Ministerial Response - Safer Travel Guidelines Review Final Report - 11 February 2021

Findings

Comments

1

Inbound  travel  has  significantly impacted  the  number  of  positive COVID-19  cases  within  Jersey.  The number of non-travel related infections of  COVID-19  in  Jersey  remained relatively  low  from  July  until September. However, the Panel notes the number of active cases  has  been rising rapidly since October 2020.

The  introduction  of  the  Safer  Travel  Policy impacted the number of positive cases identified in  Jersey  due  to  the  volume  of  tests  being conducted on arriving passengers leading to an increase in positive cases being detected. Whilst it is inevitable that inbound travel has resulted in the introduction of cases to Jersey, the Safer Travel policy has provided a proportionate response to the  level  of  risk  through  the  evidence-based targeting of testing and isolation requirements.

In Jersey, opening of the borders on 3 July was facilitated by the Safer Travel Policy which put in place a series of testing and isolation requirements for  arriving  passengers.  A  risk  stratification process (red/amber/green rating of countries) was used to reduce the risk of importing any new cases of  the  Covid-19  virus  into  the  community.

Throughout July, August and early September, there was evidence of only very low on-Island transmission.  The  border  testing  programme effectively identified the majority of new cases either on the day of arrival or on a day 5 test. For a small number of these cases, there was very limited  transmission  to  immediate  household contacts  who  were  already  in  isolation.

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Comments

From mid-September, the number of cases in the UK, France and beyond began to rise and the likelihood that an arriving passenger would test positive increased. The Safer Travel Policy was correspondingly adjusted in order to respond to this risk, with the introduction for green arrivals of self-isolation until the result of a day 0 test and an  additional  day  5  test.

In  October,  the  number  of  cases,  household groups and clusters of new cases not clearly linked to arriving passengers (unknown source) began to rise, indicating that transmission was occurring on-Island outside affected households, most likely through  individuals  without  symptoms  or  with mild symptoms who were unaware they had the virus.

This trend has continued into November with the majority of new cases now no longer associated with inbound travel, although most are linked to an already known case on-Island.

2

The  Safer  Travel  Guidelines  was implemented on the understanding of "balanced risk".

The implementation of any public health measure is a balance of considerations. In the case of the Safer Travel Policy, there is a balance to be struck between the proportionate deployment of testing and isolation requirements at the border and the various harms caused by a reduction in travel or a reduced connectivity for islanders.

3

Medical  statistics  and  forecasts  of onward infections have developed over time based upon testing regimes and accuracy of tests.

In  line  with  all  other  jurisdictions,  the understanding  of  the  COVID-19  virus  has developed  quickly  through  the  course  of  the pandemic,  assisted  by  increased  range  and availability of testing technology.

4

Medical  advisors  acknowledge  that risks  are  perceived  differently  by different  people,  and  a  balanced approach is needed.

Agreed

5

The Safer Travel Guidelines has used natural decrease of traveller numbers

It is understood that demand for travel will be impacted  by  a  number  of  factors  including standard  seasonal  variations,  increasing restrictions in neighbouring jurisdictions and the

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due to infection rates in neighbouring counties, within its strategy.

nature of risk mitigations in place, particularly with regard to isolation on arrival in jersey.

6

The  RAG  rating  will  likely  lead  to fewer incoming travellers and more of those travelling will face isolation for greater periods of time.

The continued increase in case notification rates in neighbouring jurisdictions and domestic public health  restrictions  has  led  to  a  drop  in  travel demand; the majority of arriving passengers are now classified as red on arrival and attract a longer period  of  self-isolation.  From  20  November, arriving passengers have been subject to a revised 'triple testing' programme which will reduce the maximum isolation period from 14 days to around ten. [Note: this comment was agreed before recent changes.]

7

The  Safer  Travel  Guidelines  has impacted  islanders'  mental  wellbeing both positively and negatively.

The outcome of a robust Safer Travel Policy has been of benefit in a number of areas including mental  health,  family  cohesion,  education  and business.

