EMERGENCY PREPAREDNESS INCIDENTS POLICY AND RESPONSE PLAN

EMERGENCY PREPAREDNESS INCIDENTS POLICY AND RESPONSE PLAN Document Reference: GOV - 06 Document Title: Version: 2.0 Supersedes: 1.0 Author: Authors Designation: Consultation Group: Emergency preparedness incidents policy and response plan Sarah Mattocks Rachel Pickford Corporate Affairs and Governance Manager Corporate Business Manager Governance and Risk Audit Committee Date Ratified: 3 March 2017 Review Date: 3 March 2019 1

Version Control Version Date Author Status Comment / Details of Amendments 0.1 October 2013 Lisa Stott Draft Draft plan 0.2 23.10.13 Lisa Stott Draft Draft plan updated 0.3 15.01.15 Lisa Featherstone Draft Draft plan updated 0.4 08.04.15 David Storry Draft Sections drafted 0.5 14.04.15 David Storry Draft Appendix 2 Action Cards added 0.6 23.04.15 David Storry Draft Appendix 1 Updated 0.7 11.05.15 1.0 21.05.15 2.0 03.03.17 Lisa Featherstone Lisa Featherstone S Mattocks R. Pickford Draft Final Draft Appendix 2 Updated Approved by Governing Body Updated to reflect NHSE EPRR Framework and CCG assurance document produced by NHSE. Approved by Audit Committee Circulation List Prior to Approval, this Policy was circulated to the following for consultation: Head of Strategy and Corporate Services On-call managers Audit Committee Following Approval this Policy Document will be circulated to: All CCG staff All staff working in CCG premises, not employed by the CCG Equality Impact Assessment This document has been impact assessed by the author. No issues have been identified in relation to Equality, Diversity and Inclusion. 2

Contents 1.0 INTRODUCTION... 4 2.0 PURPOSE, ROLES AND RESPONSIBILITIES... 4 3.0 INCIDENT REQUIREMENTS... 5 4.0 DEFINITIONS... 5 5.0 INCIDENT MANAGEMENT LEVELS... 6 6.0 INCIDENT DECLARATION AND RESPONSE... 7 7.0 INCIDENT STAND DOWN... 10 8.0 STRATEGIC PLANNING... 11 9.0 RECORD KEEPING... 11 10.0 COMMUNICATIONS... 12 11.0 DEBRIEFING... 13 12.0 TRAINING REQUIREMENTS... 13 13.0 EXERCISING... 14 14.0 IMPLEMENTATION, MONITORING AND REVIEW... 14 Appendix 1 - Incident Plan Action Cards... 15 Appendix 2 - Incident Management Escalation Process... 23 Appendix 3: Escalation and Alerting Procedure... 24 Appendix 4: Mitigation Plan... 25 Appendix 5 The Incident Command and Control Centre... 31 Appendix 6 OPEL Actions for Commissioners... 33 Appendix 7 P3 Sites... 34 3

1.0 INTRODUCTION 1.1 This Incident Response Plan follows the Joint Emergency Planning Resilience and Response (EPRR) Plan for the Lancashire Clinical Commissioning Groups (CCGs) and NHS England Lancashire (NHSE); a framework which has been developed for all NHS funded organisations in England in order to meet the requirements of the Civil Contingencies Act 2004 (CCA 2004), the NHS Act 2006 as amended by the Health and Social Care Act 2012 (as amended) and the NHS Standard Contract. 1.2 As a Category 2 Responder, this plan describes the classification of emergency incidents which the CCGs may need to deal with in an emergency; business continuity, critical or major incident. 1.3 This plan also outlines the escalation procedures the CCG must follow to go about their duty in respect of the NHS England Emergency Preparedness, Resilience, and Response Framework published in November 2015. 1.4 On-call arrangements in respect of this plan are outlined in the CCG s on-call pack. 1.5 A ratified version of this document will be placed on the CCG website and will be updated bi-annually. 1.6 This policy should be read in conjunction with the following documents: GOV08 Business Continuity Management Policy (available on the CCG website) NHS England Emergency Preparedness, Resilience, and Response Framework (2015 available on the NHS England website) Heatwave plan (available on the CCG intranet) Cold weather plan (available on the CCG intranet) Pandemic Influenza Plan (available on the CCG intranet) 2.0 PURPOSE, ROLES AND RESPONSIBILITIES 2.1 The purpose of this plan is to set out key roles and responsibilities within the CCG in relation to emergency incident response and the relevant escalation procedures to follow as per the classification of emergency incidents. 2.2 Each of the CCG s healthcare providers must ensure that they also meet the roles and responsibilities outlined in the NHSE EPRR Framework. Specific duties and responsibilities within the CCG The following specific duties and responsibilities apply within the CCG: Accountable Officer (AO): The AO has overall statutory responsibility for the strategic and operational management of the CCG, including ensuring that the CCG has in place robust arrangements for Emergency Planning and Resilience. 4

