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HCPC SCPE consultation closing on 16th June

Ben Whittaker
Ben Whittaker • 9 June 2023
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HCPC are seeking feedback on proposed changes to their Standards of conduct, performance and ethics for each of the fifteen professions that they regulate: Consultation on standards of conduct, performance and ethics | (hcpc-uk.org)  An additional theme – sustainability in health and care – is also discussed in the consultation to explore future revision to the Standards.  The deadline for the consultation is on Friday 16th June at 23:59.  

If you're interested in the sustainability in health and care theme, might you consider addressing this in questions 4, 5, 10, 11 and 18 in the consultation? 

 

Question 4: Do the Standards support registrants in maintaining their own well-being? *

Point for consideration: If HCPC don't address environmental sustainability in the Standards, will the registrants be more likely to practice in ways which are increasing greenhouse gas emissions and contributing to the worsening effects of climate change and air pollution?  These environmental effects will negatively impact on the health of populations, which may include the registrants own well-being. 

 

Question 5: Do the Standards ensure that registrants maintain a practice that promotes equal, fair, and inclusive treatment? 

Point for consideration:  If the HCPC standards do not address how environmentally unsustainable practice contributes to climate change can they be said to promote equal, fair and inclusive treatment? 

- The climate crisis is a health crisis, which "threatens to undo the last fifty years of progress in development, global health, and poverty reduction, and to further widen existing health inequalities between and within populations." Climate change and health (who.int)

- "Climate change not only threatens our ecosystems, it undermines the foundation of our fundamental rights, deepens inequalities and creates new forms of injustice." The ethical principles of climate change | UNESCO  

- "The UKCCC (Climate Change Commission) Health Equity Report highlights how direct and indirect impacts of climate change will widen existing health inequalities in the UK. The Group warns the most vulnerable will be hit hardest unless health equity is considered alongside future government greenhouse gas targets" Health inequalities & climate change assessed together for fair green recovery | UCL Energy Institute - UCL – University College London

- The Delivering a Net Zero National Health Service report is issued as statutory guidance and states: "Action to tackle climate change also reduces the burden of disease from air pollution, obesity, and poor diet whilst directly addressing health inequalities experienced across the country" (p.4) "...the drivers of climate change are also the drivers of ill health and health inequalities. For example, the combustion of fossil fuels is the primary contributor to deaths in the UK from air pollution, disproportionately affecting deprived and vulnerable communities." (p.8) Greener NHS » Delivering a ‘Net Zero’ National Health Service (england.nhs.uk)

- "Today, as the United Nations High Commissioner for Human Rights, I am still just as committed to environmental rights.  We need action to go further. Deeper. Faster.  We must empower people to hold their governments, big polluters and others accountable. I welcome increasing efforts to do so, including through criminal as well as civil law...  Work by the UN Committee on the Rights of the Child, among others, has repeatedly emphasized the importance of a human rights-based approach to climate action, including by protecting the rights of future generations, with accountability for the Governments and businesses most responsible. The triple planetary crisis challenges every part of society. Its impacts are profoundly unjust, and they are growing." Volker Türk, 5th June 2023 Climate protection as a human right | OHCHR

 

Question 10: Should improving sustainability in health and care practice be a part of these Standards? If so, what ought to be included in the Standard?  

Points for consideration:

1)      The legal mandate and background to addressing sustainability in healthcare.  For example:

- "The Climate Change Act 2008 is the basis for the UK’s approach to tackling and responding to climate change. It requires that emissions of carbon dioxide and other greenhouse gases are reduced and that climate change risks are adapted to... The Act supports the UK’s commitment to urgent international action to tackle climate change." A legal duty to act - Climate Change Committee (theccc.org.uk)

- Each public body in Wales (including the local health boards and NHS trusts) has a duty to act on sustainable development:   Well-being of Future Generations (Wales) Act 2015: the essentials [HTML] | GOV.WALES

- “Tackling climate change could be the greatest global health opportunity of the 21st century.” This finding, the central message of the second Lancet Commission on Health and Climate Change, attempts to answer the stark conclusion of the first Lancet Climate Change Commission, published in 2009—namely, that “Climate change is the biggest global health threat of the 21st century.” Tackling climate change: the greatest opportunity for global health - The Lancet

  - In 2021, all four UK health services committed to net zero carbon emissions, alongside 47 countries who pledged to develop climate resilient, sustainable low-carbon health systems: UK health services make landmark pledge to achieve net zero - GOV.UK (www.gov.uk)

-  In 2022, the NHS became the first health system to embed net zero into legislation, through the Health and Care Act 2022 (legislation.gov.uk) 

-   The Allied Health Professions (AHPs) are the third largest workforce in the NHS.  13 of the 14 AHPs are regulated by HCPC. The Greener AHP Hub was launched in 2021: NHS England » Greener Allied Health Professional hub The AHP Strategy for England 2022-2027 includes environmental sustainability as an area of focus, with ambitions for workforce, models of care and resource use: NHS England » The Allied Health Professions (AHPs) Strategy for England: 2022 – 2027 AHPs Deliver

- The Climate and Health guide is part of All Our Health, a resource which helps health and care professionals prevent ill health and promote wellbeing as part of their everyday practice: Climate and health: applying All Our Health - GOV.UK (www.gov.uk)

 

2) The precedent set by other regulators that have addressed sustainability in healthcare.  For example:

  • - The General Medical Council (GMC) state, "We aim to embed sustainability, social impact and ethics in everything we do. We strive to work in a way that benefits the environment and society." Corporate social responsibility (CSR) - GMC (gmc-uk.org)  The GMC consulted on sustainability within their Good Medical Practice review, which is awaiting publication, and have included sustainability in their outcomes for graduates:

