November 4, 2020
UPDATE: COVID-19 guidance for telecommunications infrastructure build and maintenance of networks in Scotland
A statement from the Scottish Government to telecommunications operators signposting them to existing guidance on critical national infrastructure and construction sectors. For more information please click here.
Coronavirus advice for Telecoms Operators in relation todeployment and maintenance
- Where we are now
- Deployment activity during the Covid-19 pandemic
- Outbreak management
- Test and Protect
Digital connectivity has never been more vital than it has proven to be during the last few months, whether supporting our health and emergency services or in enabling people to work or study from home and stay connected to friends and family.
The telecoms sector is also critical in supporting the development and growth of Scotland’s economy, especially in more remote areas and in support of a resilient and green recovery from the impacts of COVID-19.
This is a further update to the 30 July Coronavirus (COVID-19): statement to telecommunications operators which confirmed the role of telecoms as part of our critical national infrastructure (CNI) and confirmed the key worker status of telecoms staff who have been undertaking critical maintenance and repairs throughout this challenging period.
This update does not constitute legal advice.
Where we are now
Inevitably, opening parts of our economy and society has provided new opportunities for the virus to spread and the Coronavirus (COVID-19): Scotland’s Strategic Framework was published on 23 October 2020, setting out how we will work to suppress the virus to the lowest possible level and keep it there, while we strive to return to a more normal life for as many people as possible and tackle the four harms we know the virus causes.
This framework sets out a new approach to outbreak management based on five levels of protection consisting of four levels above the Route Map Phase 3 baseline (or 'Level 0') as set out below:
Level 0 (baseline) and Level 1
Within these levels, we would expect to see low incidence of the virus with isolated clusters, and low community transmission. Broadly,these levels are the closest we can get to normality, without a vaccine or effective treatment in place, before conditions will allow us to move to Phase 4 of the Route Map. They would be similar to the measures in place during the summer, once we reached Phase 3. The Baseline and Level 1 are designed to be sustainable for longer periods.
Within Levels 2 and 3, we would expect to see increased incidence of the virus, with multiple clusters and increased community transmission. There would be a graduated series of protective measures to tackle the virus, focusing on key areas of risk – broadly, indoor settings where household mixing takes place with less, or less well-observed, physical distancing and mitigations. The measures would be intended to be in place for relatively short periods (2-4 weeks), and only for as long as required to get the virus down to a low, sustainable level.
Within this level we would expect to see very high or rapidly increasing incidence, and widespread community transmission which may pose a threat to the NHS to cope. It is likely that this level would see the introduction of measures close to a return to full lockdown. Measures would be designed to be in place for a short period, to provide a short, sharp response to quickly suppress the virus.
Deployment activity during the Covid-19 pandemic
The Scottish Government has engaged with operators and the Communications Workers’ Union to inform our view that in line with construction and road works, telecoms activity is well placed to continue, using experience gained throughout the previous months as restrictions eased to allow activityto resume.
This is reinforced by the updated Strategic Framework which states that the construction sector (including road works) and outdoor work can continue in all levels of restrictions up to and including Level 4 within the Strategic Framework subject to implementing agreed safe working practices for those sectors.
A further consideration is where operators are required to carry out works in-home or in business premises. Guidance on business and physical distancing supports essential work in peoples’ homes continuing in Levels 1-3 of the Strategic Framework. This should be read as allowing both telecoms repairs and new installations, given how important broadband isin supporting the ongoing need for some people to work and study from home. The position for Level 4 is still being developed and an update will be provided indue course.
Building our digital infrastructure
Expanding our digital infrastructure, whether fixed broadband or mobile, involves a complex set of activities. Central to deploying the fibre which will ensure every premises in Scotland can access superfast speeds and which also supports the expansion of our 4G and 5G networks, is the partnership working between operators and local authorities
Most of the roll-out takes place through civils works on our road and footpath networks and so working closely with the Scottish Road Works Commissioner (SRWC) is key to ensuring the safety of engineers and others engaged in such activity.
In this regard the Commissioner issued a statement which signposts to supporting Health & Safety Executive advice and also highlights that the appropriate standard is the Safety at Street Works and Road Works, A Code of Practice 2013. The Commissioner states that it is the responsibility of each organisation working in or on the road network to undertake a site specific risk assessment before works are carried out. The code requires that this risk assessment be dynamic, and updated to reflect changing circumstances during operations.
The UK Government has also published guidance and whilst the content on ‘streetworks’ does not apply in Scotland, the rest of the guidance makes clear that landowners and occupiers of land who have entered into agreements with providers of telecommunications networks should continue to meet their obligations under those agreements.
Of course, there are elements of our mobile network expansion which is more closely aligned with traditional construction. Mobile UK is co-ordinating our engagement with the sector, as they consider the Scottish Government’s construction guidance and standard operating procedures.
All employers are by law required to carry out risk assessments and must engage employees in that process, through trades union or workforce representatives. Given the current risk to public health from Covid-19, self-employed persons should also carry out a risk assessment. The information on how to carry out a risk assessment is on the Healthy Working Lives website and includes sample assessments for different types of situations including working in other people’s homes.
Further advice on preventing transmission of COVID-19 along with other good hygiene practice amongst employees, customers and all those on business premises is available from Health Protection Scotland. If an employee becomes ill at work with Covid symptoms you should follow the Test and Protect guidance.
If workers think their working conditions are unsafe, they have rights under Section 44 of the Employment Rights Act (1996). For workers who are members of a trades union, they may wish to speak to their trades union representative.
Further information on outbreak management, Test and Protect, and advice for those at highest risk can be found at www.gov.scot
About Building Mobile Britain
Building Mobile Britain is a campaign created by Mobile UK seeking to work with national and local government, as well as interested industry groups to overcome the challenges we face with expanding the existing mobile networks, while also developing innovative services for customers.
See here for further information - or #BuildingMobileBritain
Head of Policy and Communications
Tel: 07887 911 076