Accountable Emergency Officer: The Accountable Emergency Officer is responsible for Emergency Planning Resilience and Response (EPRR) and for ensuring that plans are robust. In addition the Accountable Emergency Officer will act as the CCG s representative on health economy wide EPRR and Business Continuity groups. The role of Accountable Emergency Officer within the CCG is part of the Chief Officers remit. The full details of the remit of this role can be found in the NHS England NHS England Emergency Preparedness, Resilience, and Response Framework (2015). On-call Managers will: Coordinate the response to an incident. All CCG staff will: o Ensure that they aware of this policy and plan and their role within it. o Support Incident awareness o Encourage and participate in training or exercises. 3.0 INCIDENT REQUIREMENTS 3.1 When the CCG is supporting a response to an incident, where necessary it will establish an Incident Control Room in the Boardroom of the CCG Headquarters. 3.2 The CCG will ensure that staff are trained on the arrangements for declaring and managing an incident see Appendix 2. 4.0 DEFINITIONS 4.1 As per the NHSE EPRR Framework incidents are classified as business continuity, critical or major: Business Continuity Incident A business continuity incident is an event or occurrence that disrupts, or might disrupt, an organisation s normal service delivery, below acceptable predefined levels, where special arrangements are required to be implemented until services can return to an acceptable level (This could be a surge in demand requiring resources to be temporarily redeployed). Critical Incident A critical incident is any localised incident where the level of disruption results in the organisation temporarily or permanently losing its ability to deliver critical services, patients may have been harmed or the environment is not safe requiring special measures and support from other agencies, to restore normal operating functions. Major Incident A major incident is any occurrence that presents serious threat to the health of the community or causes such numbers or types of casualties, as to require special arrangements to be implemented. This will include any event 5

included under Civil Contingencies Act (2004) Section 1 definition of emergency, namely: a. an event or situation which threatens serious damage to human welfare in a place in the United Kingdom; b. an event or situation which threatens serious damage to the environment of a place in the United Kingdom: c. war, or terrorism, which threatens serious damage to the security of the United Kingdom. 4.2 It should be noted that a major incident for one healthcare provider, such as an ambulance trust, may not be for another, such as a mental health trust. That will depend upon the level of response expected from the provider and the extent of any disruption they suffer. 4.3 Each of the CCG s healthcare providers must therefore consider and define what for them constitutes a major incident and reflect that in their plans with robust routes of escalation. They in turn must ensure their response and escalation procedures dovetail with those of NHS partners and with the coordination role of the CCG and the local office of NHS England. 5.0 INCIDENT MANAGEMENT LEVELS 5.1 The CCG may be notified in a number of ways of an incident or potential incident requiring a response: Internal Alert Caused by a serious business continuity issue comprising the running of the CCG (and in turn its ability to coordinate its health economy) or notification of serious pressures affecting commissioned providers. External Alert NHS England direction or alert via North West Ambulance Service 5.2 The CCG must be able to identify the extent or severity of an incident by the use of levels described in the NHS England EPRR Framework. 5.3 Generally these levels correspond with the following levels of incident management: 6

6.0 INCIDENT DECLARATION AND RESPONSE 6.1 The NHS can declare an incident when its own facilities and or resources, or those of partner organisations, are overwhelmed. 6.2 The On-Call Manager (or Chief Officer) may consider the activation of this plan. Such action may be taken when it is apparent that severe weather or an environmental hazard may demand the implementation of special arrangements or when a spontaneous response by members of the public results in the presentation of incident casualties at any health care setting e.g. acute or community hospital, walk-in centre, health centre, GP Practice or minor injuries unit. THE ON CALL MANAGER HAS THE AUTHORITY TO DECLARE AN INCIDENT FOR THE CLINICAL COMMISSIONING GROUP ONLY AFTER CONSULTING WITH THE CHIEF OFFICER OR DEPUTY WHO WILL USUALLY TAKE THIS DECISION 6.3 Additionally, the On-Call Manager (or Chief Officer) may be alerted to an incident by one of the following: NHS England North West Ambulance Service (NWAS) Any NHS funded care provider within the CCG local health economy Public Health England 6.4 Escalation is the process describing the incremental implementation of special measures to mitigate or resolve an issue to return the organisation to a business as usual condition. This will normally require the implementation of a command, control and coordination model of management often referred to as C3. 7

