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9(2)(a)
Item 1a
SLT Weekly
Cover sheet for agenda item 2
Meeting date:
14 December 2021
Lead SLT member
Ginny Baddeley, DDG People
(approved paper)
Prepared by:
Harry Maher, Director Health & Safety
COVID-19 Vaccination Policy – Staff, Contractors, Visiting
Subject:
Public and Volunteers
Paper type
Decision required
Purpose of paper
To recommend approval of the COVID-19 Vaccination
Policy subsequent to consultation with our people.
SPA
Ginny Baddeley, DDG People
Recommendations To agree to the proposed final policy and release the
from this paper
decision and related papers reflecting the consultation
feedback and changes made.
Financial
There are no financial implications, but the mandate and
implications
COVID-19 infections may have significant effects on the
business.
Who has been
All DOC employees were given the opportunity to provide
actively engaged
feedback on the approach through a consultation process.
Released under the Official Information Act
in preparing this
Concurrent discussions also took place with respective
paper
Jobs for Nature and Volunteering teams to advise on
matters relevant to their work.
Persons attending
Harry Maher, Director Health & Safety
item
Time required
DOC-6873798
SLT Weekly
Report for agenda item 2
We recommend that SLT:
Paragraph
reference
(a)
Agree the proposed Final Policy on the vaccine mandate.
Policy is
attached
(b) Agree to release this paper and the attachments when the
43
decision is announced.
Executive summary
1. A draft Risk Assessment and Vaccination Policy was released for consultation on
29 November. 959 submissions were received and have now been considered.
2. 76% of the submitters agreed with the introduction of a vaccination mandate, and
77% agreed with the proposed policy
3. A number of changes have been made to the draft Policy in response to those
submissions. Those affect details of the Policy, but it is still proposed to introduce
a vaccine mandate in the same timeframe – i.e. coming into effect on 1 February
2022. There was strong support for a mandate to keep staff safe, but widespread
concerns about the effect that would have on individual staff and the business.
4. The policy would not apply to Jobs for Nature partner organisations, or most
volunteer groups. This applies where there is effectively no physical contact with
Released under the Official Information Act
those groups. It would apply to anyone working in DOC workplaces where there
is a risk of transmission (i.e. within buildings, compounds, etc).
5. The proposed final Policy is attached for consideration. If you approve the Policy,
it is recommended that you release the new Policy, this paper and the summary
of submissions to our people.
6. An accompanying paper seeks your consideration of a proposed implementation
process. This is designed to implement the proposed final Policy, taking into
account the implementation issues raised in submissions.
7. The risk assessment is a living document that will be updated as new information
becomes available.
Context / background
8. First and foremost, as a PCBU1, DOC has a primary duty of care under the Health
& Safety at Work Act 2015 (HSWA)2 to ensure , so far as is reasonably practicable,
1 PCBU is defined in HSWA as a ‘person conducting a business or undertaking, whether alone or with
others.’
2 Section 36(1) HSWA
DOC-6873798
SLT Weekly
Report for agenda item 2
the health and safety of workers3 who work for DOC while they’re at work and
workers whose activities in carrying out work are influenced or directed by DOC,
while the workers are carrying out that work.4 In many cases, DOC also has
overlapping duties with suppliers, contractors and other PCBUs with whom we
work, including casual volunteers.
9. DOC must further ensure that there is a safe work environment, and that the health
of workers and their working conditions are monitored as to prevent illness or
injury5. In the context of COVID-19, this requires DOC to take reasonable steps to
maintain a safe workplace i.e. one that meets health and safety requirements to
prevent the risk of infection and transmission of COVID-19.
10. HSWA sets out the health and safety duties of workers6 which includes taking
reasonable care for their own health and safety, and to take reasonable care that
their acts or omissions do not adversely affect the health and safety of others. They
are also required to cooperate with any reasonable health and safety policy or
procedure that DOC notifies to its workers.
11. DOC is required to consult with its workers on health and safety matters.7 It is
required to eliminate risks to health and safety, so far as is reasonably practicable.
12. A comprehensive risk assessment in relation to COVID-19 has been undertaken
to support the development of a Vaccine Policy, This took into account health and
safety measures already in place, including use of masks, physical distancing, and
ensuring sick workers do not enter the workplace. In light of recent government
decisions to change the way COVID-19 is managed in the community, an
assessment of the value that would be added by a vaccination mandate was
undertaken. This concluded that a vaccination mandate would significantly improve
Released under the Official Information Act
health and safety outcomes.
13. The PSA were involved in the work and agreed that the analysis was appropriate
and in line with the approach in other agencies, and that the result of that technical
work warranted consulting staff on the introduction of a vaccine mandate. We also
worked with the Government Health & Safety Lead and the Public Service
Commission and referenced Ministry of Health advice.
14. The draft policy proposed a broad vaccination mandate across the DOC workforce,
including contractors, and members of the public visiting our workplaces including
premises and volunteers who work with us.
15. On 23 November 2021, SLT endorsed a paper proposing a consultation,
confirmation and initial implementation process up to 1 February 2022.
3 Includes employees and volunteer workers
4 DOC must also ensure that the health and safety of other people is not put at risk by work carried
out as part of the conduct of its business (s36(2) HSWA)
5 Section 36(3) HSWA
6 Section 45 HSWA. Employees also have the general duty of good faith as prescribed in the
Employment Relations Act 2000. (ERA2000)
7 Sections 58, 59 HSWA
DOC-6873798
SLT Weekly
Report for agenda item 2
16. To initiate this process, the risk assessment and draft policy were released for
consultation on 29 November 2021. Submissions closed 7 December 2021.
Analysis of submissions has now been completed, and I have worked with the PSA
representative in determining appropriate responses to the matters raised by staff.
Summary of staff submissions on the draft vaccination policy
17. Attached is the analysis of submissions.
Key changes to the draft vaccination policy proposed in response to
submissions
Risk assessment
18. The assessment will be amended in relation to the following matters. It will be
treated as a living document that will be updated as the COVID-19 situation
evolves.
19. Many submissions noted that the COVID situation is constantly changing and
wished to have the risk assessment updated when there were significant shifts in
context. A new section has been added to the draft Policy to require that the risk
review be reconsidered if there are context changes and regularly if the situation
remains unchanged, with the first scheduled review by 31 May 2022.
20. Submissions raised questions regarding the wellbeing effects of introducing a
vaccine mandate. The risk analysis has not been amended to explicitly
incorporate this, but minimising those effects is a key role of the implementation
policy and is best considered on a case-by-case basis for individual members
and teams, particularly given that other submissions raised concerns about the
effect on their wellbeing of being potentially exposed to infection.
Released under the Official Information Act
21. It was clear from the submissions that the risk assessment was not easily
understood by many. As the risk assessment is to be periodically adjusted, it
would be desirable to develop an updated version that is more accessible. That
has not yet been done, as work has been focusing on implementation planning.
Vaccine mandate as a response to the risk assessment
22. Submissions fell into three groups. A small number opposed a vaccine mandate
because of concerns about vaccination. The majority supported a mandate,
although often noting negative effects if it resulted in staff leaving DOC. The
remaining submissions were concerned about the negative effects of a mandate
and felt that high vaccination rates and risk reduction should be achieved in other
ways.
23. The arguments in the submissions for alternative ways to achieve a sufficient level
of safety have been reviewed, and the H&S team are still satisfied that a vaccine
mandate is the best approach. Many of the measures put forward in submissions
are already in place. Others could be applied in individual cases. For example, the
mandate does not prevent agreement to an unvaccinated worker working from
home instead of being vaccinated, for example if they are completing a fixed term
contract or have a medical reason to defer vaccination.
DOC-6873798
SLT Weekly
Report for agenda item 2
24. A mandate is, however, necessary to allow managers to ensure that they know the
risk that a worker poses and/or faces as a result of their vaccination status, and to
work through possible alternative approaches for individuals who cannot comply
with the mandate. A mandate and associated measures will also provide all
workers with greater assurance of their level of risk. There is strong workplace
support for this approach with just under 80% of those who provided feedback as
part of the consultation process expressing support.
25. Viable alternatives to vaccination (e.g. deployment of widespread antigen testing)
may develop over time, as some submissions argued, but the international
experience suggests that this is not likely in the near future, and action needs to
be taken now to address a significant risk to staff. Consideration must be given as
to how any exceptions, along with the associated assurances and controls, could
be effectively managed in individual cases (by managers) in a large, diverse and
distributed workforce.
26. It is therefore recommended that SLT endorse the proposal to have a vaccination
mandate in place.
27. It is not proposed to require that DOC staff only visit and work within premises that
have a vaccination mandate in place. While many of the places DOC staff enter do
(e.g. councils, schools, universities), many cannot (e.g. supermarkets). The issue
of the risk of encountering COVID-19 if working outside a DOC premise will need
to be handled through Job Safety Assessment (JSA) processes, alongside other
risks. Clearly, we can only mandate to those areas that we have direct control over
as part of people and workplaces.
Implementation
Released under the Official Information Act
28. Critical to the success of any implementation is how we support our people and
leaders – at both an individual and team level. Wellbeing and the associated
support for our people leaders must underpin our approach.
29. Many submissions raised a range of significant concerns about implementation
matters – particularly around how unvaccinated staff would be treated and effects
of the mandate on workloads. Many submissions assumed that there would be a
blanket “no-jab no-job” approach, which was not intended by the draft policy. This
has been addressed in the proposed Policy.
30. The risk assessment will be adjusted to more clearly signal the extent of reduction
in risk that we are seeking to achieve. That will provide managers with better
guidance as they work through arrangements for unvaccinated individuals.
31. You have been provided with a separate paper on implementation, but the
following is a summary of how the proposals in that paper would address concerns
in submissions.
• All cases where a person cannot or will not comply with the mandate will be
centrally managed by the Human Resource Team as primary lead. This will
assure consistency in approach and application of the proposed Policy and
confidentiality of any health or other declared concerns.