8

The  Safer  Travel  Guidelines  has directly  reintroduced  COVID-19  into the community.

It is not accepted that the Safer Travel Policy reintroduced  COVID-19  into  the  community. While it is inevitable that positive cases will be detected  at  the  border,  there  is  insufficient evidence to conclude that the Safer Travel Policy was solely responsible for a subsequent increase in case notification rates.

9

Onward  transmission  has  started  to impact islanders.

It is clear that onward transmission has begun to impact islanders as reflected by the increased case notification  rate  and  subsequent  public  health mitigation implemented.

10

Recommendation  4  of  the  Panel's Interim Report, calling for self-isolation of all arrivals, has now been carried out, bar  isolation  within  Government provided facilities.

The  on-island  testing  facility  is  now  fully functional and has a maximum operating capacity of 2000 tests per day. This testing capacity has enabled a policy to direct every arriving passenger to  self-isolation  for  at  least  24  hours  whilst waiting for their first test result.

11

Self-isolation requirements have been updated to match the risk of infection from travellers, as well as capacity of testing systems.

The  assessment  of  country  and  region  risk classifications  is carried out and updated on a weekly  basis,  thereby  reacting  to  the  risk  of infection  posed  by  cohorts  of  travellers  from

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different jurisdictions. The requirement to self- isolate or the testing regime imposed is based on the  assessed  risk  to  public  health  and  is  not affected by testing capacity.

12

Very  few  individuals  choose  not  to participate in border testing.

The levels of participation in the Safer Travel Testing Programme have been consistently high. This is considered a substantial positive and is indicative of the appetite for testing at the border and  the  benefit  of  the  policy  to  the  island's connectivity.

13

Current policy assumes that children at boarding  schools  are  appropriately isolated from surrounding communities before travel.

The policy for children returning from education or  care  placements  was  approved  by  the Consultant  in  Communicable  Disease  Control. The application process includes a declaration that the child has not been identified as a direct contact or required to isolate under public health guidance in the 14 days prior to arrival.

14

Policies  for  university  students returning  to  Jersey  were  still  being finalised at the time of this review.

The Government of Jersey has established a cross- government Travel Cell to scope and implement policy for returning University students. This will include the need to ensure travel connectivity and support to isolate on arrival in Jersey for those who require it.

15

Exemptions  to  isolation  requirements for essential workers are reviewed on a case by case basis.

Applications for permission not to isolate for work purposes  are  made  through  a  standardised application process with clear eligibility criteria. Each application must be supported by evidence of  risk  mitigations  in  the  workplace  and  the permission only applies to the period of time the individual is at work. While each application is considered individually by the Contact Tracing Service, any approval is given within a clear and published framework.

16

It  is  assumed  that  groups  of  visiting workers will segregate themselves from the larger community.

Applications for permission not to isolate for work purposes are approved on the basis that the worker isolates at all other times when not at work for the period  of  time  as  designated  by  their  travel history. Applications for permission in instances where the work involves a public facing aspect are

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unlikely  to  be  approved  unless  in  exceptional circumstances.

17

Day 0 tests have been prioritised for on- island analysis, leading to a difference in times to receive test results.

As the on-island testing facility was established, Day  0  tests  were  prioritised  to  avoid  arriving passengers having to isolate unnecessarily. The overwhelming  majority  of  all  tests  are  now processed  at  the  on-island  facility  and  benefit from the same rapid result turnaround time.

18

The  on-island  testing  facility  is  still building capacity and will be used for subsequent  (day  5)  tests,  as  well  as community testing.

The overwhelming majority of all tests are now processed  at  the  on-island  facility  and  benefit from the same rapid result turnaround time.

19

Further testing capacity is envisaged, pending  quality  assurance  of equipment.

The  on-island  testing  facility  is  now  fully functional and has a maximum operating capacity of 2000 tests per day; this is well within current and anticipated testing requirements.

20

The  contract  tracing  team  is  now resourced; however, some procedures still slow the tracing of individuals.