6.5 When the CCG is supporting a response to an incident, where necessary it will establish an Incident Command and Control Room in the Boardroom of the CCG Headquarters or will join the provider s Incident Control Room off site. Membership of the Incident Command and Control Room can be found in Appendix 5. Supporting action cards can be found in Appendix 1. 6.6 Where access to the CCG Headquarters is restricted or out of bounds, the CCG will follow the Lancashire Mutual Working Agreement to facilitate alternative site working with the Commissioning Support Unit. 6.7 An EPRR escalation diagram can be found in Appendix 2: The area enclosed by the green dotted line represents the rise and fall of day to day demand in a state of business as usual. Fluctuations in performance in this area are managed on a day-to-day basis as part of good business governance and do not constitute a critical incident. For example, low level to moderate surge or capacity pressures. In recognition that some situations are sudden impact and others slow burn this is represented, respectively, by a blue and a red line. Where daily demand exceeds business as usual for any NHS provider, i.e. exceeding capability and/or capacity, a Level 1 incident response is activated. The NHS provider will escalate such issues to the CCG. Surpassing capability and/or capacity may also be caused by external circumstances with notification received from NHS England or NWAS. Exceeding capacity and/or capability limits is signified by the beginning of the red or blue line and subsequent transition points as the levels are reached and exceeded. This escalation process is repeated rising through the designated levels as indicated. Where capacity and demand, reaches or threatens to surpass a level that requires wider resources that cannot be accessed by the CCG (Level 2), a response must be coordinated by the CCG with NHS England. A more detailed escalation and alerting procedure through all four Levels can be found in Appendix 3. Referencing essential services, this may refer to a class of occupations that have been legislated by government to have special restrictions in regard to labour actions, such as not being allowed to legally strike. Essential services refers to those services which have been identified as critical to continue, for example in the interests of patient safety or business continuity. The CCG will ensure that our contracts with provider organisations contain requirements regarding emergency preparedness, resilience and response. The CCG will do this through the contracting arrangements in place. The CCG will also seek assurance from provider organisations that they are delivering their contractual obligation and will highlight areas of concern to the Accountable Emergency Officer for escalation. 8

North West Ambulance Service (NWAS) has a regional footprint so have adopted for use the National Ambulance Resilience Unit (NARU) Resource Escalation Plan (REAP). REAP aids the Ambulance Service to integrate into the wider NHS escalation framework. REAP is designed `to be informed` by any disruptive challenges and `to inform` internally and to the wider NHS, and other partner agencies, of the pressures facing the organisation. The NARU REAP should be viewed as guidance in challenging situations which includes various internal NWAS trigger levels aligned alongside the ones of the Lancashire Joint EPRR Escalation Plan. 6.9 Command and control The NHSE EPRR Framework outlines the three levels of emergency response and recovery. The levels are defined by their differing functions rather than specific rank, grade or status and are as follows: Operational level Operational is the level at which the management of immediate hands on work is undertaken. Operational commanders will concentrate their effort and resources on the specific tasks within their geographical or functional area of responsibility The operational commander will consider whether a tactical level is required and advise accordingly. 1 Tactical level The purpose of the tactical level is to ensure that the actions taken by the operational level are coordinated, coherent and integrated in order to achieve maximum effectiveness, efficiency and desired outcomes where it becomes clear that resources, expertise or coordination are required beyond the capacity of the tactical it may be necessary to invoke the strategic level of management to take overall command and set the strategic direction 2. Strategic level The purpose of the strategic level is to consider the incident in its wider context; determine longer-term and wider impacts and risks with strategic implications; define and communicate the overarching strategy and objectives for the response; establish the framework, policy and parameters for lower level tiers; and monitor the context, risks, impacts and progress towards defined objectives. 6.10 Emergency Planning, Resilience and Response (EPRR) Framework outlines the CCG s responsibility to mitigate raised levels of pressure in relation to EPRR escalation (as per the escalation process) by examining key triggers for escalation. More detailed communications procedures and incident command and control set up should be considered to address those triggers and an impact assessment of any actions put in place and assessment of implications to other organisations should also be undertaken to form part of the overall response plan. Further information can be found in Appendix 4. 1 NHS England Emergency Preparedness, Resilience and Response Framework, (Nov 2015) 2 Ibid 9