DOC-6873798
SLT Weekly
Report for agenda item 2
• Each person who cannot or will not comply with the mandate will be treated
on a case-by-case basis. There will be no presumption that they would need
to leave their job, but there would be a requirement that the H&S objectives
and the business needs are both met by any agreement. Where there is a
temporary arrangement until vaccination occurs (e.g. where vaccination is
being deferred for a medical reason), the agreement will need to clearly
signal the deadline for that occurring and implications if vaccination does
not occur by the determined deadline, to avoid having short term
arrangements drift into ongoing situations.
• The implementation process will take into account the potential for both the
vaccine mandate and COVID-19 infections/self isolation to create workload
issues. It is proposed that there be clear guidance that where necessary
work will be reduced to fit the available resources, with good prioritising to
ensure that critical work continues.
• HR and the PSA will work together to pick up and address incidents of
conflict, harassment, and other behavioural issues arising as a result of staff
having different attitudes to vaccination and the mandate. A number of
submissions reported that this is already a problem in some workplaces.
• Staff safety will need to be a priority in relation to enforcing the mandate for
visitors, particularly in isolated locations or when staff are working alone.
Safe operating procedures will be developed and training provided to
affected staff.
Collecting vaccine information
DRAFT
32. There were a range of issues raised in submissions, including issues relating to
Released under the Official Information Act
privacy and the logistics of checking vaccine certificates. The section in the Policy
has been re-named “Collection, Use and Storage”, not “Collection and Storage”.
33. In general, there is no need to collect data other than vaccination status. Managers
only need to verify their staffs’ vaccination status (via certificate, pass or doctor’s
certificate), with a presumption that if a certificate or pass is not shown the person
is to be treated as unvaccinated. DOC generally does not need to hold any medical
information, such as details of what vaccine was taken. If there is a reason to hold
information, then that would be done in accordance with the Health Information
Privacy Code 2020. Reference to that code has been added to the Policy.
34. The implementation process will include implementation of the process by which
managers report that their staff are compliant. Records of those verifications or
agreements will be maintained securely as health and safety or HR records,
subject
to
the
same
protections
as
other
similar
records
(e.g.
immigration/citizenship status, other H&S related records).
35. The Policy has been adjusted to ensure that staff covered by legislative mandates
(e.g. border workers) are not affected by this mandate, to remove any duplication
of processes for them and their managers.
Jobs for Nature
DOC-6873798
SLT Weekly
Report for agenda item 2
36. There has been further consideration of how this might affect Jobs for Nature
Project
Partners.
It
is
recommended
that
the
partners
and
their
employees/contractors not be mandated to be vaccinated but will be required to
have adequately considered Covid-19 within their Health and Safety plans. Jobs
for Nature partners and staff will be required to align with the policy in all other
ways – i.e. will require proof of vaccination to work in or visit DOC facilities.
Volunteers
37. There has been further consideration of individuals and groups undertaking
voluntary conservation activities on PCL. Where the work of a group is authorised
via a community/management agreement the vaccine mandate does not apply.
The group/organisation will decide whether to follow the vaccine pass or no vaccine
pass MOH guidelines for gatherings. We note that corporate groups are likely to
apply their corporate policies and approaches when doing corporate volunteer
activities.
38. For volunteer activities led by other organisations on behalf of the Department, e.g.
Corrections or CVNZ, it is that organisation’s responsibility to develop a safe
approach to the work, including deciding whether to follow the vaccine pass or no
vaccine pass MOH guidelines for gatherings.
39. All DOC volunteers who access DOC workplaces will require a vaccination in the
same way that other visitors do.
Comparison to other agencies
40. The approach being taken in the amended policy is similar to that for other
agencies. Vaccine mandates are becoming common in government agencies,
DRAFT
universities, and local government, and it is expected that this will become common
Released under the Official Information Act
in the private sector. That has implications for our work, as unvaccinated DOC
people will be limited in the places they can go and therefore the work they can
effectively undertake.
41. The risk assessment work drew on the work of MPI, as both Government Health
and Safety Lead and as having comparable workforce and workplace dimensions
(similar range of work locations and types of roles), and the conclusions were
similar.
42. I note that one difference between our Policy and that of the Ministry for the
Environment is that they have proposed treating unvaccinated staff who have a
medial exemption as if they were vaccinated. We do not propose to do that, as they
present the same risk profile as a person unvaccinated for other reasons.
Others actively engaged
43. We engaged the Jobs for Nature team, and the Volunteering team, for advice on
the policies relating to those situations.
Next steps
44. For an implementation plan to be agreed (see accompanying paper)
DOC-6873798
SLT Weekly
Report for agenda item 2
45. You will have to announce to staff the decisions, and release this paper and its
attachments
Attachments/appendices
• Summary of submissions
• Proposed final Policy
Released under the Official Information Act
DOC-6873798
Item 1b
Analysis of submissions
A total of 959 staff members responded to the staff consultation survey. All business groups and
regions are represented in the responses.
Source: DOC
Submissions on the Risk Assessment
Almost 80% of respondents agreed with the risk assessment.
Released under the Official Information Act
What the submissions said
Not all submissions commented on the risk assessment. A number welcomed the use of the
standard risk assessment approach for this issue. One submission, however, questioned the value of
the approach, arguing that it reduced the ability to look holistically at the overall situation. Another
questioned why it did not reference the government guidance on assessments. Another questioned
why staff had not been involved in the assessment as required under H&S law.
While some commented that the assessment appeared sound, or that they supported the data used,
others questioned the data or the way the risk assessment was presented. One considered that it
should have an introductory section for staff who aren’t familiar with the methodology. Another
thought it should be simplified to match the guidance from the government. Others provided
comments that suggested that they did not understand the risk assessment methodology, or they
sought more clarity on what was the quantitative basis for an assessment such as “moderate”. One
was concerned that the risk assessment appeared to cover matters that DOC had no control over.
Another considered that it should provide an assessment of the risk of transmission in the
community for comparison with risk of transmission in the workplace as per WorkSafe guidance.
Another that it appeared to ignore the effect of existing mitigation measures such as mask wearing.
Another was concerned that the effects of higher densities of people in offices under “hot desking”
and where people are returning to the office had not been factored in.
There were questions related to how the risk assessment dealt with the evolving situation (new
variants) and the gap between the decision and the mandate coming into force. There was also
concern that it did not address the gradual loss of vaccination effectiveness and the fact that
immunity and vaccination status may not match.
One submission was concerned that the analysis appeared not to distinguish between vaccination
status and infection status. Another submission questioned whether some of the data used (e.g. the
risk of a vaccinated person being infected) was gathered from situations (e.g. health care workers
constantly exposed to disease) that wouldn’t apply in the DOC context. Another felt that the risk
varied between situations (e.g. outdoors vs indoors) and that should be factored in. Another felt that
there were scenarios, such as conservation board meetings, that weren’t covered. Another
questioned why the ESR assessments of risk to people in the community were lower than the DOC
assessment of risk in the workplace (despite there being more likelihood of contact with an infected
person outside the workplace). They also asked why, if the risk was extreme, there had been no
deaths. Another raised questions about the assessment of CITES work.
Some submissions raised the issue of vaccinated people being able to pass the virus on, and a risk
that they will be more complacent and therefore pose a higher risk than the assessment assumed.
A number of submissions were concerned that the assessment did not cover other risks. Some
submissions raised the wellbeing effects of needing to work with unvaccinated people, while others
talked about the wellbeing effects of the proposed mandate on those who did not wish to be
Released under the Official Information Act
vaccinated. One argued that the effect on a person’s health of being made unemployed would be
worse than the effect of not being vaccinated. Another that the risk to all staff of work pressures
resulting from unvaccinated staff being unable to work would be worse than the risk of COVID-19.
Some submissions referred to the risk assessment not covering the risk of adverse effects of the
vaccine. There was also mention of risks to our business (e.g. threatened species) and reputation.
Many submissions on this issue raised matters which related to the response (mandating
vaccination) rather than the risk assessment. Those are largely covered in other sections, but points
that are relevant to the risk assessment includes whether antigen testing can achieve the same level
of safety, whether unvaccinated people working together resolves the safety issues, and whether
the costs of a vaccine mandate are worthwhile if the benefits of it are short-lived (e.g. because a
new variant arrives that the vaccine doesn’t control).
Relevant Issues
The risk assessment relies on assessment of the effect that vaccination would make to both the
effects of infection and the likelihood of infection. None of the submissions provided clear and
credible evidence that the risk assessment was wrong to such an extent that the policy could not be
based on it. The issue of proportionality between the benefits of a vaccine mandate and the
negative effects on wellbeing should be reviewed, taking into account comments on how to manage
staff who are not vaccinated.
The risk assessment was not easily understood by all, and is likely to need to be periodically
reviewed. It would therefore be useful to review how it is presented, including to more clearly
address:
• What it is for and how the basic methodology works.
• How long does the science suggest that a vaccination approach will be effective in reducing
risk of serious disease (assuming booster shots, changes in variants, rates of new vaccine
development, etc).
• The individual elements of the risk assessment – likelihood of being infected, likelihood of
infecting others, likelihood of having severe illness – given that these elements and their
relative significance seem not to have come across clearly.
• The relationship between this assessment and the mitigation provided by existing measures
(masks, etc).
• Provide some clarity on how the standard risk assessment process works for those who are
not familiar with the methodology.
Given the comments in submissions on the evolving disease, changing societal context (e.g.
proportion of people who are vaccinated, proportion of the population who are probably infected),
and changing vaccine information, it would be appropriate to include an explicit section in the policy
on regular review or triggers for review.
The risk assessment should be adjusted to include specific consideration of the relative risks of
vaccine side effects, and to address risks to wellbeing of COVID-19 and the proposed response (e.g.
in relation to workloads, effects on unvaccinated individuals, workplace tensions).
Submissions related to whether a vaccine mandate is a reasonable response
to the risk assessment
Released under the Official Information Act
More than three-quarters of respondents agree with the introduction of a vaccine mandate.
The following chart provides a breakdown of reasons for the staff who do not support the vaccine
mandate.
Why staff disagree with vaccine mandate
Of the ‘other’ responses (17%), approximately half objected to the vaccine mandate on principle
(e.g. consider it a breach of human rights). A number of these respondents stated that they are fully
vaccinated themselves.
