UNCLASSIFIED
Headquarters New Zealand Defence Force
DEFENCE HEALTH DIRECTORATE
MINUTE 02/2022
02 Mar 22
1006/DHD/2
CPO (Through: COS)
For information
DDLS
DDOS
COS OCDF
NZDF COVID-19 VACCINATION STATUS HEALTH ASSESSMENT
Reference
A.
DFI 0.81 Risk Management Instructions dated 06 Jul 20
Background
1.
Since Jan 2020 COVID-19 has been present as a global health threat. Infection with
COVID-19 carries significant individual risk and unchecked transmission results in significant
population health risk.
2.
NZ national strategy for the pandemic was initially one of targeting elimination of the
risk to the community. The effectiveness of this approach has since been diminished by new
more transmissible variants and by reducing capacity in public health components to apply
population protection that may limit transmission (such as contact tracing to identify
personnel who should be isolating). NZ national strategy is now one of ‘mitigation’ where
national health assets are focused on responding to vulnerable communities. Businesses and
organisations are now expected to self manage their workplace and personnel safety risk.
3.
Throughout the international COVID-19 pandemic, NZDF personnel have had a very
wide range of tasks and duties that have seen personnel unable to isolate from exposures,
even when NZ community exposure likelihood was rare. Our Managed Isolation and
Quarantine Facilities (MIQF), border duties and international postings, deployments and
responses have seen NZDF personnel in situations where exposure to COVID-19 has not
been eliminated by routine public health control measures (such as distancing, masks,
staying away from symptomatic or infected personnel).
4.
A number of NZDF personnel have contracted COVID-19 from these situations.
Infection carries a risk of harm to individuals and unfortunately we have had a number of
early COVID-19 cases in NZDF and several of these cases, (notably pre vaccine availability),
have lasting health impacts from their infection. Several cases in NZDF staff have resulted
from secondary contacts where personnel have contracted COVID-19 from other infected
personnel who have direct contact with an exposure, rather than being directly exposed
themselves.
5.
COVID-19 has presented significant ongoing risk to NZDF operations and outputs. Due
to the necessary and ongoing public health response to infected cases there is significant
organisational impact if a positive case is detected in an NZDF workplace – the requirement
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for any high risk contacts of the infected person to isolate until their risk of infection can be
confirmed, has resulted in instances of hundreds of NZDF personnel affected by the
consequence of a handful of positive cases in the workplace.
NZDF Risk Mitigation
6.
To date NZDF has managed COVID-19 as a community and workplace hazard, with a
risk assessment approach to determine appropriate mitigations to reduce the risk of;
individuals contracting COVID-19, individuals having poor health outcomes from COVID-19
infection and COVID-19 exposure and transmission in the workplace resulting in large
numbers of affected personnel with disruption to business continuity.
7.
Risk mitigation in the workplace has been achieved through a mix of individual
protective measures and workplace structure and function measures.
8.
Individual protective measures have included; mask wearing, physical distancing,
staying away from the workplace when unwell, keeping vulnerable people out of the
workplace when exposure risk is increased and a requirement for vaccinated status for all
personnel in the workplace. The benefits of vaccination are supported by Ministry of Health
(MoH) promulgated evidence that COVID-19 vaccines significantly reduce the likelihood of
poor health outcomes if infected with COVID-19 and that vaccinated personnel are less likely
to contract and transmit COVID-19.
9.
After an initial primary course of COVID-19 vaccination, international evidence shows a
waning of immunity from vaccination and booster doses have been recommended to bring
that immune response back up. NZDF has since required uniformed personnel to have a
booster dose of COVID-19 vaccine under baseline vaccination requirements to ensure they
have optimal immunity, particularly during the expected surge of community COVID-19
transmission due to new variants.
Health assessment for vaccination requirement for uniformed personnel in an NZDF
workplace
10. The rational for including COVID-19 vaccination as a baseline vaccination requirement
for uniformed personnel includes consideration of the following key factors;
a.
