strategy as late as the end of last week, but this guidance just mentions students (and staff) being able to (voluntarily) use the capacity that’s there and the standard self-isolation rules.
It’s even more interesting when you look at the comments on testing from Sally Mapstone (Principal and Vice-Chancellor at St Andrews) in this “phased return” announcement, which implies that discussions were being held but haven’t come to fruition – at least not in time:
It is also now clear that a national programme of asymptomatic testing of students is unlikely to be in place in time for us in St Andrews, although we continue to lobby for, and offer support to, that proposed scheme.
(It’s also worth noting that Mapstone identifies two causes for the St Andrews plan revision – a “larger number of students than was expected”, and “the absence of a national asymptomatic testing regime”, both of which politely and reasonably lay blame for delaying non-essential in-person teaching for several weeks at the Scottish and Westminster governments’ doors. How many more will now drop out of UUK’s 97% club?)
There’s a new section that both responds to the main UCU news from the weekend and specific questions that were being asked in Parliament about the St Andrews approach prior to the Mapstone announcement:
The guidance emphasises in particular the importance of undertaking robust and ongoing risk assessments with full input from trade unions and student associations and to keep all risk mitigation measures under regular review so that staff and students continue to feel, and be safe.
That skirmish at St Andrews concerned the overall “blend” of in-person and online teaching. Unsurprisingly the guidance doesn’t go as far as the UCU “only if necessary” line on in person, and instead plumps for a slice of tablet:
This blended model will continue. Staff and students will be on campus albeit less frequently and in lower numbers than before the virus.Institutions should continue to make reasonable efforts to facilitate working and studying remotely. Staff and students can expect to spend time working or studying from home. This will not always be possible and, where that is the case, public health measures (including physical distancing) must be in place.
In the list of issues for universities to think about, there are some new entries, and it looks like the Scottish civil servants have at least been reading Wonkhe. Note these are posed as “you better think of a solution” rather than being accompanied by any advice or help – but at least they’re in there.
First up, there’s a specific direction to think about “the circumstances of staff and students, including those with caring responsibilities, who are clinically vulnerable or who are self-isolating or under quarantine” – a helpful antidote to the “they’re all invincible” stuff peddled by the anti-maskers.
Other new ones include:
- that staff and student availability may also be affected by public transport availability and restrictions
- providing clear information to staff and students on the part they can play in ensuring the health and wellbeing of the campus and wider community
- what measures, in addition to those that were in place during the lockdown phase and earlier phases will need to be in place to accommodate additional numbers (including additional cleaning measures and queue management systems where appropriate).
Universities are also newly advised to plan for:
- considering opportunities to introduce technology and systems to aid safe working practices and in particular physical distancing
- communicating with visitors prior to arrival and on arrival to ensure visitors understand physical distancing and hygiene measures
- reducing maximum occupancy for lifts, to allow for physical distancing and providing hand sanitiser for the operation of lifts and encouraging use of stairs
- making sure that people who are disabled are able to access lifts whilst maintaining physical distancing measures
As we note above, on arrivals, despite concerns raised by MSPs in particular about international students, it’s the status quo that’s now included in here.
Institutions and providers are told to ensure that students arriving from outside Scotland (including from the rest of the UK) are provided with “clear and detailed information” on Scottish Covid regulations, and that quarantine requirements from the specific countries on the list are a legal requirement and it is “essential they comply”.
Ominously, universities are told to take “active steps” to ensure that quarantine arrangements are complied with, without making clear where that responsibility starts or ends. There’s a rehash of the rules on self-isolating, and then a directive – “institutions and providers should ensure students who are self-isolating have appropriate support, for example access to food and other necessities, and to safeguard their health and wellbeing”.
That might be fine for students in your own halls, or even students in PBSA provision where there’s a nomination agreement – but are universities supposed to ensure this across the rest of PBSA provision and HMOs too? And if not, why would it be OK (university disciplinary wise) to break quarantine in an HMO but not in halls?
Universities are also told to have “appropriate disciplinary arrangements” in place should staff or students fail to comply with the law on quarantine, in addition to existing legal penalties in Scotland. Again, if there was a debate about the jurisdiction of university disciplinary procedures, it’s clear which side the Scottish Government falls on and what it expects universities to do:
We expect noncompliance to be treated as a serious breach in terms of disciplinary procedures. Sanctions will be determined on a case by case basis but it must be clear that they include the full weight of the disciplinary procedures.