From the point that an individual is identified as a direct contact of a confirmed COVID-19 case, every effort is made to contact that person at the earliest  opportunity. Resources  are  in  place  to meet the demands placed on the Contact Tracing Service with active recruitment ongoing.

21

The  majority  of  direct  contacts  are traced within 24 hours. There has been at least one positive case of which the source cannot be traced.

There are now more cases on-Island that cannot be  linked  back  to  a  travel-related  source. However, we are linking cases to specific events or  workplaces  and  establishing  new  clusters through that method

22

The Jersey COVID alert app will not be mandatory for travellers, although will be  strongly  recommended. Furthermore,  self-isolation  on notification  by  the  app  that  an individual has come into contact with a positive case will not be mandatory.

Mandated  use  of  the  app  is  not  considered preferable for a number of reasons. In the first instance, the compulsory use of the technology would not be in line with European Commission guidelines. It would also be discriminatory against those who do not own, or know how to operate, the  necessary  smart  device  technology.  In addition,  there  are  enforcement  challenges  in legislating for mandatory use; for example, the act of switching off a mobile phone or simply leaving it at home could in those circumstances become a criminal offence.

The implications of delivering and enforcing an

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isolation  order  via  the  app  rather  than  from authorised and empowered officers and the right to deprive someone of their liberty based on a relatively unproven automated system have not been  fully  explored  in  Jersey's  legal  context.

The non-mandated approach to both usage and action on notification is felt to be best suited to encouraging mass participation and engagement with the technology.

23

The Jersey COVID alert app is  now compatible with those used in the UK.

The  underlying  tools  in  the  device  operating system are common to all modern android and iOS  devices.  We  have  since  worked  with  our counterparts  in  England/Wales,  Scotland, Northern  Ireland  and  Gibraltar  to  exploit  that commonality  and  create  a  seamless  user experience across nations. Users don't have to do anything to remain protected by their apps as they travel in the UK.

24

Some individuals may not be contacted for 72 hours when failing to respond to Government SMS messages.

The policy for SMS follow-up has been revised to reflect  this  position  with  non-response  being followed up within the 36-hour period.

25

There have been some issues with the SMS  text  message  system  for  a minority of individuals.

In a small number of cases, network or data issues have  prevented  individual  travellers  from responding to SMS contact.

26

The monitoring and enforcement team have carried out a significant number of actions to check adherence to rules.

The number of checks is significant and is central to the credibility of the Safer Travel Policy.

27

There are individuals who continue to breach self-isolation requirements.

It is inevitable that some individuals will breach the  isolation  requirement.  Nevertheless,  the regime  of  monitoring  through  home  visits  is robust and ensures that any non-compliance runs the credible risk of detection and prosecution. Our monitoring  and  enforcement  regime  acts  as  a significant  deterrent  to  non-compliance  and compares extremely positively to the enforcement activity seen in neighbouring jurisdictions.

28

There is difficulty in investigating the truthfulness of the declaration on the

Given  the  volume  and  scope  of  information collected at pre-registration, it is not feasible to verify the authenticity of all information provided;

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travel registration form and in declaring travel history.

the system relies on a participant engaging with the process in good faith. Nevertheless, where instances of wilful misinformation are suspected, these are investigated and, in appropriate cases, will be prosecuted. All participants are informed that knowingly providing false information is a criminal offence, punishable by a fine of up to £10,000.

29

Areas of the Safer Travel Guidelines continue to rely on the good will of individuals travelling to the island.

It is accepted that with regard to the provision of information  and  adherence  to  the  isolation requirement,  the  overriding  expectation  is  that individuals  will  comply  in  good  faith. Nevertheless,  where  instances  of  wilful  non- compliance or misinformation are suspected these will  be  investigated  and  prosecuted.  The consequences  of  a  failure  to  comply  with  the requirements are stated clearly in the Safer Travel Guidance  and,  in  relation  to  the  isolation requirement in particular, a number of successful prosecutions have resulted from monitoring and enforcement activity.