Consistent with the numbers of staff supporting the introduction of a vaccine mandate, nearly 77%
of staff agree with DOC’s proposed policy.
Released under the Official Information Act
What the submissions said
There was no consensus on this issue, with views across the spectrum. Some strongly supported this
as the logical and necessary response to the risk. A few went further and argued that the proposed
introduction was too slow, and there were those who considered that lack of a vaccination mandate
was having a negative effect on their wellbeing. At the other end of the spectrum were those who
felt it would not be effective, because they did not consider the vaccine mandate would lower risk
(e.g. because vaccinated people would spread disease), or because they did not consider that the
vaccine was effective and/or safe.
In between were those who felt it was disproportionate because a high level of vaccination would be
achieved without a mandate and there were other ways to address infection risk (e.g. working from
home, antigen testing), and/or were concerned about the negative effects of a mandate, such as
creating social divisions. Comments related to alternative ways to manage the risk often covered
similar points to comments on implementation – how could unvaccinated staff be managed in a fair
way, preferably still working for DOC. A number of submissions raised concerns about the effect the
mandate could have on the work, customers and the business. Some cited principles, such as their
belief that forcing people to be vaccinated was a breach of their rights. Others were concerned that
the strength of the data for improved safety was not good enough to justify the serious impacts of
introducing a mandate.
Relevant issues
The arguments on rights are being addressed in the courts. It may be appropriate to have a section
in the policy that required review if the legal context changes or there is new direction from PSC.
The issues raised by most of the submissions that covered this point will need to be addressed in
implementation design, particularly how alternative work arrangements, antigen testing, and other
measures would be used to manage staff who did not wish to be or could not be vaccinated.
Submissions appeared to have assumed that staff who were not vaccinated would need to exit the
business or not work. Any measures that can reduce that risk would address the concerns of some
submitters.
The comments suggested that submitters who opposed the mandate often considered that the main
reason for it was to protect vaccinated staff from infection. It is important that the policy clearly
identifies the fact that the risk assessment also considered the risk of severe disease if an
unvaccinated person is infected at work. The H&S team need to provide clear guidance to SLT on the
extent of their responsibility to protect staff if those staff do not wish to take the measure that
would best protect them.
What measures should be taken instead of a vaccine mandate
What the submissions said
Some submissions felt that the mandate should be set by the PSC. Some were concerned that the
vaccine mandate would lower overall vaccination in NZ and therefore increase risk.
Released under the Official Information Act
Some suggested that the vaccine mandate be limited to high-risk sites, such as where there is
contact with the public and enclosed premises, or be applied on a case-by-case basis rather than
through a blanket mandate. Others that it only apply to new staff, not existing employees.
Alternatives to compulsory vaccination were offered, including:
• Regular testing
• Testing for antibodies that show a person has had the virus and therefore is the same risk as
a vaccinated person
• Incentives, information provision, etc to persuade people to be vaccinated.
• Good hygiene arrangements
• Teams developing approaches to maintaining safety
• Encouraging people to maintain their general health so they are at lower risk of the virus
• Use of unpaid leave to give people time to consider the issue further
• Improved air conditioning and building cleaning
• Providing staff with spaces where they can work away from other staff
• Ensure PPE is being used
Relevant issues
Many submissions called for a blanket requirement to be vaccinated to, in effect, be changed to a
requirement to show how the necessary H&S risk reduction could be achieved. That might include
through behaviour of the unvaccinated individual, their teams, or the Department generally. That
needs to be further assessed, either as an explanation of what the case-by-case response means or
as a possible alternative approach to the mandate policy.
The issues identified all need to be addressed in policy, including building ventilation, masking,
staying home when sick. The advice should clearly show where that is provided for in other policies.
The advice should also address the measures to be taken to continue to encourage vaccination.
Submissions related to collection of vaccine data
What the submissions said
Concerns were raised about how data privacy would be ensured, including concerns about the
current email system for voluntarily collecting data. There were also queries about how the system
would cope over time, including collecting booster information. One submission questioned the
legality of requiring personal medical information. Another suggested that at 1 February everyone
would know the vaccination status of the staff who were still in the office. Another asked for good
communication of the reason for collection of the information.
Questions were raised about what would be acceptable evidence to be provided to the
manager/supervisor and how providing that would fit with the promise to have data kept secure.
One suggestion was that managers use the scanning app to verify certificates.
There was a specific question as to whether staff whose vaccination records are managed within he
border system would need to also provide data to the DOC system.
There were also questions about whether volunteers, contractors and visitors would have to be
vaccinated and how that would be verified. Potential effects on iwi relationships of needing to sight
Released under the Official Information Act
certificates was mentioned.
Relevant issues
The implementation work will need to address what form the information to be collected is, for staff
and others affected by a mandate, particularly whether anything other than sighting a certificate is
required. It will also need to clarify who can seek and see the data for an individual.
The Policy needs to address the issue of staff affected by legislative mandates, to remove any
duplication.
The Policy should be checked to ensure it is clear about what information is being collected and why,
and how personal information will be handled. That would include information on why someone is
unable to be vaccinated, whether people are vaccinated, and reasons for allowing an unvaccinated
person to continue to work.
Submissions relating to management of staff who are not vaccinated, and
general measures applying to all staff
What the submissions said
The general tenor of most submissions that touched on the issue was that staff who cannot or do
not wish to be vaccinated should be treated fairly and preferably kept as employees. Some
submissions raised the need for consistent treatment of these staff, guidance to managers to ensure
that, and for consistency across the public service. There was concern from some that treating
unvaccinated staff differently was unfair generally, or contrary to DOC’s diversity policy, or would
push the vaccine hesitant into refusing to take the vaccine.
Some submissions argued that the issue of non-vaccination may be temporary in some or all cases,
for example where staff are waiting an alternative vaccine, or because the submitter believed the
need for vaccination would change. They did not want actions to be taken rapidly to end someone’s
employment given that.
Some submissions identified the fact that the necessary conversations with unvaccinated staff were
likely to be difficult. Others were concerned about existing and future divisions within offices and
exclusion of unvaccinated staff, and poor behaviour by the vaccinated.
Views were varied in what would be an appropriate response to unvaccinated people. Some felt that
they should not be allowed into offices, while others felt that if they tested negative they should be
able to work in offices. Submissions also varied in whether all unvaccinated staff should be treated
the same (in some cases this was linked to people having a right to choose), or whether those who
have a medical exemption should receive different treatment. Many read the policy as implying that
termination of employment was inevitable, and some questioned why working from home or doing
work with other measures was not a viable response.
The effect on the business and other staff of standing down staff (e.g. hut wardens), and the need to
recruit replacements, was mentioned in some submissions.
Relevant issues
The Policy intended the treatment of unvaccinated staff to be determined on a case by case basis,
Released under the Official Information Act
with termination of employment only if safety could not be managed. But many submitters read
termination as inevitable. The Policy needs to send an accurate signal to staff and managers of the
intent. If possible, the Policy should clearly signal the extent of reduction in risk to the worker, and
risk to their colleagues, that the manager needs to achieve. It should also ideally indicate the extent
to which the work could be compromised in order to retain the employee (e.g. additional costs,
lower productivity, lower team cohesiveness). This is similar to the situation for staff who have been
moved onto light duties.
Implementation processes will need to address the points raised around consistency and fairness.
The Policy will need to contain a process for dealing with situations where the staff person considers
that the process is not fair, or wishes to have their issue dealt with by another person (e.g a one-up
manager).
The advice will need to clearly address the issue of whether vaccination is likely to be an essential
long-term measure or (as some submitters believed) only a short term response given the way
COVID-19 is likely to behave, the development of rapid testing, and other factors. For individuals, the
likelihood of them being vaccinated in the near future (e.g. if a new vaccine becomes available or the
situation that makes them reluctant to be vaccinated changes) will need to be taken into account
determining short term responses, and guidance will be needed to managers on that.
Other matters
What the submissions said
There were a number of comments, primarily related to how implementation of any final policy
would be handled to reduce stresses on staff and unnecessary conflicts with communities. That
included questions around
Implementation matters
• how visitors to premises would be managed,
• how contractors and visitors would be advised of the new policy,
• how children who can’t be vaccinated would be handled,
• how “premises” would be defined (e.g. whether field sites would be affected),
• are vehicles “premises” and can they be used by other parties who aren’t vaccinated
(volunteers),
• ensuring that the treatment of staff in relation to working from home is consistent with the
working from home policy,
• what arrangements would be in place where staff are to be terminated (period of notice
with pay),
• how realistic the 18 January date is (if staff delay being vaccinated until they know the final
mandate decision)
• risks associated with enforcement of hut and related rules, particularly where staff handling
the situation are working alone in isolation, and need for training in compliance for staff
required to check vaccination status of visitors,
• management of people who spread misinformation or who harass other staff in relation to
their vaccination status,
• managing the flow-on effects of implementation on staff, communities, community
reactions,
Released under the Official Information Act
• how communication is managed to ensure staff get good information in a safe environment,
H&S issues not related to vaccination mandate
• managing H&S implications of long covid (e.g. for driving safety),
• how do we manage entry into workplaces without a mandate,
Biodiversity
• how to protect bats from COVID transmitted from people,
Future review issues
• how (in the longer term) natural immunity as a result of infection will be treated,
Scope question
• whether the mandate should be imposed on JFN partners,
• what services should we do regardless of whether people are vaccinated (essential public
services).
Relevant issues
The H&S and HR teams need to ensure that all the issues related to implementation and H&S are
adequately addressed in implementation and related processes.
The SLT decision needs to address the scope issues.
The Biodiversity DDG needs to address the issue about disease transmission to other species.
Released under the Official Information Act
Item 1c
DOCCM-6873027
DOC risk assessment – transmission of COVID-19 in the workplace
Assumption highly transmissible variant and community transmission
This risk assessment (Appendices 1 and 2) assume community transmission occurs
throughout New Zealand Aotearoa. The basis for treating border tasks as higher risk work
(due to contact with incoming international passengers, crew, airport staff and other
government agencies) remains valid when COVID-19 is still prevalent in many countries and
any new variants would be likely to affect border workers first.
