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NHS managers who fail hygiene standards face sack

The government has announced that the Health Improvement and Protection Bill will not include provision for criminal sanctions against senior staff whose hospitals fall below required hygiene standards. Greg Bousfield talks to Sapna Malik, specialist personal injury lawyer with Leigh, Day & Co, about why she is "not surprised" at the move...

The Health Improvement and Protection Bill will no longer include provision for criminal sanctions or fines against senior hospital staff whose institutions fail to meet hygiene standards, Health Secretary Patricia Hewitt has announced at the Bill’s consultation launch.

Instead, Trust board members could be sacked for failing to meet hygiene standards.

“I am not surprised that the criminal sanction has been removed, it was like the corporate manslaughter bill, where we were originally promised a lot but didn’t get very much,” says Sapna Malik, specialist personal injury lawyer with Leigh, Day & Co. “We will continue to fight these claims from a civil liability perspective.”

The government’s new proposal is that the Healthcare Commission will monitor healthcare institutions’ compliance with hygiene guidelines and will serve a health and safety-style improvement notice on any (public or private) institution which fails to meet the required standards. The Healthcare Commission will take no further action if standards are subsequently complied with, within a specified required time-frame. However, in the situation where an institution fails to comply, the Healthcare Commission could then refer the case to the Secretary of State, who might dismiss a trust board or individual members. The government says that a new compulsory code of practice for healthcare associated infections (HCAIs) which has now open for public consultation is the key to the new policy.

  While the NHS Confederation is pleased that the threat of criminal sanctions is gone from the Bill, some clinical negligence lawyers believe criminalisation could have assisted in the difficult task of bringing successful claims for negligence in hospital infection cases.

Criminalisation “would support the more general argument that the hospital was failing at a more global level to act in a responsible and reasonable manner with regard to infection control, but wouldn’t necessarily go to help an individual case where you still have to prove individual causation,” Malik says. Indeed, the difficulty of identifying the source of an individual’s infection – and thus whether it arose from negligent or non-negligent sources – is a major hurdle in establishing negligence claims and might also have represented a hindrance in obtaining criminal convictions. “It can be very difficult to pinpoint a particular decision or failure that can be linked to a particular death or serious infection.” The government says that this is the major reason it has dropped criminalisation.

The proposals for hygiene standards’ improvement notices and possible dismissals might provide a similar type of assistance in establishing negligence claims help claims, but this is uncertain. For example, the dismissal of a senior staff member might be linked to a general failure to meet hygiene guidelines rather than to any particular individual infection incident.

Breach of health and safety statute provides one of the few possibilities of statute support for a negligence claim. “One of the angles we are looking at is the use of the Control of Substances Hazardous to Health (COSH, 2002) regulation. The benefit of that is that you don’t have to have a resources argument [the defence that a hospital could not meet hygiene standards because of under-funding] when it comes to a breach but there are certainly no authoritative cases on it and one can see arguments against that as well,” she says. 

The HCAIs code of practice consultation runs until 23 September 2005.

(22/07/05)

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