30

Communication  of  the  Safer  Travel Guidelines  remains  predominately electronic and digital in nature.

It  is  accepted  that,  as  far  as  possible,  it  is preferable to make important guidance available in  a  number  of  formats.  However,  given  the rapidly  changing  context  of  the  pandemic,  the repeated updating of paper documents or printed public facing material has often been impractical or  not  cost-efficient.  As  far  as  possible,  the necessary  information  will  continue  to  be provided in as wide a range of media as possible.

31

Further  transparency  in  the  decision making behind Safer Travel Policies is still needed and timely communication of  future  changes  to  the  Guidelines continues to be an issue.

The rapidly developing nature of the COVID-19 pandemic  has  required  an  agile  and  flexible approach across all policy areas, including the Safer Travel Policy. Within such a context, it is not  always  possible  to  communicate developments within the timescales which would otherwise be expected. On each occasion when a change in policy has been required, every effort has been made to ensure that the highest quality information  is  available  to  the  public  and stakeholders at the earliest opportunity. This will remain the case.

Findings

Comments

32

Various  actions  are  taking  place  to compliment  the  Safer  Travel Guidelines during the upcoming winter.

The Government of Jersey's COVID-19 Winter Strategy  comes  into  effect  on  20  November. Under the strategy there are eight main actions being  taken  over  the  winter  to  keep  islanders secure, safe and well: increasing on-Island testing; continually  updating  our  classifications  of countries  and  regions; introducing  mask  policies  for  indoor  public spaces; adopting shielding programmes to keep people at high risk safe but connected; vaccinating for flu and for COVID-19; making sure all of Government is prepared, especially in supporting care, health and economic interventions; being ready to escalate if needed, but using the 'least overall harm' principle; and communicating about sensible behaviour, underpinned by guidance and backed with enforcement.

Recommendations

To

Accept/ Reject

Comments

Target date of action/ completion

1

As infection rates have increased in neighbouring jurisdictions stricter self- isolation periods must be considered. Specifically, from immediate effect, those travelling from Green regions should isolate until a day 5 negative test. Urgent consideration should also be given to the requirement for those travelling from Amber regions to isolate for 14 days.

Not accepted

Under  an  update  to  the  Safer  Travel Policy  as  advised  by STAC,  from 20 November all arriving passengers will be required to undergo 3 x tests on Day 0, 5 and 10. Isolation periods will be linked to  this  testing  framework  with  green arrivals isolating until a negative Day 0 test result, Amber arrivals isolating until a  Day  5  negative  test  result  and Red arrivals isolating until a Day 10 negative test result. (Note: since the above text was agreed, the policy has been further updated.)

Recommendations

To

Accept/ Reject

Comments

Target date of action/ completion

2

As it has been shown that children and students are capable  of  transmitting the virus, from immediate effect,  they  should  be treated  the  same  in relation  to  self-isolation rules and inbound travel, to  decrease  the  risk  of further  school  closures and onward transmission.

Not accepted

The testing age threshold at the border is fixed at 11 years of age. This threshold is based on the fact that the overwhelming majority of children under the age of 11 are  accompanied  by  adults  who  are tested,  therefore  the  risk  of  infection within  the  travelling  group  is appropriately assessed. The introduction of testing for under 11s at the border is not  considered  a  proportionate intervention based on medical advice.

3

Clear,  contingent planning for the return of university  students must be undertaken, including a  firm  policy  on  what provision  and  support will be made available to enable  them  to  self- isolate  safely  on  their return.  This  should  be finalised  and  announced by  the  Government without delay.

Accepted

The  Government  of  Jersey  has established a 'Travel Cell' led by officers of  the  Chief  Operating  Office  and CYPES to scope the issue of returning university  students  and  progress appropriate  support in terms  of  travel connectivity and support to isolate.

Immediate / completed

4

Greater  clarity  and formalised,  publicly available  rules  for visiting  workers,  should be  provided  before  the end of November 2020.