The risk assessment is undertaken on two bases:
• The risk of a DOC worker infected with COVID-19 transmitting COVID-19 to others during
work activities.
• The risk of a DOC worker becoming infected with COVID-19 at work.
We have identified work tasks that involve contact with others, the most credible worst-case
scenario associated with the risk of infection with COVID-19, and the likelihood of transmitted
infection occurring and it leading to that consequence.
We have assessed inherent risk, residual risk with current controls, and what having all DOC
staff vaccinated who work in that area would do to the risk rating.
Impact of Vaccination
Vaccination of DOC workers has the following impact:
• It reduces the likelihood of DOC workers transmitting COVID-19 at work from Almost-
certain/Likely down to Possible
Released under the Official Information Act
• It reduces the likelihood of DOC workers being infected with COVID-19 from Almost-
certain/Likely down to Possible
• It reduces the consequence of DOC workers being infected with COVID-19 at work from
Severe down to Moderate
Residual risk assessment – DOC vaccination
The residual consequence and residual risk ratings are presented as dual ratings for both
vaccinated and non-vaccinated persons. This is because DOC workers during the course of
their work may come into contact with other persons who are not vaccinated.
We have assessed the residual risk of a DOC worker positive for COVID-19 Delta variant
passing this infection onto others at work is:
• Extreme for an unvaccinated DOC worker transmitting infection during work to an
unvaccinated person
• High for an unvaccinated DOC worker transmitting infection during work to a vaccinated
person
• High for a vaccinated DOC worker transmitting infection during work to an unvaccinated
person
• Medium for a vaccinated DOC worker transmitting infection during work to a vaccinated
person.
1
DOCCM-6873027
We have assessed the residual risk of a DOC worker being infected by the COVID-19 Delta
variant at work is:
• Extreme for an unvaccinated DOC worker being infected during work by an
unvaccinated person
• High for a vaccinated DOC worker being infected during work by an unvaccinated
person
• High for an unvaccinated DOC worker being infected during work by a vaccinated
person
• Medium for a vaccinated DOC worker being infected during work by a vaccinated
person.
Unvax
to
Unvax
Vax to
DOC
Unvax
Unvax
to
DOC
vax
Released under the Official Information Act Vax
to
Vax
Where we identified a residual risk rating of high or above (for current controls without
vaccination) we believe (based on WorkSafe guidance) that we need to consider the
reasonably practicable nature of mandatory vaccination for roles unless other additional
controls are reasonably practicable and would change the residual risk rating sufficiently.
Rapid antigen testing
Rapid antigen testing could further decrease the likelihood of DOC workers infected with
COVID-19 transmitting infection to others by picking up the infection early. As this is currently
being trialled in New Zealand and is not currently available to DOC, it has not been factored
into this risk assessment.
2
DOCCM-6873027
Notes and assumptions
Vaccine efficacy
Efficacy of vaccine MOH site key points:
• 90-100% efficacy across all genders, ethnicity etc
• 100% efficacy in 12-15yo
7 May science update – viral transmissions [latest update]
• 54% reduction in cases of household members of healthcare workers in Scotland
after 2 doses
• 38-49% less likely to transmit virus to household contacts after 1 dose
• 4-fold reduction in viral load after 1 dose (less infectiousness)
Immunisation Advisory Centre
• Israel’s vax programme cut documented infection by 92%
• CDC: 90% effective in healthcare workers in protecting against infection
IMAC Delta page
• Delta patients 2x more likely to be hospitalised or need emergency care than Alpha
variant (UK study)
IMAC international vax page
• 5.1 deaths/million for people with 2 doses, 47.3 deaths/million for unvaccinated (UK
numbers)
Released under the Official Information Act
Knowns
• People are infectious and asymptomatic for 48 hours after infection
• Infectious period continues until 72 hours after symptoms resolved
• Consequence is severe for all infections as potential outcome is death or severe
illness (hospitalisation and/or long Covid).
Assumptions
• Delta variant is in community and there is some detected or undetected transmission,
OR borders are open to some degree.
• Vaccination status of people we interact with is unknown.
3
Appendix 1 - Risk assessment of COVID-19 highly transmissible variants (assumption community transmission) DOCCM-6873027
LOW INFLUENCE AND CONTROL:
Non-DOC worksites and/or interactions with the public
Work activity
Persons
Frequency and
Inherent
Inherent
Inherent
Controls
Residual
Residual
Residual
Residual
Residual
Residual risk
involved
length of contact
likelihood
consequence
risk
(without vax)
likelihood
consequence
risk (with
likelihood
consequence
(with controls
with others and
(controls no
for person/s
controls &
(with DOC
for person/s
incl DOC vax)
environment
DOC vax)
infected (with
no vax)
controls &
infected
controls & no
mandatory
(with controls
DOC vax)
DOC vax)
& DOC vax)
Contact with
DOC
Very frequent, short Almost
Severe
Extreme
Barriers,
Likely
Moderate
High
Possible
Moderate
Medium
customers at non-DOC workers;
duration exposure,
certain
masks,
(vax)
(vax) DOC
sites: reception
Other PCBU
aircon
handwashing,
workers;
distancing
Severe
Extreme
Severe1
High
Public
(no-vax)
(no-vax) Others
Embedded on non-
DOC
Very frequent,
Almost
Severe
Extreme
Masks,
Almost
Moderate
High
Possible
Moderate
Medium
DOC sites eg vessels,
workers;
prolonged
certain
handwashing,
certain -
(vax)
(vax) DOC
helicopters
Other PCBU
exposure, may
distancing
Likely
r the Official Information Act
workers;
include small
Public
internal spaces
Severe
Extreme
Severe
High
(vessels/
(no-vax)
(no-vax) Others
helicopters),
physical distancing
may be difficult
Visit/attend non-DOC
DOC
Very frequent,
Almost
Severe
Extreme
Masks,
Likely
Moderate
High
Possible
Moderate
Medium
sites2 including
workers;
moderate
certain
handwashing
(vax)
(vax) DOC
outdoor areas 3
Other PCBU
exposure, indoor or
workers;
outdoor, physical
Severe
Extreme
Severe
High
Public
distancing may be
(no-vax)
(no-vax) Others
difficult
Released un
Outdoor large events,
DOC
Very frequent,
Almost
Severe
Extreme
Masks,
Likely-
Moderate
High
Possible
Moderate
Medium
e.g. Kepler Challenge
workers;
prolonged
certain
handwashing,
possible
(vax)
(vax) DOC
Other PCBU
exposure, outdoors,
distance (hard
(outdoor)
workers;
physical distancing
to maintain)
Severe
Extreme-
Severe
High
Public
may be difficult
High
(no-vax)
(no-vax) Others
Indoor large events
DOC
Very frequent,
Almost
Severe
Extreme
Masks,
Likely
Moderate
High
Possible
Moderate
Medium
where DOC is not in
workers;
prolonged
certain
handwashing,
(vax)
(vax) DOC
control e.g. in-person
Other PCBU
exposure, aircon,
distance (hard
conferences,
workers
physical distancing
to maintain)
Severe
Extreme
Severe
High
meetings, some Te
may be difficult
(no-vax)
(no-vax) Others
Pukenga Atawhai
Public meetings
DOC
Frequent, moderate Likely
Severe
Extreme
Masks,
Likely-
Moderate
High
Possible
Moderate
Medium
workers;
exposure
handwashing,
possible
(vax) DOC
(vax)
Public
distance
(speaker on
Severe
Extreme-
Severe
High
platform away
High
(no-vax) Others
from people)
(no-vax)
1 Other persons DOC workers come into contact with may not be vaccinated.
2 Includes visit/attendance at other agencies (e.g. court, tribunal)
3 Excludes the work activities undertaken by DOC workers captured by the vaccination mandates in COVID-19 Public Health Response (Vaccinations) Amendment Order (No 3) 2021 (LI 2021/325) – New Zealand Legislation (i.e. affected education services, health and disability
sector such as fire services and SAR, prisons and borders where applicable)
4
International visits and
DOC
Frequent, variable
Almost
Severe
Extreme
Masks,
Almost
Moderate
High
Possible
Moderate
Medium
postings
workers;
vaccination
certain
handwashing,
certain -
(vax)
(vax) DOC
Other PCBU
coverage,
distancing
Likely
workers,
community
Severe
Extreme
Severe
High
Public
transmission
(no-vax)
(no-vax) Others
REQUIREMENTS SET BY OTHER ORGANISATIONS AND AUTHORITIES
Work activity
Persons
Frequency and
Inherent
Inherent
Inherent
Controls
Residual
Residual
Residual
Residual
Residual
Residual risk
involved
length of contact
likelihood
consequence
risk
(without vax)
likelihood
consequence
risk (with
likelihood (with
consequence for
(with controls
with others and
(controls no
for person/s
controls &
DOC controls &
person/s
incl DOC vax)
environment
DOC vax)
infected (with
no vax)
mandatory
infected
controls & no
DOC vax)
(with controls &
DOC vax)
DOC vax)
Travel international4
DOC
Very frequent,
Almost
Severe
Extreme
Masks,
Almost
Moderate
High
Possible
Moderate
Medium
workers;
prolonged
certain
handwashing
certain
(vax)
(vax) DOC
Public
exposure,
recirculated air
Severe
Extreme
Severe
High
(no-vax)
(no-vax) Others
Travel domestic (air,
DOC
Very frequent,
Almost
Severe
Extreme
Masks,
Likely
Moderate
High
Possible
Moderate
Medium
taxi, public transport)
workers;
moderate
certain
handwashing
(vax)
(vax) DOC
Public
exposure,
recirculated air
Severe
Extreme
Severe
High
(no-vax)
(no-vax) Others
HIGH INFLUENCE AND CONTROL:
DOC and other government agency worksites
Work activity
Persons
Frequency and
Inherent
Inherent
Inherent
Controls
Residual
Residual
Residual risk
Residual
Residual
Residual risk
involved
length of contact
likelihood
consequence
risk
(without vax)
likelihood
consequence for
(with controls
likelihood (with
consequence for
(with controls
Released under the Official Information Act
with others and
(controls no
person/s
& no vax)
DOC controls &
person/s
incl DOC vax)
environment
DOC vax)
infected (with
mandatory
infected
controls & no
DOC vax)
(with controls &
DOC vax)
DOC vax)
Contact with
DOC
Very frequent, short Almost
Severe
Extreme
Barriers,
Likely
Moderate
High
Possible
Moderate
Medium
customers at DOC
workers;
duration exposure,
certain
masks,
(vax)
(vax) DOC
sites: reception/ visitor
Other PCBU
aircon
handwashing,
centres
workers;
distancing
Public
Severe
Extreme
(no-vax)
Work at a DOC office/
DOC
Very frequent,
Almost
Severe
Extreme
Masks,
Almost
Moderate
Extreme
Possible
Severe6
High
workshop in close
workers;
prolonged
certain
handwashing,
certain -
(vax)
(no-vax) Others
contact with other
Other PCBU5 exposure, aircon
distancing,
Likely
workers
workers;
reduced %
casual
workers
Severe
Extreme
Severe
High
volunteers,
onsite, work
(no-vax)
