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RCOG submission to the DHSC Consultation on ‘Making vaccination a condition of deployment in the health and wider social care sector’

22 October 2021

The make-up of the healthcare and social care workforce is predominantly female, which means there is likely to be a considerable number of pregnant women potentially affected by the proposal to mandate vaccination as a condition of deployment.

Pregnancy and maternity remain a protected characteristic under the Equality Act 2010 and it is therefore essential that the particular rights of pregnant women are considered in light of the proposed policy.

Data from the United States and the UK, where over 260,000 pregnant women have had a COVID-19 vaccine, has so far not raised any safety concerns. However as these are new vaccines, there is a need to gather more safety data specifically related to pregnancy.

While we fully support and encourage all of those who work in a healthcare and social care setting, including pregnant women, to get vaccinated as an important way to protect themselves and their patients, we believe that having a vaccine should be a personal choice informed by a discussion on individual risk and benefit, supported by a healthcare professional.

Government guidance is clear that pregnant women of any gestation should be offered a workplace risk assessment with their employer and occupational health team. If following this the employer is unable to remove or manage any risks, individuals should be offered suitable alternative work or working arrangements, or be suspended on normal pay. If pregnant women are unable to work in healthcare or social care settings because they choose not to have a vaccine, their employer should offer them the same alternatives.

However, we are concerned that the proposed policy risks pregnant women losing employment because they want to retain their right to choice around vaccination. COVID-19 has disproportionately affected women’s employment, and this policy risks creating further disparities.

It is also important to highlight that while Covid-19 vaccine and annual flu vaccine take up among healthcare professionals is generally high, there will be practical implications on staffing levels if the UK Government chooses to introduce mandatory vaccinations. The pressures on the workforce and high rates of vacancies in healthcare and social care are well known and will be significantly exacerbated if a decision is made to terminate healthcare and social care workers contracts if they choose not to be vaccinated.

The RCOG advises against ever implementing a policy where vaccination is a condition of work, as we feel that women, especially those who are pregnant, should always be given the choice to make informed decisions about their own health and care.