6.11 The CCG must refer to The Operational Pressures Escalation Framework (OPEL) when being asked to support Providers with their operational capacity pressures. A diagram from the framework can be found in Appendix 6 which outlines the actions of Commissioners. Local A&E Delivery Board areas will operate Operational Pressures Escalation Level (OPEL) 1 when operating within normal parameters. At OPEL 1 and 2, we would anticipate operations and escalation to be delegated to the relevant named individuals in each organisation across the A&E Delivery Board. At OPEL 3 and 4 however, it would be expected that there would be more executive level involvement across the A&E Delivery Board, as agreed locally. 6.12 P3 mass casualty sites are essentially non-acute healthcare locations where patients with minor injuries can be treated in a safe location. They will be healthcare buildings which therefore have a level of service already applied. These sites will reduce pressure on acute hospitals allowing them to focus on the critical and urgent cases. Chorley and South Ribble and Greater Preston CCGs have identified P3 sites which could be used to treat walking wounded at a time of mass casualties. Further information can be found in Appendix 8. 6.13 Through the CCGs on-call process, managers are aware of the process for escalating incidents to the NHS England Local Area Team where the incident is outside of the CCG s remit, control or of significant severity to warrant a Lancashire wide approach. Details for contacting the Lancashire Incident Manager/Strategic Commander are detailed within the CCG on-call pack. 6.14 The role and responsibilities of the on-call manager in the capacity of incident commander can be found in the actions cards within this policy (Appendix 1). 7.0 INCIDENT STAND DOWN 7.1 The Incident Response Team will receive notification of Stand Down from the organisation that initiated the notification of an incident. This may be long after the emergency services response is over. 7.2 Where the Incident Control Room was locally determined, the Incident Commander will be responsible for determining when the CCG response should be stood down. There may be a period of time where the response is partially stood down and active monitoring is undertaken before releasing all resources. 7.3 Once the stand-down decision has been taken, the CCG on-call will ensure that all appropriate elements of the local response are stood down. This may be a staged process. It is important to ensure that where communication channels have been specially created for the incident, forwarding mechanisms are in place to ensure that no traffic is lost. This will also ensure that people trying to contact the Incident Control Room, if established, have an alternative access route. 7.4 Any decision to stand-down must be communicated both internally and externally as appropriate and amendments to resource levels agreed. 10

8.0 STRATEGIC PLANNING 8.1 Under the Health and Social Care Act 2012 Local Health Resilience Partnerships (LHRP) will provide strategic forums for joint planning for emergencies for the new health system and will support the health sector s contribution to multiagency planning through LRFs (Local Resilience Forum). They are not statutory organisations and accountability for emergency preparedness and response remains with individual organisations. 8.2 The new system will offer benefits including: a more consistent approach across England, permitting better understanding of health preparedness at LRF level and nationally leadership of planning at a senior level with a focus on cross-agency preparedness opportunity for better integration between health and local government emergency planning 8.3 The Accountable Emergency Officer, or an appointed deputy, will be the CCG representative at the Lancashire LHRP and will engage with and support the wider health economy in discharging its requirements through this group. 8.4 The Accountable Emergency Officer, or an appointed deputy, will also be the conduit for escalation for the LHRP should a provider fail to maintain the necessary Emergency Planning, Resilience and Reponses capacity and capability. 8.5 The CCG has developed an On-Call rota to ensure that an emergency contact is in place in the event of issues within the acute provider or an incident being declared by the Area Team. The rota is staffed with senior members of the CCG with each member being provided with a detailed on-call pack. All senior managers on the on-call rota have been made aware of their roles and responsibilities during and outside of on call periods. 8.6 The CCG will hold an emergency planning risk register with mitigating action plans in preparedness for an incident taking place. 9.0 RECORD KEEPING 9.1 Good record keeping is paramount in the event of an incident. The senior manager on-call in the role of incident commander is responsible for ensuring that accurate records are kept of all decisions and actions taken in their area of work once an incident has been declared by NHS England s Local Area Team or if the on-call process is activated by a commissioned provider. 9.2 For all incidents facilitated in a command and control environment, either in or out of hours, the on-call manager should appoint a trained Loggist from the CCG s Loggist list which can be found in the on-call pack. The on-call manager in the role of incident commander is ultimately responsible for the log (which may be upheld in court at a later date) and will facilitate the recording of strategic decision and actions via the Loggist which are taken through the lifespan of incident response. 11

9.3 Any incidents where the CCG is asked to provide support to providers during a period of on-call either in or out of hours should be reported via an incident log form by the on-call manager. A template can be found in the on-call pack. 10.0 COMMUNICATIONS 10.1 At the time of an incident at level 3 or 4, a strategic response will be taken and communications will be led by NHS England see Appendix 3, regarding incident levels). The CCG will support NHS England as and when requested. 10.2 At the time of an incident at level 2, a tactical response will be taken and communications will be led by the CCGs. The key actions to be taken are as follows: Communications plan: A communications plan will be developed to ensure there are appropriate statements for ensuring communication to all CCG staff, Governing Body members or the general public, as appropriate, in the event of an emergency. Existing communications channels will be used, where possible. Dealing with requests from the media: Midlands and Lancashire CSU provide media relations cover during the out of hours period. All enquires during normal office hours should be referred to the CCG s communications team. Incident response team: Will need to ensure appropriate communication arrangements are in place, including keeping the CCG Chair and Chief Officer informed. Media liaison during the incident: The Incident Response Team (IRT) includes attendance of an appropriate communication representative. These will be responsible for facilitating responses, including the provision of a holding press release and the opportunity for further media interaction as appropriate. 10.3 Unless authorised by the CCG or NHS England, individual members of staff MUST NOT make statements or provide information to the media. 10.4 Message logs and decision logs will be maintained for each incident. These will record all communications and decisions made or advised. The Loggist will be responsible for ensuring these are kept up to date. The Loggist will be trained in how to log incidents. 10.5 The Loggist action card and the supporting standard operating procedure; Logging during an Emergency Incident outline further details about the role and how this should be undertaken. 12