Not accepted

The eligibility criteria and public health guidance for arriving workers wishing to leave  isolation  for  work  purposes  are available  on  Gov.je.  The  process  is underpinned by a clear set of eligibility criteria, a formalised application process and a set of risk mitigations which must be in place to receive permission.

5

As  soon  as  practical, enable  day  5  testing through the on-island lab as  a  priority  to  allow people  to  return  to  the community  in  a  timely and safe manner.

Accepted

Other than in unforeseen or exceptional circumstances, all Day 5 test are now processed  through  the  on-island Opencell laboratory.

Immediate / completed

Recommendations

To

Accept/ Reject

Comments

Target date of action/ completion

6

Before  the  end  of December  2020, investigate  and  agree suitable  data  protection protocols,  approved  by the  Information Commissioner, for more expedient  retrieval  of plane manifests, in order to  be  able  to  identify direct contacts quicker.

Accepted

Information  sharing  arrangements  are now  in  place  with  commercial  travel operators facilitating the rapid sharing of information for contact tracing purposes. The  track  and  trace  team  is  now receiving passenger manifests in a fast turnaround  from  the  appropriate companies.

Immediate /

completed

7

With  immediate  effect, promote the Jersey Covid Alert app predeparture to all  travellers,  including those  departing  Jersey, and  ensure  strong suggestion  of  self- isolation if notified of a positive  case  interaction before  contacting  the helpline.

Accepted

Passengers will be made aware of the COVID  Alert  App  at  pre-registration. From  8  December  those  identified  as direct contacts through the app will be told  to  isolate  while  awaiting  contact from the Contact Tracing Service.

Immediate /

Dec 20

8

With  immediate  effect, individuals  who  fail  to respond to wellness SMS text  messages  for  36 hours should be followed up to ensure symptomatic individuals  are  not interacting with the larger community.

Accepted

The policy for SMS follow-up has been revised to reflect this position with non- response being followed up within the 36-hour period.

Immediate / completed

9

With  immediate  effect, bolster  enforcement team's visits to those in self-isolation to check for adherence to the rules.

Accepted

Resources have been made available to increase  the  Monitoring  and Enforcement Teams capacity. Resources will  continue  to  be  available  to  meet demand  and  ensure  that  the  isolation requirement is effectively monitored.

Immediate /ongoing

10

Further  communication of the importance of self- isolation  and  the

Accepted

The  consequences  of  non-compliance with isolation requirements will continue to  be  communicated  clearly  through

Immediate /ongoing

Recommendations

To

Accept/ Reject

Comments

Target date of action/ completion

consequences  for  not doing so i.e. fines, should take place by December 2020,  to  help  build greater compliance.

appropriate  means  to  encourage compliance.

11

The  travel  registration form should be amended with immediate effect to deal specifically with the matter  of  truthful declaration  of  travel history.  Consideration should  also  be  given  to ways  in  which  this message  can  be reinforced  to  travellers, including  the consequences  for  non- compliance.

Accepted

The  travel  form  is  being  amended  to emphasise  the  offence  of  knowingly providing  false  information,  which  is punishable by a fine of up to £10,000.

Immediate /Dec 2020

12

Consideration  should  be given to the prioritisation of  non-digital communication  of  the Safer  Travel  Guidelines as soon as possible.

Accepted

Hard  copies  of  the  Safer  Travel Guidelines are available.

Immediate /ongoing

13

Decisions  surrounding the  Safer  Travel Guidelines must be made in a timely manner, with options  clearly communicated  ahead  of time  to  allow  for inclusion  of  the  States Assembly and Scrutiny in any decision making.

Accepted

Communication of changes to the Safer Travel  Policy  to  the  States  Assembly will be as clear and timely as possible within  the  context  of  the  rapidly changing pandemic situation.

Immediate / ongoing

14

Simple,  clear,  and frequent  communication of  the  Safer  Travel Guidelines must continue

Accepted

Effective and timely communication of the  Safer  Travel  Guidelines  will continue indefinitely.

Immediate / ongoing

Recommendations

To

Accept/ Reject

Comments

Target date of action/ completion

through  the  winter period.