(no-vax) Others
Public
bubbles
4 Full vaccination is likely to be required for international travel
5 PCBU worker includes volunteer workers and contractors
6 Other persons that DOC workers come into contact with may not be vaccinated.
5
Visit multiple DOC
DOC
Frequent, moderate Almost
Severe
Extreme
Masks,
Likely
Moderate
High
Possible
Moderate
Medium
sites7 and work in
workers;
exposure, aircon
certain
handwashing,
(vax)
(vax) DOC
close contact with
Other PCBU
distancing,
workers at those sites
workers,
work bubbles
casual
volunteers,
Public
Severe
Extreme
Severe
High
(no-vax)
(no-vax) Others
Visit/attend outdoor
DOC
Frequent, moderate Likely
Severe
Extreme
Masks,
Likely
Moderate
High
Possible
Moderate
Medium
areas (e.g. National
workers;
exposure
handwashing,
(vax)
(vax) DOC
Parks Great Walks
Other PCBU
distancing
tracks, other tracks on
workers,
conservation land)
Public
Severe
Extreme
Severe
High
(no-vax)
(no-vax) Others
Meeting other
DOC
Frequent, moderate Likely
Severe
Extreme
Masks,
Likely-
Moderate
High
Possible
Moderate
Medium
agencies
workers;
exposure
handwashing,
possible
(vax)
(vax) DOC
Other PCBU
distancing,
workers,
digital
Severe
Extreme
Severe
High
r the Official Information Act
public
meetings
(no-vax)
(no-vax) Others
Indoor large events
DOC
Very frequent,
Almost
Severe
Extreme
Masks,
Likely
Moderate
High
Possible
Moderate
Medium
where DOC is in
workers;
prolonged
certain
handwashing,
(vax)
(vax) DOC
control (e.g. some Te
Other PCBU
exposure, aircon
distance (hard
Severe
Extreme
Severe
High
Pukenga Atawhai)
workers,
to maintain)
(no-vax)
(no-vax) Others
Public
Working from home
DOC
Living with others -
Almost
Severe
Extreme
Handwashing,
Likely -
Moderate
High
Possible
Moderate
Medium
(e.g. Flexible Work,8
workers;
Very frequent, short certain
-
distancing
possible
(vax)
(vax) DOC
during a government
Public
duration exposure,
Likely
(hard to
imposed lockdown)
aircon
maintain),
social
Severe
Extreme
Severe
High
isolation, home
Living on own –
bubble, digital
(no-vax)
(no-vax) Others
moderate exposure
Released und meetings
7 DOC sites includes DOC premises
8 Refer: http://intranet/tools-and-services/hr-and-payroll/flexible-working/
6
Appendix 2 - Risk assessment of border-related work tasks higher - risk DOC COVID-19 work DOCCM-6873027
Work activity
Persons
Frequency and
Inherent
Inherent
Inherent
Controls
Residual
Residual
Residual
Residual
Residual
Residual risk
involved
length of contact
likelihood
consequence
risk
(without vax)
likelihood
consequence
risk (with
likelihood
consequence
(with controls
with others and
(controls no
for person/s
controls &
(with DOC
for person/s
incl DOC vax)
environment
DOC vax)
infected (with
no vax)
controls &
infected
controls & no
mandatory
(with controls
DOC vax)
DOC vax)
& DOC vax)
Administration of
DOC
Frequent, moderate Likely
Severe
Extreme
Masks,
Possible
Moderate
High
Unlikely
Moderate
Medium
CITES (implemented
workers;
exposure
handwashing,
(vax) DOC
(vax)
through TIES Act) –
Other PCBU
distance
airport, inspection of
workers,
(speaker on
Severe
Extreme-
Severe
High
animal and plant
Public
platform away
High
(no-vax) Others
r the Official Information Act
species covered by
from people)
(no-vax)
CITES for
import/export, seizure
of items without CITES
permits and removal /
destruction
Released un
7
Risk matrix
Term
Definition
Severe
Actual or potential for work-related notifiable event causing fatalities or
Likelihood
Criteria
life-changing/threatening injuries, illnesses or exposures to MORE THAN
Almost
• Expected to occur multiple times within the next 12 months
ONE person; OR multiple people requiring crisis or ongoing mental health
certain
• >90% chance of occurring
care for significant exposure, e.g. PTSD. Notifiable to
WorkSafe/regulator.
Major
Actual or potential for a work-related notifiable event affecting ONE
Likely
• Could occur within the next twelve months
person, including fatality, injury, illness or exposure that causes a life-
• 61-89% chance of occurring
changing/threatening event; OR severe irreversible incapacity or health
effects, or disabling illness; OR a person receiving hospital-based crisis
Possible
• Expected to occur in the next two years
mental health treatment or ongoing mental health care for significant
•
exposure, e.g. PTSD. Notifiable to WorkSafe/regulator.
31-60% chance of occurring
Moderate
Actual or potential for work-related injury, illness or exposure (mental or
physical) requiring in-patient medical treatment with reversible
Unlikely
• Expected to occur once in the next two to five years
impairment; OR lost time injury; OR multiple medical treatment cases; OR
• 5-30% chance of occurring
a person receiving work-related crisis mental health treatment/counselling
(not admitted to hospital). May be notifiable to WorkSafe/regulator.
Minor
Actual or potential for reversible work-related injuries, illnesses or
Rare
• Expected to occur in five years or more
exposures (mental or physical) requiring first aid or outpatient medical
• <5% chance of occurring
treatment, no long-term effects, may require restricted duties.
Released under the Official Information Act
Minimal
Actual or potential for reversible work-related injuries or illnesses (mental
or physical) requiring first aid at most, no long-term effects.
DOCCM-6873027
Item 1d
DOC COVID-19 Vaccination Policy Based on community transmission
Purpose
The purpose of this policy is to set out DOC’s approach to COVID-19 vaccinations in line with DOC’s
Health and Safety risk assessment:
Transmission of COVID-19 in the Workplace. That risk
assessment relates to situations where there is a highly transmissible variant and community
transmission
. This Policy sits within broader health and safety policies, including those relating to
COVID-19. This Policy does not apply to staff who are subject to a legal requirement to be vaccinated
in order to undertake their work, such as border workers.
Introduction
Our priority is to keep our people safe and well. We do this because it is the right thing to do and we
have legislation (Health and Safety at Work Act 2015) that protects and supports this.
Released under the Official Information Act
COVID-19 is a significant risk to those who are infected. With community transmission, the risk of DOC
staff being infected within the workplace has increased and needs to be managed through a suite of
measures put in place in the workplace.
A health and safety assessment has been carried out to understand the risk and associated factors to
staff, visitors, contractors and suppliers, volunteers and community groups (including Jobs for Nature
projects) in different work scenarios. Mitigating and assuring ourselves that we can effectively and
safely manage risks associated with COVID-19 in the workplace has led us to develop a COVID-19
Vaccination Policy.
This policy will require all staff to be fully vaccinated to enter and work in DOC workplaces. Vaccination
is central to mitigating risk. You must be fully vaccinated and have a My Vaccine Pass by 1 February
2022.
1
Health and Safety risk assessment -
vaccination
DOC has assessed the risk and impact of a COVID-19 infection for all our people based on an
assumption of a highly transmissible variant and community transmission. You can see our current
Health and Safety risk assessment here DOC-6873027. The COVID situation is constantly changing
and the risk assessment will be updated when there are significant shifts in context. The first
scheduled review is by 31 May 2022. The risk assessment is based on multiple, layered controls such
as physical distancing, hygiene, signage, limiting numbers, barriers, and masks. Vaccination presents
a higher level, additional control and significantly moves the profile of risk down in both likelihood
and severity. Vaccination reduces the risk that the vaccinated person will be infected, suffer serious
illness if they are infected, and infect others they are in contact with. Additional measures will be in
place, including mask wearing, social distancing and the use of vaccine passports as reflected in the
Governments Traffic Light System.
It is recognised that vaccination and a vaccination mandate can have wellbeing effects on some
individuals and teams. Those risks have been taken into account in development of the Policy and
implementation processes.
Released under the Official Information Act
What that means for DOC staff
Given our risk assessment, DOC will require all staff to be fully vaccinated to enter and work in DOC
workplaces. This will be in place for the foreseeable future.
As an
employee, if you are not vaccinated, or choose not to be vaccinated, or are unable to be
vaccinated for medical or religious reasons, or have a medical exemption, we will work with you
individually to understand your situation and what options might be available to you. Whether you
can stay in your current role will depend on the nature of the work you undertake, whether you can
undertake your work from an alternative location in the short term, the availability of alternative work,
and any other factors that are relevant to your situation.
Where you have chosen to not be vaccinated (as opposed to being unable to be vaccinated), it will be
necessary to ensure that there are no undue effects on the business and your team colleagues due
to the arrangements put in place. Working from home on a long-term basis with no entry into the
2
workplace or in-person interaction with teams and managers is not likely to be considered a viable
option.