10.6 The on-call manager in the role of Incident Commander should refer to the on-call pack for in and out of hours contact details for Loggists. 10.7 Once the stand-down decision has been taken, the CCG on-call manager will ensure that all appropriate elements of the local response are stood down. This may be a staged process. 11.0 DEBRIEFING 11.1 Debriefing provides the opportunity for everyone involved in the incident and its management to comment on the response provided. The purpose is to capture lessons learned for subsequent analysis. A debriefing session with other agencies, where appropriate will help to inform future training, improve procedures, collect evidence for the enquiry, identify and respond to the needs of staff. 11.2 A hot de-brief will be held within 24 hours of the stand down of an incident, with a full de-brief being held within 14 days of the incident. An incident report MUST be produced within 28 working days of the incident. 11.3 Structured debriefs should be held with involved staff as soon as possible after deescalation and stand down. Participants must be given every opportunity to contribute their observations freely and honestly. As part of the debriefing process a post incident report will be produced to reflect the actual events and actions taken throughout the response. Typically this will include: Nature of incident; Involvement of the CCG; Involvement of other responding agencies; Implications for strategic management of the NHS; Actions undertaken; Future threats/forward look; Chronology of events 11.4 A separate lessons identified report will focus on areas where response improvements can be made in future. This report will include the following sections: Introduction; Observations; and Recommendations; and Action Plan (detailing actions, timescales and owner) 12.0 TRAINING REQUIREMENTS 12.1 All Governing Body members and senior managers need to be aware of the contents of this plan, and ensure that they are acquainted with the CCG s on-call pack and, for those on the on-call rota that they have the necessary documents available to them at all times. 13

12.2 The Accountable Emergency Officer will, on request, provide support, assistance and advice, including instruction in the application of the process and use of the templates to any member of the CCG and CSU. 12.3 On call managers will receive training on an annual basis and on request in incident handling. 13.0 EXERCISING 13.1 This plan will be tested and reported to the CCG Governing Body as part of the CCG s Emergency Planning, Resilience and Response exercise plan. 13.2 Plans developed to allow the CCG to respond to incidents must be tested regularly. Roles within the plan, not individuals, are tested to ensure that they are fit for purpose. The outcome of testing exercises must identify and record whether it worked and what needs changing. The NHSE EPRR Framework outlines that the CCG must conduct the following types of testing exercises as a minimum: Communications exercise every 6 months These exercises are to test the ability of the organisation to contact key staff and other NHS and partner organisations 24/7. Table top exercise every 12 months The table top exercise brings together relevant staff, and partners as required, to discuss the response, or specific element of a response, to an incident. Live play exercise every three years The live play exercise is a live test of arrangements and includes the operational and practical elements of an incident response. Command post exercise every 3 years The command post exercise tests the operational element of command and control and requires the setting up of the Incident Coordination Centre. 14.0 IMPLEMENTATION, MONITORING AND REVIEW 14.1 The Accountable Emergency Officer is responsible for ensuring that this document remains current. The document will be reviewed every two years or earlier in the light of amended legislative guidance or organisational change. 14.2 The CCG will undergo the NHSE EPRR assurance process on an annual basis. This process is to assess the preparedness of the NHS, both commissioners and providers against common NHS EPRR Core Standards which will include the preparation and management of incidents. 14

Appendix 1 - Incident Plan Action Cards Action Card Senior Manager on call Stand By Notification received from NHS England Accountable to NHS England Local Area Team (LAT) Incident Director or Incident Manager Responsible for: Assessing the initial information received in respect of a potential or actual incident and escalating to NHS England Local Area Team (LAT) as necessary. No Action 1 In the event of the Senior Manager on call being notified of a potential or actual incident by: NHSE (North of England) Time Completed Notification may also come from other partner agencies. 2 Start a personal incident reporting log detailing information received and actions taken. The Incident Reporting Log can be found in Section A6. 3 Obtain as much information about the incident as possible and begin to complete the Incident Reporting Log, include any specific or urgent actions required from the CCG. 4 In light of the information received so far, assess the severity of the situation and consider the potential impact of the incident on the local health economy. 5 If it is a potential or actual incident for the NHS, or if an incident standby or implement has been declared by a partner agency, agree the CCG response with NHS England Local Area Team (LAT) 6 Immediately implement instructions from NHS England Local Area Team (LAT) and clarify requirements. Also join all NHSE meetings / conference calls. 7 If Incident Response Plan is activated and the CCG is requested to set up an Incident Control Room (ICR) notify the relevant personnel. CCG Chief Officer and Chairs, Chief Finance Officer or Head of Quality and Performance (if not available wait until working hours to declare an incident if this has not already been declared by an external body) Relevant CCG personnel to set up the ICR. Call an available Loggist to provide Loggist duties (4 hour slot per Loggist in or out of hours) see on-call pack Advise all other Loggists to prepare on stand by for duty On-call manager of provider units. Cascade information as required (see action card Activate the Plan- Senior Manager on-call ) For contact details see Sections A4,A5 and A10. 8 Call further Loggists to provide Loggist duties as necessary on a 4 hour turnaround 9 Provide further support to the NHS England Local Area Team (LAT) Incident Manager and or Incident Director. (See action card Activate the Plan- Senior Manager on-call ) 15

