This submission has been prepared by LSE IDEAS, with advice from Dr Clare Wenham, Assistant Professor, Department of Health Policy, LSE, and Susan Scholefield, former Head of the Civil Contingencies Secretariat and member of the LSE IDEAS Advisory Board
This submission addresses the following points raised in the Joint Committee’s call for evidence, on the extent to which:
A. Domestic preparedness and resilience in relation to biosecurity risks
A1. Exercises for testing and improving national resilience against biosecurity and other risks need to be given greater priority and should be undertaken annually, in line with World Health Organization (WHO) guidance. The last such exercise in the UK was in 2016, and prior to that, in 2012, before the Health Protection Agency became part of Public Health England in 2013, and responsibilities for public health were re-allocated between the NHS and local government. Ministers from a range of departments should be required to participate in such exercises.
A2. The results of resilience exercises should be published promptly and within a defined period (e.g. no later than three months), unless there are reasons for confidentiality based solely on identified threats from foreign powers or non-state actors. The results should have a clear programme of action for next steps to mitigate risks.
A3. Regional and local resilience exercises are needed, in addition to national exercises, to understand the different impact that outbreaks of disease and other biosecurity threats may have on different areas of the country and of society. These exercises should be led by local authorities, based on an understanding of the interaction between national and local responsibilities and capacity.
A4. Exercises in resilience should pay close attention to the need to establish - and sustain on a permanent basis - working relations and coordination between Government departments and agencies and between national, regional and local levels. It should be assumed that these links can atrophy or become ineffective rapidly if not regularly exercised and refreshed.
A5. There should be a strong presumption against seeking to build new organisations to deliver policies in the midst of a crisis. Resilience exercises should include surge capacity contingency, and consider how existing institutions can be adapted rapidly for new and hitherto unforeseen needs.
A6. Planning for dealing with biosecurity – and other national security – risks should make explicit the extent to which Government is prepared to invest in capacity to identify, assess and cope with low probability but high impact events: chemical, biological, radiological and nuclear (CBRN) accidents and attacks; infectious diseases of people, animals and plants; mass casualties, fatalities and evacuation. Such plans should also consider how emergency capacity – for example, for tasks like testing and contact tracing, or for informing, alerting and warning the public – can be used in the meantime.
B. National security strategies and their contribution to preparedness
B1. The UK Government needs to reconsider the approach that has been taken to strategy documents related to national security. Extant documents, such as the Biological Security Strategy, tend to be too abstract, over-concerned with coordination within Whitehall, and light on practical and accountable steps for their implementation within and outside central Government. Care should also be paid to the use of language – security terminology may not be conducive to engagement with the wider civil sector in the case of pandemic-like events.
B2. The UK needs to adopt a broader approach to national security and resilience, reflecting increasing biosecurity and other non-conventional security and resilience risks. Strategy for addressing biosecurity risks should reflect the WHO and the global heath security community’s all-risk approach to infectious disease, in line with the 2005 International Health Regulations.
B3. The national security and resilience community needs to be broadened and developed, drawing upon expertise from beyond the conventional security-related disciplines to reflect social science and civil society inputs, diversified by ethnicity and gender. To this end, a National Security and Resilience College should be established, using existing entities and experts, to train people from that broadened community at all levels – national, regional and local – together.
B4. Since the UK’s national security strategies address risks of all kinds to the safety and well-being of people in this country, these strategies need to take account of pre-existing inequalities and structural vulnerabilities in the health and life-chances of different parts of society. This includes the differential impact of such contingencies on ethnic and socio-economic groups, and on men and women.
B5. The Biological Security Strategy includes a strong commitment to advancing international health norms through the WHO. The Government’s explicit decision early in the COVID-19 outbreak to diverge from WHO advice on testing and contact tracing – and its subsequent decisions as UK policy evolved during the pandemic – therefore needs to be reviewed for their impact on the UK’s global health diplomacy.
C. Cross-government input in planning for pandemics
C1. Efforts to develop coordination across the broadened national security and resilience community should focus more on developing, refining and normalising working practices through regular interaction (and less on high-level policy formation).