In good faith, we will ensure that you have opportunities to respond to any proposed changes to your
employment and will take into consideration your responses. This process will be managed centrally
by the Human Resources Team, with the support of your manager and you can involve a support
person of your choice (e.g. a union delegate).
The final decision on vaccination rests with the individual. The decision by DOC to require vaccination
does however mean that ultimately if you choose not to be vaccinated or to tell us your vaccination
status, we may need to consider termination of your employment.
Vaccination will greatly increase your safety and reduce the risk of you infecting a colleague. But
vaccination is in addition to and does not replace other safety measures, including wearing masks,
maintaining social distancing, and staying home if you may have been exposed or are unwell. All the
identified safety measures must be taken to ensure that our staff remain safe.
To support you receiving your vaccination, the Department has put in place policies to make it easier
for you to get vaccinated and implement other safety measures. Approved
Discretionary Leave with
Pay is available for you to get your vaccinations during your normal working hours, if you need time
to recover from vaccination, you are sick due to a COVID-19 related illness, or you are self-isolating
due to COVID-19. It is also available if you need to support a dependent (e.g. elderly parent, child) in
getting their vaccination.
Released under the Official Information Act
Collection, Use and Storage of Personal
Medical Information
You will be required to provide evidence of your COVID-19 vaccination status to your manager. This
can be a vaccination certificate, or vaccine pass. Your manager will sight the above and send an email
to [email address] confirming your vaccination status.
This information will be stored in a secure file accessible only to Human Resources/Health & Safety
staff who are managing the process and who will be involved with a manager in any follow up, such
as potential redeployment options.
If there is a reason to hold information, then that would be done in accordance with the Health
Information Privacy Code 2020.
3
If you cannot or choose not to provide evidence of vaccination, your manager will note that you are
unvaccinated. If you are subsequently vaccinated, you can at that time provide evidence to your
manager and that change in status will be recorded.
Protecting our staff from other people
entering DOC workplaces
In the interests of keeping our people safe, DOC will be ensuring that contractors and suppliers who
do work in or visit DOC premises are vaccinated. All people entering our premises will need to provide
proof that they are vaccinated.
The term “premises” is defined for the purposes of this policy as
A DOC workplace and premise is a DOC building and immediate surrounds where DOC has
influence and control over entry to the building. Where DOC shares a building, the DOC workplace
is the area of the building that DOC controls.
“DOC workplace and premises” does not include an outdoor work environment, for example Public
Conservation Land where work is not occurring on a given day
The mandate will also apply where a contractor or volunteer is working in close proximity to DOC staff
Released under the Official Information Act
or in an enclosed space with DOC staff (e.g. working together in a helicopter or vessel, travelling in a
DOC vehicle). Contractors and volunteer groups who are working in protected areas without close
contact with DOC staff will not be subject to this policy but will be be expected to determine their own
health and safety procedures, including how to protect against COVID-19 risks.
DOC will be writing to all
contractors and suppliers to advise of our vaccination requirements, which
will come into effect on 10 January 2022.
Suppliers will be able to do contactless drop-offs of goods to DOC premises.
Restrictions on entry of visitors to DOC workplaces and premises will come into effect on 10 January
2022. Signage and procedures to ensure this can be safely implemented will be in place by that date.
Groups who may be affected, including volunteer groups and iwi, will be advised.
END
4
Item 1e
DOC-6873020
COVID-19 Vaccination Policy Implementation
HR Process and Guidance for DOC Employees
15 December 2021
Scope
This document covers DOC employees including those working here on
secondment.
Definition of Vaccinated
For the purposes of the Vaccination Policy, vaccinated means you are currently
fully vaccinated against COVID-19 and its variants as per the official standards
and advice set at any time. Information on the COVID-19 vaccine can be found
at:
• Ministry of Health NZ
• Unite against COVID-19 (covid19.govt.nz)
DOC will regard an employee as vaccinated if the employee has received the
required doses of a Ministry of Health (MOH) approved vaccine, including any
required booster vaccination in the time recommended by MOH.
Released under the Official Information Act
Currently, to be fully vaccinated this means the employee has received the first
and second dose of the vaccine and can produce a valid Vaccine Passport.
To remain fully vaccinated for the purposes of this Policy, all required boosters
or additional dosage of vaccines as recommended by MOH must be received
within the required timeframes.
New Employees
All new DOC employees and any employee transferring to DOC from another
agency as from the approval date of this policy must have been fully vaccinated
at least two weeks prior to their starting date with DOC (unless they have a
MOH exemption).
What you need to do to comply with this policy
To comply with the Vaccination Policy, an employee must be fully vaccinated by 1
February 2022.
1
You will be required to provide proof of your vaccination status with My Vaccine
Pass, which is the official record of your COVID-19 vaccination status (or My Health
Record as an acceptable alternative). You can find information on this at My Vaccine
Pass | Unite against COVID-19 (covid19.govt.nz).
In considering implications for DOC employees who are unvaccinated, DOC will
explore all reasonable and available alternatives in consultation with the employee
and their representative. The potential outcome of termination of employment is as
a last resort, and alternatives will be considered within reasonable, available and
appropriate fiscal and operational considerations.
Supporting our people to be vaccinated
DOC will continue to enable our people to be fully vaccinated (and remain
vaccinated) by providing paid discretionary leave during work time to receive
a vaccination and/or booster and to recover from any short-term effects of
vaccination.
The COVID hub provides links to available resources to assist employees in
their decision making about the COVID-19 vaccination.
Key Dates
There are some key dates that are important for everyone to be aware of.
The key dates are as follows:
Released under the Official Information Act
2 December 2021 The COVID-19 Public Health Response (Protection
(11.59pm)
Framework) Order 2021 and the new COVID-19
Protection Framework (CPF) came into force (also
refer Appendix One)
14 December 2021
Vaccination Policy is approved and next steps outlined
15 December 2021
New employees (including secondees or transferred
workers from other agencies) to DOC are required to
be fully vaccinated (unless they have a medical
exemption from MOH).
15 December 2021 o Current employees are encouraged to provide
to 31 January 2022
evidence of their vaccination status to their
manager (My Vaccine Pass or My Health Record).
If an employee has a medical exemption from
MOH this also needs to be disclosed to
understand their work situation.
2
o
Managers will email the COVID-19 inbox with the
vaccination status of employees.
o The HR Team (with their manager and any
support person) will work with any employee
proactively who advises they are not willing to
be vaccinated to explore and to seek agreement
on available and reasonable alternatives to
termination prior to 1 February 2022.
1 February 2022
o
Only
fully
vaccinated
people,
including
employees, may enter a DOC workplace based on
whether vaccination is required by Government
mandate as well as required by DOC on health
and safety grounds as identified in the DOC risk
assessment.
1 to 9 February 2022
If the employee does not hold a My Vaccine Pass or
chooses not to disclose their vaccination status, or are
unable to be vaccinated, DOC will work with the
employee individually to decide how to manage the
impact of the Vaccination Policy on them. The employee
will be invited to a meeting to discuss any available and
reasonable alternatives to termination. (
Refer below to
Assessment Phase for more detail.)
o During this period, the employee will not be required to
be at work and will continue to be paid while we consult
Released under the Official Information Act
on alternatives to termination.
10 February 2022
• Should the employee refuse to be vaccinated or not
disclose their vaccination status and there are no
reasonable alternative options available, dismissal with
notice of termination (4 weeks) will be given.
The
employee will not be required to attend work during the
notice period and will continue to be paid. The
employee’s employment will end when the notice
period expires.
(Refer Termination below for more
detail.)
8 March 2022
Should the employee not have their required vaccinations
by the end of the notice period, their employment will be
terminated.
3
Vaccination Status
Employees
Need to supply confirmation of vaccination status
who are
using My Vaccine Pass (MVP) or My Health Record as
vaccinated
the appropriate means of evidence.
Confirmation will be confidentially recorded in an
employee’s Occupational Health and Safety record and
can be updated as required.
Employees who
Need to supply confirmation of vaccination status
are unvaccinated
using authorised Ministry of Health exemption.
due to medical
We will work with employees on a case-by-case
reasons or other
basis and this will include reviewing any reasonable
accepted reasons
alternative working options as necessary.
Employees
who are
unvaccinated
DOC will follow the process outlined to determine any
appropriate options and will discuss timeframes and
Employees who are
potential outcomes with the employee.
unwilling or decline
to declare
vaccination status
Released under the Official Information Act
Medical exemptions
The criteria for medical exemption from vaccination will be aligned with the criteria
for medical exemptions published in the Gazette by the Director-General of Health,
consistent with the COVID-19 Public Health Response (Vaccinations) Order 2021.
Where you are unable to be vaccinated for medical reasons, you will be able to
obtain a medical exemption as outlined in the MOH website: MOH exemption
standards.
If you are awaiting a medical exemption, DOC will engage with you to gain advice
from your medical professional and evidence that you have applied for an
exemption.
If you have a medical exemption each individual’s situation will be considered on
a case by case basis by the DDG People consistent with the New Zealand Bill of
Rights Act 1991 and the Human Rights Act 1993.
4
Assessment Phase
Discussion with employees who are unvaccinated
When unvaccinated employees have advised their manager of their vaccination
status, to be no later than 1 February 2022, this will trigger the assessment phase,
where options will be explored to determine if there are any reasonable and
appropriate measures that can be applied to reduce the possibility of exposure
to, infection or transmission of COVID-19, including the risk to other colleagues
and members of the public at work.
In assessing the individual circumstances DOC will consider feasible controls to
minimise and protect all employees, customers, stakeholders, and visitors. The
types of options that will be explored include determining:
• if the role can be performed in a different way
• whether you are able to perform your role without requiring access to
a work-related location where vaccination is an entry requirement
• your skills and experience to assess if there are any alternative roles
within DOC or other agencies that can be performed from a location
that doesn’t require vaccination either on a temporary or permanent
basis
• The ability for you to undertake your role from home as agreed on a
temporary basis
Released under the Official Information Act
• Whether you have a work area at home that provides the same or
greater levels of ergonomic support you would receive in your normal
work environment.