Imposed national and international vaccine mandates. NZ currently has a
vaccination order in place that relates specifically to border and health workforce1.
Any NZDF person who is deemed an affected worker under these mandates is
required to meet these mandated orders. NZDF has a rotating workforce that
supports both international borders and MIQF. Due to the rotational nature
(sometimes at very short notice) of uniformed staff supporting MIQF, a wide
number of uniformed personnel have been required to be vaccinated in preparation
for being placed in these working environments.
b. Many countries have vaccine status border entry criteria, most of those now include
three doses of vaccine. NZDF uniformed personnel are often required to travel or
deploy, sometimes at short notice, and sometimes with unpredictable itineraries, to
international destinations. Due to these restrictions uniformed personnel who are
1 COVID-19 Public Health Response (Vaccinations) Order 2021
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not vaccinated are not able to be deployed offshore to meet NZDF international
output requirements.
c. Due to the staged intervals of the primary course and boosters and the period to
develop immune response post vaccine, these vaccinations can not be applied just
before duty periods or notification of duty periods but must be in place as part of
readiness requirements for uniformed personnel and are in policy for baseline
rather than enhanced vaccine schedule for this reason.
d.
Personal protection. There is significant available clinical evidence that COVID-19
vaccinations reduce the risk of serious illness or poor health outcomes if a person is
infected with COVID-19. Recent evidence still shows that vaccination protects
against severe illness and hospitalisation inclusive of the Omicron variant. NZDF
personnel can be deployed into austere locations where access to health support is
limited and consequence of severe illness can not be optimally managed.
Additionally intent of many military health protective measures is to do all that we
can to reduce the consequence of severe health outcomes in our personnel, given
the type of environments they may be required to operate in, as a component of
our duty of care, and as a component of maintaining force strength through
maximum number of fit and health personnel able to conduct their duties.
e. Some trades in NZDF do have direct and immediate employment consequence that
can be sustained post COVID-19 infection. Occupational divers are an example of
this, where diving with active infection can prove unsafe in an underwater setting. A
Worksafe recommended stand down applies for infected personnel, and the degree
of their symptomology dictates further stand down and health examination
requirements to ensure they return to full fitness to safely dive. It is notable that
this recommendation has been updated since the availability of vaccinations, as pre
vaccination, likelihood of significant health effects for divers were realised
internationally related to more severe illness. Now with vaccines reducing symptom
severity, the likelihood of reduced consequence of COVID-19 infection on trade
divers is reduced if their course of illness is mild.
f.
Reduced chance of onward transmission. Given the close working and living
environments for uniformed personnel, including barracked accommodation and
maritime platforms, short term and longer termed confined living conditions,
infectious diseases can spread rapidly and render large numbers of people unwell or
isolating (mandatory isolation periods apply for COVID-19 positive personnel and
high risk contacts, as a required response to testing positive for a notifiable
disease). There is evidence that COVID-19 vaccinations do interrupt transmission
through both vaccinated personnel being at a reduced likelihood of contracting
COVID-19, but also due to the lower likelihood of symptomology of the respiratory
illness. Infected persons with low or no symptoms are less likely to exhale and
spread droplets of infectious viral particulates, hence interrupting transmission risk
in confined settings, particularly when isolation can not be achieved.
g. Reduced onward transmission risk, means less NZDF workforce affected and this
assists in maintaining critical capabilities that often don’t have a redundancy in skill
or workforce number to replace them if they are isolating due to exposure or
illness.
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Health assessment for vaccination requirement for civilian personnel in an NZDF
workplace
11. The rational for including COVID-19 vaccination as a recommendation for civilian
personnel in the workplace includes consideration of the following factors;
12.
Imposed national and international vaccine mandates. Any civilian personnel who are
designated as affected personnel under the current vaccine orders for health and disability
sector and border workers are required to comply with those orders. Any civilian personnel
required to travel overseas in the course of their duties will also need to meet international
border requirements for vaccine status.
13.