10 If it is NOT a potential or actual incident: If no further action is required, complete the Incident Report Log. If it can be dealt with using normal resources, notify the appropriate personnel and maintain a watching brief. Continue to reassess the situation as further information becomes available and determine if any additional action is required. In the event of any increase in the scale / impact of the incident reassess the risk and re escalate as needed. 11 Participate in CCG and multi-agency debriefs. 12 Establish communications strategy 13 Review team business continuity plans where necessary 16

Action Card Chief Officer Accountable to NHS England Local Area Team (LAT) Incident Director or Incident Manager No Action Time Completed 1 Respond as requested by the Senior Manager on-call. 2 Inform the CCG Chair. 3 When informed that an Incident has been declared proceed to the CCG Incident Control Room at Chorley House. 4 Alert NHS England Area Team which is responsible for the upward reporting of incidents and so as much information as possible about the incident should be provided. 5 Maintain liaison with NHS England Area Team providing regular updating reports of the CCG status and response. 6 Record all instructions received, actions taken and other incidents which may enable the CCG to assess the success of the Emergency Plan and provide evidence to any inquiry which may follow. All entries noted must be timed, dated signed and made in ink. 7 Send the Emergency Plan action plan to the Emergency Co-ordinator. 8 Ensure all evidence both written and electronic is forwarded to the Head of Strategy and Corporate Services 9 Counselling will be offered to all those involved in an incident 17

Action Card CCG Communications Lead Accountable to CCG - Senior Manager on-call Responsible for: providing communication co-ordination, advice and support to the CCG Senior Manager on-call. No Action 1 Confirm with the Senior Manager on-call that an incident is taking place. 2 Call NHS England Local Area Team (LAT) communications lead to confirm activation of the communications handling. 3 Commence personal log. 4 Agree communications officer support for the Incident Control Room and Incident Management Team, if they are established. 5 Issue pre-arranged Public Health / Safety Messages as requested by NHS England Local Area Team (LAT) within the first hour of becoming aware of the incident. 6 Assume responsibility for managing all public information and media communications on behalf of the Regional Team in accordance with the directions of the Senior Manager on-call and the SCG (Gold) communication cell if established. Note that if it isn t established all media responses are controlled and coordinated by the Strategic Coordination Group (SCG) (Gold) so CCG communications input/feedback should be fed upward into the NHS England Local Area Team (LAT) for communication to the SCG (Gold). 7 Rapidly formulate and implement an integrated media and communications handling plan in conjunction with NHS England Local Area Team (LAT). This will incorporate channels such as social media. Identify health spokespeople. 8 If required by the regional team alert local communications network of the incident and advise of the media handling strategy. 9 If required by the regional team deal with all media enquiries/draft statements/organise press conferences and interviews/ provide public information as agreed in the media handling strategy. 10 If required attend SCG (Gold) on behalf of the Regional Team. 11 Once a SCG has been established it will control messages about the overall incident and its health impact, to the media. Therefore it is vital that communications leads from local health organisations act as one to advise the SCG (Gold). This will be via a Regional Team communication lead, identified to be present at the SCG (Gold). 12 Identify communications officer/admin support to log media calls and develop rolling questions and answer brief. 13 If required identify communications officer/admin support to liaise with local NHS communications network to ensure urgent cascade of information / coordinated internal communications / messages for staff. This should continue as appropriate throughout the incident. 14 Provide regular updates to the Regional Team communications team and stakeholders communications teams as required. 15 On stand down, ensure that all original documentation (including notes, flip charts, emails etc.) are kept. Close personal log. Time Completed 18

16 Attend hot and formal debriefs. 17 Manage any on-going media and public interest in the local NHS response, including social media. 19

