As the incidence of infection of COVID-19 escalates in South Africa, of primary concern must be the guarding against the further transmission of infection, guidance needs to be provided to pharmacy owners, responsible pharmacists, all other pharmacy staff, clients/patients, their respective families and the public at large on what to do in case of an infection. The pharmacy environment, like all other work environments, should comply with the provisions of the Occupational Health and Safety Act, 1993 (OHSA), as well as operational standards set out in the Good Pharmacy Practice (GPP) Rules and the Infection Prevention and Control guidelines issued by the Department of Health (DoH). These may be accessed on the SAPC COVID-19 Information Centre, available on the SAPC website: www.sapc.za.org/covid
The Regulatory Framework
Attention must be drawn to the legal obligations that employers, such as pharmacies, have to both employees and third parties, as well as the legal obligations that employees have to their employer and third parties (See more at: http://www.labour.gov.za/department-of-employment-and-labour-unveil-guidelines-to-deal-with-covid-19-at-workplaces).
Section 8 of the Occupational Health and Safety Act, 1993 (OHSA) provides that every employer is obliged to provide and maintain, as far as reasonably practicable, a working environment that is safe and without risks to the health of its employees.
Employers:
- must take steps which are reasonable and practicable to eliminate or mitigate any hazard or potential hazard to the safety or health of employees, before resorting to personal protective equipment; and
- must provide such information, instructions, training and supervision as may be necessary to ensure, the health and safety at work of its employees.
In terms of the OHSA General Safety Regulations, an employer may not permit a person to enter a workplace where the health or safety of such person is at risk or may be at risk unless the person enters the workplace with the express or implied permission of and subject to the conditions laid down by the employer.
The GPP (in Chapter 1 & 2) expresses in detail the safety precautions that the pharmacy owner should take to protect staff operating in hazardous conditions, wherein infection and transmission of disease may occur. The provision of personal protective equipment, disinfection of environments, and protection of both patients and pharmacy staff are therefore of importance.
Section 9 of OHSA provides that every employer shall conduct its business in such a way to ensure, as far as reasonably practicable, that persons other than those in its employment who may be directly affected by its activities are not exposed to hazards to their health or safety.
OHSA also imposes a duty on employees to take reasonable care for their health and safety and that of other persons who may be affected by their actions or omissions:
- They must co-operate with the employer to enable a duty imposed by the employer to be complied with;
- Employees must accordingly obey the health and safety rules and procedures laid down by the employer and carry out any lawful orders given in this regard;
- Employees who act in violation of such rules or who disobey reasonable and lawful instructions in this regard may be subjected to appropriate disciplinary action;
- In terms of Section 14(d) of OHSA, if an employee becomes aware of a situation that is unsafe or unhealthy s/he must report such a situation to the employer as soon as practicable. This includes any suspicion, in the circumstances that we all now face, that a fellow employee, client or other person exhibits flu-like symptoms or is running a fever.
The Environmental Regulations issued in terms of OHSA provide, inter alia, that the employer must ensure that the premises are ventilated in such a way that the air breathed by the employees does not endanger their safety. Where there is a danger of unsafe air, the employer must provide the employees (and must ensure that they correctly use) respiratory protective equipment of a type that reduces the exposure to the employee to a safe level. Businesses are therefore required to ensure that the air-conditioning systems at their premises do not expose the employees to the risk of infection.
WHAT TO DO IF A STAFF MEMBER TESTS POSITIVE FOR COVID-19
In light of the OHSA provisions, a Responsible Pharmacist (RP) or pharmacy owner must ensure that:
- in the event of a staff member testing positive:
- they contact the National Institute for Communicable Diseases on this number 0800 029 999 for guidance;
- all staff members who had close contact with a COVID-19 infected person, and who were not using appropriate PPE, self-isolate for not less than 14 days;
- the pharmacy must be closed while the entire workplace is sanitised reasonably and acceptably; and
- the unaffected pharmacists and pharmacy support personnel continue to operate the pharmacy. (Access the Department of Health COVID-19 Infection Prevention and Control Guidelines at SAPC COVID-19 Information Centre on the SAPC website: www.sapc.za.org/covid)
- in the event that the entire pharmacy staff need to self-isolate, the RP or pharmacy owner must:
- close the pharmacy;
they contact the National Institute for Communicable Diseases on this number 0800 029 999 for further guidance; - ensure that the entire workplace is sanitised reasonably and acceptably before the pharmacy may be re-opened;
- notify patients on measures taken by the pharmacy to ensure that patients can obtain their prescriptions (repeats and chronic) while the pharmacy is closed;
- provide contact details to patients for any queries and questions, as well as details on how to obtain their prescriptions; and
- provide information on alternative pharmacies and healthcare practices that can provide the necessary pharmaceutical care.
- close the pharmacy;
- in the event that the RP test positive for COVID-19 while the RP is the only pharmacist among the pharmacy workforce and the pharmacy owner cannot find a locum pharmacist to directly supervise the pharmacy, the pharmacy owner must ensure that:
- the pharmacy is closed;
- they contact the National Institute for Communicable Diseases on this number 0800 029 999 for further guidance;
- the RP must self-isolate for not less than 14 days;
the entire workplace is sanitised reasonably and acceptably; - notify patients on measures taken by the pharmacy to ensure that patients can obtain their prescriptions (repeats and chronic);
- provide contact details to patients for any queries and questions, as well as details on how to obtain their prescriptions; and
- provide information on alternative pharmacies and healthcare practices that can provide the necessary pharmaceutical care.
RE-OPENING OF A PHARMACY FOLLOWING COVID-19 INFECTION
The RP or pharmacy owner must ensure that:
- the entire workplace has been sanitised reasonably and acceptably before opening;
- the staff member(s) on returning to work after isolation or quarantine period, should follow general work restrictions that include:
- undergo medical evaluation to confirm that they are fit to work;
- wearing of surgical masks at all times while at work for a period of 21 days from the initial test ;
- implement social distancing measures as appropriate (in the case of health workers avoiding contact with severely immunocompromised patients);
- adherence to hand hygiene, respiratory hygiene, and cough etiquette;
- continued self-monitoring for symptoms, and seek medical re-evaluation if respiratory symptoms recur or worsen;
- there is a supervising pharmacist who has accepted the roles and responsibilities of the RP, in terms of Section 22 of the Pharmacy Act, if the RP is unable to resume their duties.