C2. Planning for future pandemics will require broader inputs from Government and non-government organisations, and from a wider range of experts, to reflect the whole-of-society risks that have been exposed by COVID-19. This should include social scientists to reflect the impact across the board on UK politics, economics, health equities, education, gender relations, social policy, and food security.
D. Roles and responsibilities of the National Security Council and Government departments and agencies
D1. The principal role of the National Security Council is to set strategy and to formulate policy, rather than crisis response. In any future inquiry about Government performance in the COVID-19 pandemic, scrutiny of the National Security Council’s contribution will need to focus on the adequacy of the assumptions underlying the Government’s strategy for pandemics.
Domestic preparedness and resilience in relation to biosecurity risks
1. The COVID-19 pandemic has changed fundamentally the perspective of the UK Government and public on biosecurity risks. The UK Government’s assessment of the risk from infectious disease has previously prioritised the need manage a flu pandemic and to control outbreaks of disease overseas. Emphasis was placed on capacity building in low and middle income countries to prevent, detect and respond to outbreaks like Ebola, and contain these at the source, mitigating their international spread (such as to the UK). Genetic data demonstrates that COVID-19 spread rapidly in the UK from contacts in nearby countries like Italy and Spain, and this slipped through the net of extant government policy on infectious disease control.
2. The focus on mitigating the risk of infectious diseases at source appears to have distracted attention from the requirement for appropriate national and local capacity to deal with an epidemic other than flu within this country. Preparations for outbreaks of flu, a disease with a brief incubation period, directed more attention to hospital capacity than the infrastructure of laboratories for testing, effective contact tracing capabilities, and local reporting systems needed for diseases with longer incubation periods that can be contained by testing and tracing contacts. Significant reductions in funding and capabilities of local government over the past decade through austerity measures and the hollowing out of local government and social care, have amplified this problem.
3. The gap between policy formulation and implementation is exemplified by the UK being ranked second worldwide by the Global Health Security Index (2019, Johns Hopkins Center for Health Security) for its policies for preparing for a pandemic whereas, as of mid-June, it had the highest number of recorded deaths from COVID-19 among European countries.
4. Of the many factors that have contributed to the widely-perceived gap in subsequent performance with respect to COVID-19, three can be noted here: a misconception about biosecurity risks and the specific character of the COVID-19 risk; inadequate national resilience in the area of health and social care; and over-centralised and improvised decision making.
5. Biosecurity risks are discussed in the Government’s strategy documents as though they affect everyone in this country in largely the same way. Planning for a major outbreak of disease has not made allowances for significantly different outcomes across the country, by ethnicity, income or gender. Nor have allowances been made for different socio-economic outcomes arising from public health interventions, such as lockdown, working from home, and the closure of schools. Well established differences in health outcomes by region, income and ethnicity appear to have been largely overlooked in the assessment of biosecurity risks. This has inhibited an effective response as COVID-19 has shifted from being a threat to health to becoming a broader risk to society.
6. The assumption that the transmission and risks of COVID-19 would be similar throughout the UK reduced the Government’s flexibility in responding to the crisis. If the Government had planned for the possibility of different outcomes and priorities among the nations, regions and local communities, the tensions between central Government and the Devolved Administrations and municipal and other local leaders outside London could have been reduced.
7. The civil contingency planning that underlies the UK Government’s strategy for national, regional and local resilience has worked effectively in relation to risks such as civil disorder, floods and at least some infrastructure disruptions. With respect to health, contingency planning has relied too much on the Department of Health (since 2018, Health & Social Care). At present, the current institutional structures of the NHS do not all have a statutory basis and arrangements for partnership working at regional and local levels vary across the country. This may be one of the factors underlying the relative neglect of the threat of COVID-19 in care homes early in the pandemic.
8. Over centralisation of decision making has also contributed to disappointing outcomes during the COVID-19 pandemic. In three crucial areas for dealing with the pandemic – procurement, testing, and contact tracing – decisions and functions were drawn towards central Government, which was rapidly overwhelmed. In some regions and local communities, the UK’s resilience was weakened by limited institutional capacity and decision making power below central Government - in Public Health England, in the social care system, and in local government – to carry out these urgent tasks.