Personal protection. Given the evidence that supports improved health outcomes for
fully vaccinated personnel, if NZDF assesses a significant COVID-19 exposure risk in the
workplace then it would seem negligent to place a person who has a higher likelihood of
severe illness in that exposed workplace. Protecting vulnerable personnel from exposure has
been a consistent component of both NZDF and national COVID-19 strategy. It is not possible
to quantify the degree of vulnerability of a single risk factor (such as being unvaccinated),
but the international evidence remains strong that unvaccinated persons are more likely
than vaccinated persons to have severe illness and be hospitalised.
14.
Reduced chance of onward transmission. Under the workplace force health
protection measures infected NZDF civilians who are symptomatic, should not enter a
workplace until cleared that they are COVID-19 negative (over several test days, depending
on their exposure risk), or until they have completed their isolation period as a positive case
and have been cleared to return to work. As civilians don’t usually cohabitate in household
like settings with uniformed personnel, onward transmission can be less of a factor in a
health assessment. However, for any civilian appointments who do cohabitate through the
nature of any duties that require them to be in close confines with other NZDF personnel,
there is an increased transmission risk directly through their unvaccinated status as a vector
to contract and pass infection to others, or increase symptomology with illness that can’t be
isolated early due to the nature of the living/working environment.
15.
Capability disruption. In some NZDF workplaces the absence of very few people or the
collective capability they deliver can result in secondary risks to the organisation and to
individuals. As an example a single unvaccinated health worker may be more likely to
contract COVID-19 and be more symptomatic and off work for longer than the 10 days of an
asymptomatic case. Effective health response is then unable to be achieved and harm may
result from the absence of that service to our personnel. Similar examples may exist in areas
such as platform maintenance, essential services that support NZDF personnel and specialist
skills across the organisation.
Current exposure risk
16. Overlaid on the personal and collective workplace impact factors outline above is the
assessed likelihood of COVID-19 hazard in the workplace. As with any workplace hazard the
likelihood and consequence of its presence must be considered in order to determine the
level of required control measures.
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17. As at 03 March, NZ is at the start of what is predicted to be a significant surge in
COVID-19 infections in the community. NZ currently leads the OECD world in daily increasing
case numbers per capita. 20-30,000 cases per day are being identified but national positive
testing rates of >30% indicate that the presence of illness is likely higher than reported
cases.
18. It is estimated that in some regions such as Auckland up to 1 in 5 people may have
COVID-19. The most common infected age group remains in the <30 age due to exposure
risk behaviours. This matches much of NZDF demographic and provides cause for targeted
measures to ensure we reduce the likelihood of NZDF personnel contracting COVID-19 in
those age groups.
19. Since 15 Feb NZDF has had rapidly increasing case rates in its personnel. Impact of
these cases is mostly reduced by workplace force health protection measures and rapid
internal public health response to positive cases detected in the workplace.
20. NZDF workplaces currently have 100% vaccinated personnel attending workplaces
including visitors to those defence areas. Most infected personnel who do inadvertently end
up in the workplace have low symptomology and are not shedding much virus due to that
low symptomology, combined with the workplace force health protection measures we are
seeing low rates of workplace transmission.
21. We have had a significant base outbreak in the Auckland region, perpetuated through
household like living conditions of uniformed employees, however this has been contained
in spread and no personnel have been seriously unwell in the 100% vaccinated positive
cases. Several ships have also have positive cases on board, again with no seriously unwell
cases in the 100% vaccinated embarked force.
22. It is assessed that the national case rate of COVID-19 will continue to exponentially
increase over the next 4-6 weeks and that the likelihood of exposures in the workplace will
increase despite workplace force health protection measures. Consequence of those
exposures to individuals in the workplace is significantly reduced by the lower likelihood of
severe illness if an individual does contract COVID-19. It is also assessed that optimal
disruption of onward transmission through high vaccination rates in the workplace will
reduce likelihood of significant impact from high case rates across workplace personnel and
outputs.
Unvaccinated personnel in NZDF Defence Areas or workplaces.