Action Card Loggist Accountable to The person for whom they are logging: Senior Manager on-call Responsible for: recording and documenting all issues/actions/decisions made by the Senior Manager on-call (decision maker in the Incident Management Team) No Action 1 The Loggist must use the Incident Report log provided 2 On arrival all staff must wear ID badges. If the badges are unclear the Loggist must ask for clarification of who is present within the room and their title. 3 The log must be clearly written, dated and initialled by the Loggist at the start of shift and include any location. 4 All persons in attendance to be recorded in the log. 5 The log must be a complete and continuous record of all issues/actions/decisions made by the Senior Manager on-call. 6 Timings have to be accurate and recorded each time information is received or transmitted. If individuals are tasked with a function or role this must be documented and when the task is completed this must also be documented. 7 If notes or maps are utilised these must be noted within the log. 8 At the end of each session (4 hour slot per Loggist) in the log a score and signature is to be added underneath the documentation so no alterations can be made at a later date. 9 All documentation is to be kept safe and retained as evidence for any future proceedings. 10 When something is written in error changes must be made by a single line scored through the word and the amendment made. 11 Participate in CCG and multi-agency debriefs. The loggist is NOT: A gofer; General Administrative support; The loggist MUST NOT: Take minutes; Record for more than one decision maker; Keep a separate chronological log; Have responsibility for the decision/action. Please note: The Incident Reporting Log and all paper work becomes legal documentation and could be used at a later date in a public enquiry or other legal proceedings. 20

Action Card Senior Manager on call at Stand Down Accountable to NHS England Local Area Team (LAT) Incident Director or Incident Manager When the Stand Down command is given by the NHS England Local Area Team (LAT) Incident Director, the Senior Manager on-call must: No Action 1 Ensure the process continues to maintain that business runs as usual internally and externally across the CCG, it is possible that the Business Continuity Group (Recovery Group) are not stood down at the same time as the Incident Team. 2 Support the multi-agency recovery phase if required. 3 Stand down the CCG Incident Management Team as agreed with the Regional Team. 4 Agree when staff involved in the incident should return to their normal duties. 5 Debrief the staff working in the incident room (hot debrief). 6 Complete and sign off the CCG Incident reporting Log and ensure all relevant documentation is secured. 7 Ensure a formal report is prepared, highlighting any good practice or issues identified. 8 Participate in CCG and multi-agency debriefs. Time Completed 21

General Action Card for all CCG staff to be read prior to an incident Suspicious Packages at Chorley House In advance of an incident Ensure that you have read and understood the action card. Suspect Contents of a Package / Letter If you find a package / letter that has suspicious contents whilst opening it, STOP immediately. Gently put the package down and move away. Ensure that everyone else around the package is informed of your suspicions and is moved away. If the package has powder, or fluids come from it that may have contaminated yourself When alerted to the CCG ICR Maintain a personal log / notes of the incident if your role requires this. Set up the ICR if you are requested to do this as part of your role. Ensure that your organisation continues to provide advice whilst you are in transit to the ICR, e.g. a second member of staff responds to queries raised. When alerted to attend another organisations ICR Ascertain where the ICR is being established and make your way to the location. Ensure that your organisation continues to provide advice whilst you are in transit to the ICR, e.g. a second member of staff responds to queries raised. Ensure you have a full briefing of your organisations actions / decisions. Maintain a personal log / notes of the incident if your role requires this. Post Incident Provide your personal log / notes and other documents. Contribute to post-incident debriefing. Contribute to the report of the incident. 22

Appendix 2 - Incident Management Escalation Process NHS INCIDENT MANAGEMENT ESCALATION 23

NHS England National team NHS England Regional team Spec Comm CCGs with NHS England and Primary Care Provider with CCGs Appendix 3: Escalation and Alerting Procedure Provider Escalation and Alerting Capacity and demand reaches, or threatens to surpass, level that requires wider resources that cannon be accessed by the provider A business continuity incident that threatens the delivery of patient services Responding to a declared major incident or major incident standby A media or public confidence issue that may result in local, regional or national interest A significant operational issue that may have implications wider than the provider e.g. public health outbreak, suspect Ebola, security incident, Haz-mat incident Coordinating Organisation NHS Incident Level 1 CCGs Capacity and demand reaches, or threatens to surpass, a level that requires wider resources that cannot be accessed by local CCGs A business continuity incident that threatens to surpass a level that threatens the delivery of essential patient services (in line with ISO 22301) Responding to a declared major incident or major incident standby A media or public confidence issue that may result in local, regional or national interest A significant operational issue that may have implications wider than the local health economy e.g. public health outbreak, suspect Ebola, security incident, Hazmat/CBRN incident 2 NHS England Regional team local office NHS England Regional team Capacity and demand reaches, or threatens to surpass, a level that requires regional coordination or NHS mutual aide e.g. ECMO, PICU, Burns, other specialist function A business continuity incident that threatens the delivery of an NHS England function A business continuity incident impacting on more than one providers' essential services Responding to a declared major incident and/or the establishment of an NHS England Incident coordination centre (ICC) A media or public confidence issue that may result in regional or national interest A significant operational issue that may have implications wider than the remit of the local office of the regional team e.g. public health outbreak, suspect Ebola, security incident, CBRN/Hazmat incident, Critical National Infrastructure (CNI) An incident that may require the request and activation of a military MAC A An incident that may require the activation of the National Ambulance Coordination Centre (NACC) Capacity and demand reaches, or threatens to surpass, a level that requires national coordination or NHS mutual aid e.g. ECMO, VHF, Burns, other specialist function A business continuity incident that threatens the delivery of an essential NHS England function or a protracted incident effecting one of more NHS England sites A business continuity incident with the potential to impact on more than one region A declared major incident which may have a significant NHS impact and/or the establishment of an NHS England Incident Coordination centre (ICC) A media or public confidence issue that may result in regional, national or international interest A significant operational issue that may have implications wider than the remit of the regional team e.g. flooding, security incident, Hazmat/CBRN incident, Critical National Infrastructure, collapse of a commissioned supplier that provides services to more than one region An incident that may require the request and activation of a military MAC A 3 NHS England National team Department of Health Capacity and demand reaches, or threatens to surpass, a level that requires international coordination e.g. ECMO, VHF, Burns, other specialist function Invocation of central government emergency response arrangements Issues that may require invocation of 'Emergency Powers' to be invoked under the CCA 2204 or measures under Sections 252A or 253 of the NHS Act 2006 A business continuity incident with the potential to impact on significant aspects of the NHS e.g. NHS Supply Chain, NHS Blood and Transplant A business continuity incident with the potential to impact on significant aspects of the delivery of NHS England A declared major incident which may have national and/or international implications e.g. CBRN, MTFA A media or public confidence issue that may result in national or international interest A significant operational issue that may have implications wider than the remit of the NHS e.g. Critical national Infrastructure An incident that may require the request and activation of a military MAC A 4 24