• Whether you have a work area that provides a safe and secure work
environment.
• Balancing business operational requirements with your individual
circumstances, the needs of other team members, and stakeholder
expectations.
DOC has limited capacity to accommodate working from home on a permanent
basis and certain roles are not able to be undertaken at home. While all
reasonable accommodations will be considered, permanently working from home
will not be the primary option.
HR will make a recommendation to DDG People in terms of the options discussed
with the employee.
5
A letter will be sent to the employee outlining the outcome of the assessment phase
and the recommendation made to the DDG People. The employee can make a
submission to the DDG People should they wish her to consider other options.
Termination
The employee will have met with HR (Manager, and PSA if requested) during the
assessment phase.
A letter will be sent to the employee advising the proposal to terminate which was
sent to the DDG People. The letter will provide the opportunity for the employee to
provide further information and request to consider other options.
A list of unvaccinated employees will be sent to the DDG People with
recommendations for approval to terminate together with the employee’s
feedback.
The DDG People will take advice from DDG colleagues and decide whether to
terminate. DDGs to consider that all roles are treated similarly taking into
consideration individual circumstances.
Following the assessment of all available and reasonable alternatives and none
have been agreed, then the employee will be given 4 weeks paid written notice
of termination of their employment. The employee will not be required to work
nor attend at work during the notice period.
Termination letter sent by DDG People to the Manager to deliver to the employee.
Where a decision to terminate the employment is made, contractual notice periods
apply if it is longer than four weeks (otherwise minimum statutory notice is four
Released under the Official Information Act
weeks) .1
Deciding to Get Vaccinated
If the employee chooses to get vaccinated during the assessment period the
employee can return to the workplace on a date reasonably set by DOC (taking
into account matters such as vaccine efficacy recommendations and work needs).
If the employee gets vaccinated during the notice period, and provides accepted
proof of vaccination, if there is no unreasonable disruption to the workplace and
DOC’s business, DOC may withdraw the termination notice and the employee can
return to work on a date reasonably set by DOC.
1 COVID-19 Response (Vaccinations) Legislation Act 2021 amending the Employment Relations Act
2000 [Schedule 3A]
6
Support
We have discussed and shared this proposal with the PSA. They are available
for advice and assistance to their members.
We are committed to the wellbeing of our employees. EAP support is available
for all DOC employees. EAP counselling can be used for any personal or work-
related issues including coping with change and stress. To arrange a counselling
appointment, please:
call:
0800 327 669
Other support may be found at the Wellbeing Hub For health related queries, please talk to your GP or Healthline.
Be respectful of others
We appreciate there may be differing views on COVID-19 Vaccination Policy and
that there will be much discussion about it. We urge you to be tolerant and
respectful of your colleagues if their views differ from yours. Because views are
personal, trying to influence others or debating positions in the workplace is not
encouraged.
We acknowledge this decision may be concerning for some of our people - please
refer them to support available (above).
Released under the Official Information Act
7
Appendix One
Government Vaccine Mandates
DOC’s risk assessment which informed this Vaccination Policy does not cover certain
roles that are required to be done by vaccinated employees under Government
vaccine mandates2 relating to the following sectors relevant to DOC:
• Border workers – CITES employees or other employees who are required to
work at the border.3
• Health and Disability: DOC firefighters / SAR / Avalanche. Employees in these
roles are required to be vaccinated because they may carry out work which
may require being within two metres, for more than 15 minutes, of a Health
Practitioner (e.g. paramedic or GP) providing health services to the public
• Education services where our employees are visiting schools and there is
contact with children or students
The new COVID-19 Protection Framework has extended these mandates to cover
certain roles within businesses that are required to utilise My Vaccine Passes: for
DOC these include:
• hospitality (serving of food and drink for sale),
• close contact services or businesses (where cannot maintain 1m physical
distancing).
Released under the Official Information Act
The mandates do not require a person to be vaccinated. The focus of the mandates
is on the roles being undertaken. An employee may choose whether or not to be
vaccinated. However, if their role falls within one that must be undertaken by a
vaccinated employee, and the employee remains unvaccinated, then we may take
the steps outlined in this Policy up to and including termination of employment.
If an employee is covered by the mandatory vaccination requirement, the following
vaccination deadlines apply to them:
1. Affected Persons in the education and health and disability sectors must have
received their first dose by 15 November 2021 and their second dose by 1
January 2022 (unless an exemption applies);4 and
2. Employees at settings where a My Vaccine Pass is required for entry must
have received their first dose by 3 December 2021 and their second dose by
2 COVID-19 Public Health Response (Vaccinations) Order 2021 in effect 30 April 2021
3 COVID-19 Public Health Response (Vaccinations) Amendment Order 2021 in effect 14
July 2021
4 COVID-19 Public Health Response (Vaccinations) Amendment Order (No 3) 2021 in effect
25 October 2021
8
17 January 2022.
Only vaccinated employees can carry out the relevant work covered by the
Government vaccine mandates. We will work with employees when determining
whether a particular role will reasonably require an employee to undertake work
covered by these mandates and will follow the steps set out in this Policy for
considering other options and discretionary paid leave.
Any unvaccinated workers who have previously been assigned to work in these
settings will need to discuss alternative options with their employers. They will not
be able to continue to work in high-risk environments until they are vaccinated.
Released under the Official Information Act
9
Item 1f
SLT Weekly
Report for agenda item [#]
Meeting date:
14 December 2021
Lead SLT member
Ginny Baddeley, DDG People
(approved paper)
Prepared by:
Harry Maher, Director Health & Safety
Subject:
COVID-19 Vaccination Policy – Implementation Process and Guidelines
Paper type
Decision required
Purpose of paper
To recommend approval of the draft COVID-19 Vaccination Policy
Implementation HR Process and Guidance for DOC Employees
SPA
Ginny Baddeley, DDG People
Recommendations
Approve the implementation process and guidelines
from this paper
Financial implications
No implications
Who has been actively
HR team and PSA assigned delegate
engaged in preparing
this paper
Persons attending item
Harry Maher, Director Health & Safety
Released under the Official Information Act
Time required
We recommend that SLT:
Paragraph
reference
(a)
Agree to the attached COVID-19 Vaccination Policy Implementation HR
[Insert
Process and Guidance for DOC Employees
paragraph
number]
Context / background
1. An accompanying paper has proposed that you adopt a final Policy on mandating vaccination
against COVID-19. This paper sets out a proposed HR process and guidance document to ensure
consistent and legally compliant implementation of the mandate.
Proposal
2. Attached is the proposed COVID-19 Vaccination Policy Implementation HR Process and Guidance
for DOC Employees
SLT Weekly
Report for agenda item [#]
3. As set out in the accompanying paper, there will also be implementation work undertaken
related to:
• Maintaining the risk assessment, with initial amendments to reflect comments in
submissions (including to improve readability), and then amendments as necessary to
reflect new information.
• Work between HR and the PSA to address any workplace issues that are identified, such
as harassment of staff based on their vaccination status or beliefs.
• Work by managers to address impacts on the business of any loss of staff capacity as a
result of the mandate and/or infections.
• Work to ensure that staff involved in enforcing the mandate in relation to visitors to
DOC premises are provided with the necessary systems, training and support.
Others actively engaged
4. The PSA assigned delegate was involved in development of the implementation approach.
Next steps
5. Once the implementation approach is approved, implementation work will commence.
6. SLT will need to ensure that there are effective communications with iwi, concessionaires,
volunteer groups, contractors and others who may be affected by the restrictions on entry to
offices and/or who work with staff and may be concerned about whether our staff are
vaccinated.
Attachments/appendices
Released under the Official Information Act
• COVID-19 Vaccination Policy Implementation HR Process and Guidance for DOC Employees
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Released under the Official Information Act
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Item 2a
Date:
13 April 2022
To
Ginny Baddeley, DDG People
Prepared by:
Harry Maher, Director Health & Safety
Subject:
Implementing Cabinet Decisions - COVID-19 Vaccination Policies
Paper type
Decision required
Purpose of paper
To report back on the staff survey on the proposal to suspend the
COVID-19 Vaccination Policies for DOC Employees/Contractors/
Volunteers and visitors to DOC workplace premises, and to
recommend final decisions
SPA
Ginny Baddeley, DDG People
Recommendations
Note that the results of a review of the COVID-19 Vaccination Policies
from this paper
for DOC Employees/Contractors/Volunteers were considered by SLT,
and a proposal to suspend the mandate and take other related steps
has been provided for staff consultation and feedback
Note the feedback provided through the staff survey, which closed
Tuesday 12th April
Approve the proposal to suspend the COVID-19 Vaccination Policies for
DOC Employees/Contractors/Volunteers and visitors to DOC workplace
premises, subject to certain conditions (see below)
Report the key feedback from staff to SLT for their consideration
Released under the Official Information Act
during implementation
Financial implications
No implications
Who has been actively
PSA
engaged in preparing
this paper
I recommend that you:
(a)
Note that the results of a review of the COVID-19 Vaccination Policies for DOC
Employees/Contractors/Volunteers were considered by SLT, and a proposal to suspend
the mandate and take other related steps has been provided for staff consultation and
feedback
Note the feedback provided through the staff survey, which closed Tuesday 12th April
Approve the proposal to suspend the COVID-19 Vaccination Policies for DOC
Employees/Contractors/Volunteers and visitors to DOC workplace premises, subject to
certain conditions (see below)
Report the key feedback from staff to SLT for their consideration during implementation
Context / background
1. On Wednesday 23 March 2022 the Prime Minister announced a series of Cabinet decisions relating
to vaccine mandates and related COVID management issues, including an announcement that
from 11:59 hrs Monday 4th April My Vaccine Passes will no longer be a requirement at any traffic
light setting, but the Pass system would remain in place and could continue to be used by
businesses.
2. The basis of the changes was a result of high levels of vaccinations, widespread but peaking
community transmission and the serverity of Omnicrom as the dominant variant.
3. A review of our Risk Assessment and associated “DOC Employees/Contractors/Volunteers and
visitors to DOC workplace premises” policy was commissioned and advised that justification for a
blanket national vaccine mandate is not currently required to keep staff safe, provided other
measures (including possibly role-specific vaccine mandates) are effectively implemented.