23. An unvaccinated person compared to a vaccinated person when exposed to COVID-19
is more likely to; contract infection, transmit infection and become seriously unwell from
that infection.
24. The personal, workplace and workplace continuity consequence of an unvaccinated
person being in an NZDF workplace therefore depends on the likelihood of exposure in the
workplace and the impact of that exposure due to the nature of their working environment,
and their specific trade and duties.
25. Suggestions of testing status prior to workplace attendance for unvaccinated
personnel are currently impractical for PCR testing due to testing result delays, and
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inaccurate in terms of assurance for rapid antigen testing due to the error rate related to
sensitivity of antigen tests. Additionally, testing is a post exposure control that simply
measures if someone is infected on the day of the test but doesn’t prevent infection.
26. Overall NZDF has necessarily moved from an approach of elimination likelihood of
COVID-19 infection entering the workplace to management of impact on personnel and
workplace business continuity if it does enter the workplace.
27. It is assessed that due to this inability to eliminate the hazard, priority should be
focused on reducing individual harm from exposure and reducing workplace/activity impact
and disruption from exposures and onward transmission of cases.
Dynamic risk response
28. The requirement to mitigate the potential consequence of a hazard in the workplace
must be proportionate to the prevalence of that hazard in the workplace. NZ currently has a
significantly increased prevalence of COVID-19 hazard in the community and the workplace.
29. The potential impact of COVID-19 entering the workplace from a community acquired
infection arguably remains significant regardless of the likelihood. In an NZDF workplace
context as we have already experienced, a very large number of people can be impacted by
a single exposure. The consequence of this can vary by which outputs or components of
outputs are effected.
30. An approach to determining a proportionate response to the likelihood and impact of
COVID-19 exposure in each workplace should consider;
a.
Likelihood of exposure variations by region and community prevalence of the
disease
b.
Likelihood of exposure variations by task and by workforce composition (e.g.
mixed border worker, returning uniformed duty travel, regional movement,
COVID-19 related support duties)
c.
Impact variations by critical outputs or critical enabling services with minimal
redundancy e.g. air maintainers contributing to safe platform response, mess
staff feeding large numbers of people on camps/bases, support to base isolation
and accommodation facilities, health staff.
31.
Application of obligations under HSWA IAW ref A, extends to spaces under shared
occupancy with temporary or permanent non NZDF personnel. If their individual risk of
being a vector for COVID-19 may impact NZDF employees or our outputs, or being exposed
to COVID-19 in an NZDF workplace may result in a severe health outcome because of a lack
of all available personal protective measures including vaccine protection, the health
assessment considerations outlined in this document should be applied. Communication and
engagement with agencies and providers operating in Defence Areas must occur to ensure
they comply with NZDF risk management requirements.
32.
It should be noted that this health assessment is being written in response to the
current situation in NZ and globally. Initial assessments and advice were made based on the
situation and available evidence at that time, but as risk in the COVID-19 setting is dynamic it
should be considered that health assessment and health and safety assessments should also
be dynamic in response to evolving situations.
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Conclusion
33. It is currently assessed that:
a.
The likelihood of the hazard of COVID-19 being present in the workplace has
significantly increased in the last few weeks. Auckland remains the highest
community exposure threat however with the absence of any regional borders to
contain cases, it is assessed that all Defence Areas face a likelihood of COVID-19
in the workplace at a minimum of ‘likely’, with the Auckland region at ‘almost
certain’. This is a dynamic assessment of exposures but there are no indications
of this improving in the near future.
b.
The health assessment to inform individual workplace risk assessments is not
based on a single factor, and should take into consideration impact factors
relating to; affected workers under existing national and international mandates,
personal protection, health threat to others in the workplace and threat to NZDF
capability disruption through extended staff illness and onward transmission risk.
c.
Organisational risk tolerance in relation to these combined areas of impact
should determine policy and process settings for unvaccinated personnel
physically entering NZDF workplaces or activities.
CM TATE
LTCOL
Chief Medical Officer
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