Appendix 4: Mitigation Plan 25

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Appendix 5 The Incident Command and Control Centre Incident Response Team The membership of the Incident Response Team will comprise: Incident Commander This is the on-call manager, who may be replaced by a member of SMT or the Chief Officer dependent on the nature of the incident Communications Representative This could be from the CCG Communications team or the out of hours support commissioned from MLCSU Administrative Support Loggists Call handlers Runner The role of the incident response team is to Ensure continuous review of the situation to determine a continued appropriate response Ensure appropriate documents and records are being made and retained, including the capture of accurate financial information relating to additional expenditure as a result of the incident Ensure appropriate communication arrangements are in place, including keeping the CCG Chair and Chief Officer informed Ensure, where possible, that the response can be maintained within the local health economy Maintain resources to support the incident response team, including shift changes as appropriate Ensure the CCGs critical services are maintained Determine when the incident is over and stand down the CCG response Ensure that all staff who have been involved in the response to the incident are debriefed Ensure an incident investigation report is written, where appropriate Ensure lessons learned are incorporated into future incident response arrangements. Action cards have been developed to support individuals involved in the incident Response Team and provide detailed instruction and information containing emergency procedures, functional roles and responsibilities pertinent to specific ICR roles. Staffing the Incident Response Team The Incident Commander will need to agree with other CCG senior managers the arrangements for on-going staffing, dependant on local availability, CCG working arrangements and the anticipated longevity of the incident. Contact details for all staff are held in the on call file provided to each on-call manager. These will be kept as up-to-date as possible and reviewed quarterly for accuracy as part of business continuity planning. Record keeping during the Incident Following an incident, the CCG may be required to provide evidence to an appropriate enforcement agency (e.g. HSE), a judicial inquiry, a coroner s inquest, the police or a civil 31

court hearing compensation claims. In the course of any or each of these, the CCG may well be obliged or advised to give access to documents produced prior to, during and as a result of the incident. Under no circumstance must any document which relates or may in any way relate (however slight) to the incident, be destroyed, amended, held back or mislaid. During any incident, a document means not only pieces of paper but also photographs, audio tapes, video tapes, and information held on a PC, laptop, mobile device (including phones, ipads) or other computer. This also includes electronic mail. Message Logs and decision logs will be maintained for each incident. These will record all communications and decisions made or advised. The IRT Loggist will be responsible for ensuring these are kept up to date. 32

Appendix 6 OPEL Actions for Commissioners 33

Appendix 7 P3 Sites Examples of complex incidents that could overwhelm resources where P3 sites would support: Incident Location and date Fatalities Injuries Terrorist attack New York 2001 2993 8700 on the World Trade Centre Multiple bomb Bali 2002 202 300 attacks in a tourist resort Multiple bomb Madrid 2004 191 1900 attacks to transport system Tsunami Thailand 2004 2,000,000+ Unknown Multi bomb London 2005 52 650 attacks across a city Terrorist active Mumbai 2008 166 300 shooting in a city Bomb attack and Osla 2011 77 151 active shooting Paris attacks Paris 2015 130 368 These are extraordinary circumstances and are dealt as best endeavours. In the event of such an incident regular activity for that day will have to cease to accommodate the unexpected scenario. The decision to open a P3 site would come from NHS England in liaison with the CCG on call manager. A separate standard operating procedure for P3 sites is available on the staff intranet. 34