9. In preference to utilising existing institutions, the UK Government set up large new organisations for testing and contact tracing, involving the hiring and training of thousands of people. The same principle was applied for technological solutions, with the Government choosing to develop its own app for contact tracing. In light of this experience, an important principle of resilience should be to make better use of the people, organisations and capabilities already in place – a lesson that was already apparent from the Ebola crisis
National security strategies and their contribution to preparedness
10. The 2015 Strategic Defence & Security Review (SDSR) asserted (paragraph 4.131) that lessons had been learned from outbreaks of disease such as Ebola from 2014. The 2015 Review concluded that the UK had “detailed, robust and comprehensive plans in place and the necessary capacity to deal with infectious diseases, including pandemic influenza and respiratory diseases.”
11. The 2018 National Security Capability Review, concerned with effective deployment of the resources that the UK can bring to bear on national security, introduced the “fusion doctrine”. This is described in the Review as “a more accountable system to support collective Cabinet decision making, with the introduction of senior officials as senior responsible owners to deliver each of the National Security Council’s priorities”.
12. Among the capabilities examined as part of this Review was national resilience, defined as “the readiness for and recovery from emergencies and disruption”. The Review committed the Government to continuous support for, and improvement of, Local Resilience Forums (multi-agency partnerships including local councils, emergency services, and the NHS).
13. However, of the 89 action points that concluded the National Security Capability Review, only one related to health, although infectious disease had been identified as one of six “Tier 1” risks to national security. This action point was to deploy a new rapid response team to help other countries to investigate and control outbreaks of disease.
14. The Government’s approach to biological security was assessed separately in the 2018 UK Biological Security Strategy. This document explained what was being done within Government to protect the UK from biological threats (including infectious disease of all kinds, and attacks using biological weapons). It also explained how coordination between Government departments in this area would be further improved.
15. The Biological Security Strategy stated that, if there were a significant disease outbreak in the UK, the health service would be supported by “extensive cross-government response arrangements, including detailed contingency planning, to allow effective coordination and leadership – reinforced through a regular programme of training and exercises. The training takes place at local as well as national level – working with Local Resilience Forums and strategic coordinating groups to support a UK-wide response”.
16. Although the Biological Security Strategy explicitly sought to prepare for any type of disease, its general approach suggests that two strong underlying assumptions were that a future pandemic would be an influenza like illness (ILI) and that emerging diseases could be contained at source, likely in a low or middle income country setting.
17. Certain features of these three strategy documents published by the UK Government in 2015-2018, and their analysis and objectives for biological security, stand out in the light of the 2020 pandemic. All three documents were concerned principally with coordination and arrangements between Whitehall departments. The expression “cross-government” applied in these documents, including in relation to the “fusion doctrine”, generally means across Whitehall. There is little detail in these papers about implementation, and the continuous follow-up required at all organisational levels, importantly at local government or between devolved administrations, for ensuring that strategic objectives are carried out and in place. There is almost no discussion on working with and strengthening institutions outside central Government.
18. Membership of international organisations and partnerships forms an important part of the Government’s strategy for dealing with infectious disease overseas and reducing the risks of this spreading to the UK. The Biological Security Strategy mentioned that the UK uses membership of the WHO and similar bodies “to amplify our ability to strengthen international norms”, and to “ensure that the WHO leads and enables effective responses to health emergencies”. The Government made an explicit decision to depart from WHO recommendations in respect of testing and contact tracing in March 2020 in the COVID-19 outbreak in the UK. This and any other subsequent decisions will need to be scrutinised for their impact on the UK’s health diplomacy as well as on the course of the disease in this country.
Cross-government input in planning for pandemics
19. The UK Government has invested significant effort in trying to ensure that national security policies are formed by drawing on the input of a wide range of Government departments. The Biological Security Strategy was presented as “an overarching narrative for how the cross-Government effort fits together”. The logic of this document appears to have been that the enumeration of capabilities and plans in different areas of the UK Government demonstrated that an effective strategy for dealing with biosecurity risks was in place. In the past – notably during the Ebola outbreak outside the UK – this had been the case. With respect to COVID-19, the Biological Security Strategy proved seriously deficient.