Nescafe Gold Blend
There’s actually a longer section on blended learning than we implied above, although much of it falls into the “bleedin’ obvious” category. There are some fun nuggets.
First of all, for contact tracing purposes, a “record of the contact details of students attending in-person sessions should be kept”. That will be much harder to do in some universities (and in some classes and for some students) than others, students will be worried about data protection issues, staff will be worried about admin, and systems vendors will be thrilled. This regime is also to cover “on-site classes and activities”, records should also be kept of “visitors and contractors”, and helpfully “particular attention should be made to the guidance on lawful data collection and management”. Well, yes (let’s not even get started on what types of information may be deemed sensitive).
There is a reiteration of “this won’t be normal” too. Institutions are told to ensure students are aware that “opportunities to socialise will be considerably more restrictive than is normally the case” (can someone let UUK know), and that “this will not feel like a normal start to a student’s university or college life” – and as well as a reiteration of the guidelines on social mixing, universities are told again to have disciplinary arrangements in place should staff or students fail to comply. “It must be clear that they include the maximum sanctions available for gross misconduct in the most extreme cases.”
Open the window
Also new for higher education is specific text on ventilation – where centralised or local mechanical ventilation is present, systems should be adjusted to full fresh air, and where ventilation units have filters present “enhanced precautions” should be taken when changing filters. Doors and windows are also to be kept open to “increase natural ventilation”.
Unsurprisingly, the guidance also incorporates the schools advice on masks (everyone can, some are exempt, and people should in communal areas).
The guidance also reiterates current advice on self-isolation and getting a test if you have symptoms – although universities “should consider identifying isolation rooms” in the event a person having symptoms cannot return home immediately. Providers should also “monitor staff and student absences” and whether these are due to possible or confirmed Covid-19.
We also have a definition of a household for students – (those that share a kitchen or bathroom), those that have spent a significant time in the home, and “sexual contacts who do not usually live with the student” – a welcome shift from the “abstinence only” mood that has prevailed so far (although the general guidance on socialising still officially applies). The guidance is still fairly silent on persuading reluctant students to declare symptoms or get a test, however.
As a reminder, and outbreak is two or more linked cases (confirmed or suspected) of Covid-19 in a “setting” within 14 days – where cross transmission has been identified; or an increase in staff and student absence rates, in a setting, due to suspected or confirmed cases. If an organisation suspects an outbreak, they are reminded to inform their local NHS board Health Protection Team (HPT). The college, university or provider may be then contacted by them, as they may get information from NHS Test & Protect or other sources.
Interestingly, institutions and providers are instructed not to make “unilateral decisions” about managing situations where they suspect an outbreak is occurring – but should seek urgent advice from their local Health Protection Team about issues relating to the testing of suspected cases and contacts and taking steps such as closing parts of facilitates. Where confusion reigns about “who’s in charge” south of the border, the command and control structure couldn’t be clearer here:
The Health Protection Team or Incident Management Team will declare when the outbreak is over.
There’s also an interesting bit on “dynamic risk assessment”. Devi Sridhar had advised that “thresholds” of infection within certain subjects/labs should be published which would require closing of that facility, or a stop to face-to-face teaching and moving online. This doesn’t go that far but does say that risk assessment and adoption of mitigation measures should not be a one-off exercise, rather part of a regular and ongoing consultation and feedback loop between employers and trade unions and student associations to identify what measures are working, where refinements are possible and any gaps remaining.
As we noted in the intro – overall there’s nothing in here that should be a surprise, although in many aspects it’s full of “raises more questions than answers” and even though it offers some clarity, many will be nervous about the allocations of control, responsibility (and by implication, blame) peppered throughout the document.
We’re also still fairly underwhelmed at the lack of modelling underpinning guidance like this, the focus (still resolutely on, rather than off-campus) and the lack of a proper strategy on asymptomatic testing or symptom declaration.
Will most of this now re-appear in England, Wales and Northern Ireland only in a different order? Probably. May as well convert into an agenda for tomorrow’s meeting now.
One response to “Scotland’s universities get new Covid guidance – but is it too late?”
Nothing on ‘illicit‘ socialising in Halls. Parties are already happening right under the noses of university staff. Given what happened when young people filled the streets of the UK, drinking and not social distancing, as soon as pubs reopened isn’t this by far the highest and most obvious risk which needs managing. It’s one thing writing risk assessments and providing rules and guidance but doesn’t experience tell us that risk is only properly managed by robust monitoring and enforcement. If Universities can’t actively manage this simple thing they aren’t getting their Severity v Likelihood Matrix right.