4. A paper was presented to SLT 28 March 2022
Released under the Official Information Act
SLT decisions
5. At the 28th March SLT meeting the following decisions were taken:
I.
Suspension of the Policy with the exceptions set out below. Suspension was
recommended rather than revocation as future events (for example, should a new variant
emerge) may require a move back to mandates, and suspension rather than revocation
means those situations can be responded to quickly.
a) Retention of the Policy for a defined group of staff, contractors and
volunteers in specific ‘high consequence’ situations where isolation is not
possible and evacuation is by helicopter or boat and can be disrupted by
weather
II.
HR, together with managers and where appropriate Health and Safety support, to work
with individuals who were not able to produce a valid My Vaccine Passport or an MOH
issued Exemption as at 01 February 2022. This would complete the work already
undertaken that was paused on 23 March 2022 This would focus on the development of
return-to-workplace plans. If there is a requirement for vaccination to be required for any
impacted individual and their work, these would be worked through on a case-by-case
basis.
III.
Being explicit about the suspended vaccination policy when recruiting.
Implementation
6. MBIE and PSA advice was that, prior to final confirmation, we should consult with our people
on the proposed course of action. This was done via a limited period web survey starting 6th
April closing 11th April. This sought to determine overall views on the proposals and key issues
to be addressed in implementation.
7. The summary of feedback is attached. Overall, the approach is supported, with the level of
support being similar to that for the introduction of the Vaccination Policy. Comments that
strongly opposed the approach either wanted no vaccine mandates at all (and in some cases
no COVID-specific measures) or considered that the approach would not keep them or other
vulnerable workers safe. A number of people considered that it was too early to change the
approach and suspend the policy. The level of support is sufficiently high that I do not consider
you will need to take the issue back to SLT. Delaying full implementation of the new approach
to allow Omicron to peak in all regions is desirable.
8. Key issues that were highlighted by staff and will need to be addressed in implementation are:
a) There is already poor implementation of COVID related health and safety measures in some
locations (masking, distancing, etc). This needs to be addressed. The risk of transmission is
still high, and the risk that an infected person could suffer adverse effects (including long-
Covid) is also still high. Setting an expectation to follow public health messages will be
important, particularly as there remains a high risk that staff will come into contact with
people who are infectious (including visitors). This includes mask wearing, for which clear
guidance already exists.
b) There are site specific issues that need to be addressed, notably around ventilation, shared
premises, and interactions with the public. This needs to be leader-led with appropriate
support (e.g. from Property).
c) Staff not taking time off when sick and feeling that doing the work is more important than
recovery or protecting their colleagues from infection (presenteeism) was identified by
many as a serious problem. Role modelling, good management of staff who come to work
Released under the Official Information Act
when ill, support for staff while they are ill or convalescing, and ready availability of sick
leave are all required.
Analysis and recommendations
9. The feedback from staff broadly supports the proposed new approach to COVID-19 health and
safety risks.
10. It highlights, however the importance of effective implementation of a wide range of
measures to manage risk, particularly for vulnerable staff. This was also a key finding in the
risk assessment review. From the feedback and PSA comments, it is clear that there is concern
about the ability of DOC to achieve uniformly high safety, given differences in context (e.g.
levels of COVID-19 in the community), office configuration (crowding, ventilation),
management quality, and team culture. That makes effective implementation planning and
monitoring/correction systems vital.
11. I therefore recommend that you confirm the SLT decisions of 28 March 2022, but when
reporting back to SLT, reiterate the need to ensure that implementation of COVID related H&S
measures at place and within teams is treated by managers as a critical issue.
12. I further recommend that you agree that providing support to managers in implementing new
systems be a key priority over the next few months. I would use the staff feedback as a key
input into priority setting for support work, along with feedback through HPE from the PSA on
problem areas.
13. Given that COVID-19 has probably not yet peaked in all regions, and a return to work needs
to be carefully managed, I recommend that the suspension of the policy take effect from 4
May giving us time to work with our staff currently working through HR processes and time to
work with managers and site leaders to set expectations.
14. While it is desirable that staff return to their normal work patterns, I recommend that managers
are supported to take into account individuals vulnerabilities and perceptions of risk. Where there
is likely to be continued working from home, completing a flexi-work agreement is vital to ensure
their H&S when working at home, even if that would only be a temporary arrangement related to
COVID risk.
Others actively engaged
15. The PSA assigned delegate has assisted in analysis of staff feedback.
Released under the Official Information Act
Item 3
DRAFT for Consultation 29
November 2021
DOC COVID-19 Vaccination Policy Based on community transmission
Purpose
The purpose of this policy is to set out DOC’s approach to COVID-19 vaccinations in line with DOC’s
Health and Safety risk assessment:
Transmission of COVID-19 in the Workplace. That risk
assessment relates to situations where there is a highly transmissible variant and community
transmission is widespread.
Introduction
Our priority is to keep our people safe and well. We do this because it is the right thing to do and we
have legislation (Health and Safety at Work Act 2015) that protects and supports this.
COVID-19 is a significant risk to those who are infected. With widespread community transmission,
Released under the Official Information Act
the risk of DOC staff being infected within the workplace has increased and needs to be managed
through a suite of measures put in place in the workplace.
A health and safety assessment has been carried out to understand the risk and associated factors to
staff, visitors, contractors and suppliers, volunteers and community groups (including Jobs for Nature
projects) in different work scenarios. Mitigating and assuring ourselves that we can effectively and
safely manage risks associated with COVID-19 in the workplace has led us to develop a COVID-19
Vaccination Policy.
This policy will require all staff to be fully vaccinated to enter and work in DOC workplaces. Vaccination
is central to mitigating risk. Your second vaccination must have been administered by 18 January
2022.
1
Health and Safety risk assessment -
vaccination
DOC has assessed the risk and impact of a COVID-19 infection for all our people based on an
assumption of a highly transmissible variant and widespread community transmission. You can see
our current Health and Safety risk assessment here DOC-6853729
The risk assessment is based on multiple, layered controls such as physical distancing, hygiene,
signage, limiting numbers, barriers, and masks. Vaccination presents a higher level, additional control
and significantly moves the profile of risk down in both likelihood and severity. Vaccination reduces
the risk that the vaccinated person will be infected, suffer serious illness if they are infected, and infect
others they are in contact with. Additional measures will be in place, including mask wearing, social
distancing and the use of vaccine passports as reflected in the Governments Traffic Light System.
DOC’s risk assessments are dynamic and will be revised should any factors change and if other
controls become available to DOC.
A formal review of the Risk Assessment and Policy will be undertaken at 31 May 2022
What that means for DOC staff
Released under the Official Information Act
Given our Risk Assessment, DOC will require all staff to be fully vaccinated to enter and work in DOC
workplaces. This will be in place for the foreseeable future.
As an
employee, if you are not vaccinated, choose not to be vaccinated, or are unable to be vaccinated
for medical or religious reasons, or have a genuine doctor’s exemption, we will work with you
individually to understand your situation and what options might be available to you. Depending on
your role and the nature of the work undertaken, we will consider the way you work, the ability for
you to undertake your work from an alternative location in the short term, and the availability of
alternative work.
Working from home on a long-term basis is not considered a viable option in this circumstance if you
are choosing not to be vaccinated.
In good faith, we will ensure that you have opportunities to respond to any proposed changes to your
employment and take into consideration your feedback. This process will be managed centrally by
the Human Resources Team, with the support of your manager and be supported by a support person
of your choice.
2
The final decision on vaccination rests with the individual. The decision by DOC to require vaccination
does however, mean that ultimately if you choose not to be vaccinated or to tell us your vaccination
status, we will need to consider termination of your employment.
Vaccination will greatly increase your safety and reduce the risk of you infecting a colleague. But other
safety measures, including wearing masks, maintaining social distancing, and staying home if you may
have been exposed or are unwell, will continue to be vital.
To support you receiving your vaccination, the Department has put in place policies to make it easier
for you to get vaccinated and implement other safety measures. Approved “
Discretionary Leave
with Pay” is available for you to get your vaccinations during your normal working hours, if you need
time to recover from vaccination, you are sick due to a COVID-19 related illness, or you are self-
isolating due to COVID-19. It is also available if you need to support a dependent (e.g. elderly parent,
child) in getting their vaccination.
Vaccination status
To operationalise this policy, DOC will need to sight and be assured of your vaccination status. This
means we can implement effective controls to keep you and all people who come to a DOC worksite
or premises safe. We already have a good base of data from voluntary emails to the COVID-19 inbox,
and we will work with those who haven’t advised yet to gather your vaccination record. We have
secure systems in place for handling data on people’s vaccination status (see below).
Released under the Official Information Act
Your vaccination record can be obtained from https://app.covid19.health.nz/
If you choose not to provide your vaccination status DOC will have no option but to deem you
unvaccinated and treat you as such.
Collection and Storage of Personal
Medical Information
You will be required to provide evidence of your COVID-19 vaccination status to your manager. This
can be a) vaccination certificate, b) vaccine pass, or c) a letter or email from your GP.
Your manager will sight the above and send an email to the [email address] confirming your
vaccination status with date of your second vaccination.
3
This information will be stored in a secure file accessible only to Human Resources/Health & Safety
staff who are managing the process and who will be involved with a manager in any follow up, such
as potential redeployment options.
If you choose not to provide or do not have MY COVID Pass or confirmation of vaccination your
manager will note that you are unvaccinated.
Protecting our staff from other people
entering DOC workplaces
In the interests of keeping our people safe, DOC will be ensuring that contractors and suppliers who
do work in or visit DOC workplaces are vaccinated. All people to our workplaces (DOC offices and
facilities) will need to provide proof that they are vaccinated.
DOC will be writing to all
contractors and suppliers to advise of our vaccination requirements, which
will come into effect on 14 December 2021.
Restrictions on entry of visitors to DOC workplaces will come into effect on 14 December 2021.
Signage and procedures to ensure this can be safely implemented will be in place by that date.
END
Released under the Official Information Act
4