20. The COVID-19 pandemic has demonstrated that efforts to develop cross-Government coordination should be focused more on working practices, rather than policy formation at a high level. The response to any emergency is likely to involve organisations that are not used to working together – such as the Border Force and the Department of Health during the Ebola outbreak. The COVID-19 pandemic has involved a much broader range of people and organisations, with local variations, including the Department for Work and Pensions, and the Department for Digital, Culture, Media and Sport. For example, on 9 June 2020, the Civil Contingencies Secretariat and the Cabinet Office Emergency Planning College notified ResilienceDirect partners of a Covid-19 Learning and Development Programme, developed in collaboration with UK Government Departments, Devolved Administrations, the College of Policing, University of Manchester and other professional institutions.
21. In any future emergency, it is likely that some areas of Government will be engaged for the first time with unfamiliar counterparts. Moreover, institutional memory in central Government can be short – officials can easily forget that certain institutions, areas of expertise and channels of communication are available, and might swiftly be adapted and expanded to be useful. The 2015 SDSR contained a commitment (paragraph 7.19) to establish a virtual National Security Academy to act as a hub “to share, develop and maintain critical knowledge and skills across the national security community”. This has not yet been implemented. The COVID-19 pandemic has reinforced the need for such an institution – a National Security and Resilience College. This could address both these issues, through developing a broader national security community, drawing (and learning) from a more diverse range of expertise. The new COVID-19 Learning and Development Programme could form part of its initial curriculum.
22. Security risk assessments, and policy and contingency planning for future pandemics will require broader inputs from Government, civil society, academic and private sector organisations, and from a wider range of experts, to reflect the whole-of-society risks that have been exposed by COVID-19. The severe impact of the disease on people with pre-existing health conditions and on BAME frontline workers and citizens has highlighted the relatively greater risk arising from features of UK society that have not until now been taken in to account in national security risk assessments. The impact of the COVID-19 pandemic and of subsequent economic disruption by socio-economic group, ethnic group, gender, disability and other intersectional at risk groups needs also to be understood and built into future planning.
D. Roles and responsibilities of the National Security Council, and Government departments and agencies, with respect to biosecurity risks
23. The principal role of the National Security Council is to set strategy and to formulate policy. Crisis response is appropriately managed through COBR or an adapted Cabinet Office-chaired committee. In any future inquiry about Government performance in the COVID-19 pandemic, scrutiny of the National Security Council’s contribution will need to focus on the nature of the Government’s strategy for pandemics, and the impact of underlying strategic assumptions on preparedness.
24. The Biological Security Strategy set out a reporting obligation by a “cross-Government director-level governance board”, comprising representatives of eight Government departments, a number of agencies, the Cabinet Office and the Devolved Administrations, to the Threats, Hazards, Resilience and Contingencies Subcommittee of the National Security Council. It is not yet clear how this reporting obligation has been performed up to and during the COVID-19 pandemic.
25. Although successive national security strategies have required Government departments to report back on implementation, the Cabinet Office has tended to focus on conventional national security issues. The Department of Health & Social Care has generally been left with the discretion to follow up on biosecurity risks. This must change as the risk of disease outbreaks has been realised during 2020.
26. Ministers need to be supported by the best national, regional and local expertise to take decisions and keep them constantly under review in the light of horizon scanning and short, medium and long term plans and objectives. For these reasons, the key generic capabilities and resilience capability framework set out in the Civil Contingencies Act 2004 are designed to address the problems to be solved, usually regardless of how the crisis has been caused. For example, Operation Yellowhammer – which required the NHS to prepare for a “no deal” BREXIT on top of winter flu planning – enabled several NHS bodies and their local partners to cope with COVID-19 better than they otherwise would have. This illustrates how the right institutional framework combined with timely political focus can bring positive results.
27. National security strategies, and contingency plans, cannot be expected to fit exactly the situation that emerges in a given crisis. Political leadership is indispensable for recognising the gaps, and deciding how they can best be filled.
Head of Global Strategies Project at LSE IDEAS
London School of Economics and Political Science
18 June 2020