Consultation description

The government is reviewing whether COVID-status certification could play a role in reopening our economy, reducing restrictions on social contact and improving safety.

COVID-status certification refers to the use of testing or vaccination data to confirm in different settings that individuals have a lower risk of getting sick with or transmitting COVID-19 to others. Such certification would be available both to vaccinated people and to unvaccinated people who have been tested.

The government is looking to consider the ethical, equalities, privacy, legal and operational aspects of a potential certification scheme, and what limits, if any, should be placed on organisations using certification.

The call for evidence has been issued to inform this review into COVID-status certification, to ensure that the recommendations reflect a broad range of interests and concerns.

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FDF response

The Food and Drink Federation is the industry body representing over 900 UK food and drink manufacturers. In line with the Government’s wish to assess public and business views of support for vaccine, testing and immune certification the FDF has consulted its 900 member companies and 20+ associations on the subject. Our membership is comprised of branded and own label businesses supplying the food service sector (transport, schools, care homes); hospitality (café, restaurants and pubs) and retail. Perhaps not surprisingly, the views of our members differ according to the channel/s that they predominantly serve. It is also clear that this is an evolving debate with new proposals for the sorts of certification and its technological and practical specification emerging throughout the consultation period. 

We set out the considerations most concerning FDF members below.

1. Reopening of hospitality/food service (out of home)

Vaccination, testing and immunity certification would be very likely to support the reopening of these vital sectors at sufficient scale to make it sustainable. While there has rightly been considerable government support for hospitality outlets, the long-tail of the out of home sector, which includes manufacturing, packaging and logistics has not been supported to the same degree. Our members have been reluctant to take on the additional debt offered by the government loan scheme, currently one of the limited available options. It is vital that the out-of-home sector is assisted to re-open as quickly and safely as possible at scale, thus guaranteeing jobs in vulnerable companies. Despite the welcome support of the furlough scheme, regrettably, some of our members are already being forced to restructure their operations and make redundancies in those parts of the industry which appear no longer to be viable.

Members are concerned that vaccine certification in particular may exclude some sectors of the community. Public debate has highlighted the relatively lower take up of the vaccine among certain ethnic groups. It would be divisive and discriminatory - not to say socially corrosive - if this disparity was to be institutionalised in access to food service and hospitality. Similarly, young people, who have already seen their life-chances impacted by Covid-19, are at a lower vaccine priority level. It is likely to be several months before the majority can access a second dose. This group have suffered considerably from mental health issues triggered by the pandemic and the prospect of exclusion from opportunities to engage in wider society would be damaging and grossly unfair as it is a direct result of Government policy. Vaccine certification would also exclude groups such as pregnant women/new mothers and those who for health reasons are unable to receive the vaccination. Both of these groups also benefit from the support that wider socialisation brings. 

Members also express some concerns about the practical process for certificate verification. This must be robust.  Document falsification sometimes occurs in the age identification schemes operated by the pub trade. A certification scheme should only be introduced alongside other safety measures including contact tracing, social distancing and rigorous hygiene. It is important that it is easily understood, highly accessible for all sections of the community, social group and age cohort and that it takes into account legitimate concerns about cost to users and confidentiality.

2. Operational safety for manufacturers and use of certification at work

Throughout the pandemic, food manufacturing has continued to operate and the safety of colleagues has been paramount. Considerable investment has been made in implementing social distancing and reducing risk to colleagues who may be working in close proximity. Even those manufacturers supplying exclusively to retail, which have had continually buoyant sales (if not margins) have incurred considerable cost. Responsible companies have gone to exceptional lengths in implementing a huge range of measures - including staggered shifts; temperature checks and more recently testing - to keep their workforce safe. Where outbreaks have occurred, they have handled swiftly by members working in concert with the local health protection advisers. 

Many manufacturers will welcome the prospect of certification at work and the role it could play in keeping employees and the wider community informed and safe.These businesses are often pivotal to the wider economic health of a community and major employers. There was considerable stress on the supply chain early in the pandemic where the enormous production uplifts triggered by panic-buying collided with increasing employee absence. The cessation of testing and testing data meant colleagues would often remain at home as a precaution. Certification may supply more reassurance to our members’ colleagues and potentially swifter identification and certainty of the source of outbreaks. 

Of course both employers and employees retain concerns about data protection and the collection, verification and storing of sensitive employee data. The industry relies heavily on agency workers which could expose some vulnerabilities in tracking certifications. There is also lack of clarity at this point on the legal position of employers in insisting on vaccination or testing. This could expose employers to discrimination claims from those unable to have the vaccination and again, lead to falsification of documents. Certainty must be given on the legal position. Finally, FDF has supported the increased use of home-testing in the community as it assists our myriad of businesses with under 50 employees. And those located far from community testing sites. However, we recognise that home testing does potentially increase the possibility of inaccurate results and of certification of those outcomes. 

3. Summary

FDF members believe that it is vital to ensure the speedy reopening of food service and hospitality businesses at scale. If this does not happen in the next few weeks many of these businesses will collapse. The UK could lose up to half its pubs and sandwich shops with catastrophic economic and personal consequences for those involved. Up to 4 million people are employed in the food and drink supply chain. At least half of those jobs could be at roost. While the industry has reservations about vaccine, testing and immunity certification FADF believes that the benefits of an appropriately robust, secure and accessible scheme significantly outweigh the risks. We support the creation of such a scheme. We will continue to play our full part in encouraging members and to embrace it. We will also encourage colleagues to embrace the safety measures agreed by government and continue to work above and beyond in our adoption of proportionate safety measures in accordance with the Working Safely guidance.