Tackling climate change – even regulators have roles to play – Improving medical education and practice across the UK (wordpress.com) (Article)

Outcomes 3 - Professional knowledge - GMC (gmc-uk.org) (outcomes for graduates)

  • - The Care Quality Commission (CQC) state that their "quality statements show how services and providers need to work together to plan and deliver high quality care".  The CQC quality statement for Environmental sustainability – sustainable development is: "We understand any negative impact of our activities on the environment and we strive to make a positive contribution in reducing it and support people to do the same." Key questions and quality statements - Care Quality Commission (cqc.org.uk)
  •  
  • - The General Dental Council have consulted on sustainability being part of their standards, which are awaiting publication.
  •  

3) Whether your professional body or official international organisation has addressed sustainability.  For example:

 

4) As a registrant, do you have any examples of how you have incorporated sustainability into your practice and how inclusion within SCPEs could support/enable you to do this more effectively?  Or, as a registrant, might you identify that you have not been able to integrate into your practice because you/your employer need guidance and you want HCPC to provide this?  

 

5) Do you have any suggestions about how to integrate sustainability within HCPC's standards?  For example, 

A New Standard 11. Practice sustainably to protect patients, the wider community, and the environment, both now and in the future 

Minimise the environmental impact of the care you provide 
11.1 You must take steps to develop your understanding of the links between climate change, environmental degradation, and human health. 

11.2 You must seek to understand basic carbon literacy and the environmental impacts of the products and services you provide. 

11.3 You must, wherever safe and effective to do so, choose treatment with the least environmental impact i.e. lowest carbon footprint or least waste generated. 

11.4 You should include sustainability as a domain of quality when taking part in improvement work, thereby minimising the environmental and financial impacts and seeking positive social impact. 

11.5 You should exploit opportunities to promote actions that both reduce carbon emissions and benefit public health e.g. promoting active travel, sustainable diets 

Or ​Incorporation into Standard 1 with the additional subheading and points as below: 
Existing Standard 1. Promote and protect the interests of service users and carers 
Additional subheading: Practice sustainably to protect patients, the wider community, and the environment, both now and in the future 
1.13 You must take steps to develop your understanding of the links between climate change, environmental degradation, and human health. 

​1.14 You must seek to understand basic carbon literacy and the environmental impacts of the products and services you provide. 

​1.15 You must, wherever safe and effective to do so, choose treatment with the least environmental impact e.g. lowest carbon footprint or least waste generated. 

​1.16 You should include sustainability as a domain of quality when taking part in improvement work, thereby minimising the environmental and financial impacts and seeking positive social impact. 

1.17 You should exploit opportunities to promote actions that both reduce carbon emissions and benefit public health e.g. promoting active travel, sustainable diets​ 

 

6) Do you have any examples about how inclusion of sustainability in HCPC's standards might support public protection needs?  For example,

o We all have an impact on the environment and thus we have an ethical duty both as citizens and as health care professionals (HCPs) to act on climate change.

o   HCPs should "first, do no harm", but healthcare has a significant impact on the environment in the UK accounting for almost 5% of UK greenhouse gas emissions. Climate change has been described as the biggest global health threat this century, and addressing it as the biggest global health opportunity this century.  All HCPs have a responsibility to practice more sustainably and reduce the impact of healthcare on the climate. 

o   Climate change threatens the core purpose of the healthcare sector: it is well evidenced that poor environmental health contributes to major diseases including cardiac problems, premature birth, asthma and cancer. 

o Action on climate change will bring direct improvements for public health and health equity.  Reaching our country's ambitions under the Paris Climate Change Agreement could see: over 5,700 lives saved every year from improved air quality; 38,000 lives saved every year from a more physically active population, over 100,000 lives saved every year from healthier diets. 

o   If HCPs are not regulated on environmental sustainability, HCPs can continue practicing healthcare that is not in the best interests of the public. For example, by prescribing a metered dose inhaler instead of a low carbon dry powder inhaler (where clinically indicated) to a patient with asthma, the prescription is contributing to greenhouse gases. This is turn has an impact on air quality that will exacerbate that very same patient’s asthma symptoms. Indirectly, the prescribing clinician is worsening the health outcomes of the patient they are trying to protect by not being familiar with the science of climate change.

o   By including environmental sustainability in the SCPEs, every HCP will have an ethical responsibility to consider the climate impact of the assessments and treatment that they prescribe to ensure public protection.  

The long-term impacts of this inclusion will support the health of the population now and that of future generations.

 

Question 11: Do you consider there are any aspects of our proposals that could result in equality and diversity implications for groups or individuals based on one or more of the following protected characteristics – age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, or sexual orientation – as defined by the Equality Act 2010? *

Point for consideration: "Climate change is undermining many of the social determinants for good health, such as livelihoods, equality and access to health care and social support structures. These climate-sensitive health risks are disproportionately felt by the most vulnerable and disadvantaged, including women, children, ethnic minorities, poor communities, migrants or displaced persons, older populations, and those with underlying health conditions" Climate change and health (who.int)  For example:

 

Question 18: Do the proposed updates make it clear that HCPC supports a registrant's right to freedom of expression?  

Point for consideration:  Could the Standards support healthcare professionals who want to express themselves peacefully at climate protests as a way of trying to prevent the negative health impacts of climate change?  Should HCPC be clearer about their threshold for punitive action in these circumstances?  

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