Testing on Productions

The most basic control for any hazard is avoid, and sensible testing – not indiscriminate testing – can help keep the virus out of a production, or limit its spread within.

On January 1st 2024 The Health Protection (Coronavirus, Testing Requirements and Standards) (England) (Amendment and Transitional Provision) Regulations 2023 made several key amendments to The Health Protection (Coronavirus, Testing Requirements and Standards) (England) Regulations 2020.

  • The notion of a “single end-to-end testing service” has gone, along with the need for providers of commercial COVID testing to register with the Government. Now a “testing service provider” means “a person who carries out a sample collection or a point of care test, or a diagnostic laboratory”.

  • It applies to testing “provided in the course of a business by or on behalf of a testing service provider” so if a third party is charging your production to provide testing for SARS-CoV-2 they are caught by the requirements of this legislation.

  • If you subcontract sample analysis and/or sample testing, the provider needs to be accredited by UKAS (or another national accreditation body):

    • in relation to sample collection or a point of care test, ISO Standard 15189:2022
    • in relation to a diagnostic laboratory, either ISO Standard 15189:2022 or ISO/IEC Standard 17025:2017

There are some transitional provisions we won’t bore you with.

If you recall, the Government has been inventing new legislation to deal with imaginary issues with COVID testing for some time. The original legislation was framed to ensure that:

“…all private providers offering COVID19 testing services on a commercial basis in England provide services that are of a sufficiently high standard”

This had the effect of stopping private GPs, set medics and other qualified medical professionals conducting COVID tests outside the NHS which caused considerable consternation at the time, and had the effect of concentrating pretty much all commercial testing in the hands of a few large private providers – at a time when an awful lot of private testing for travel etc was mandated by law.

It’s claimed that these latest changes make compliance “less onerous” but the COVID testing space still has very high barriers to entry – and qualified medics are still barred from providing a simple diagnostic test as part of their private clinical practice.

Infection Timeline

THE TRAJECTORY OF A SARS-CoV-2 INFECTION HAS CHANGED DRAMATICALLY IN THE LAST FOUR YEARS.

WE’VE CHANGED. HIGH LEVELS OF IMMUNITY AT POPULATION LEVEL MEAN THAT WE WILL NOW TEND TO SHOW SYMPTOMS EARLIER – BECAUSE THE BODY RECOGNISES THE VIRUS MORE QUICKLY – AND BEFORE A TEST WILL RELIABLY SHOW A POSITIVE RESULT.

NEVER IGNORE SYMPTOMS AND DON’T BE FOOLED BY A NEGATIVE RESULT EARLY ON.

0days

[1.7-2.2 days]

DETECTABLE

THROAT SWABS

0days

[1.7-3.2 days]

DETECTABLE

NASAL SWABS

0days

[7.4-10.2 days]

CLEARED

THROAT SWABS

0h

[8.7-10.7 days]

CLEARED

NASAL SWABS

THE VIRUS IS DETECTABLE IN THE THROAT ~2 DAYS BEFORE THE NOSE BUT IT IS DETECTABLE FOR LONGER IN THE NOSE – AND AT HIGHER LEVELS.

28 DAYS FROM INFECTION 33% OF NASAL SWABS AND 11% OF THROAT SWABS WILL STILL TEST POSITIVE ON PCR.

VIABLE VIRUS CAN’T BE DETECTED AFTER 12 DAYS FROM INFECTION IN THE NOSE AND 11 IN THE THROAT – OR 10 DAYS FROM SYMPTOM ONSET.