Policy for the Administration of Insulin to Adults with Stable Type 2 Diabetes by a Senior Healthcare Support Worker

Transcription

1 Policy for the Administration of Insulin to Adults with Stable Type 2 Diabetes by a Senior Healthcare Support Worker Reference No: Version 2 Ratified by: P_CS_34 LCHS Trust Board Date ratified: 29 th July 2014 Name of originator / author: Lisa Green Deputy Chief Nurse Name of responsible committee / Individual LCHS Quality Scrutiny Group Date issued: 7 July 2015 Review date: July 2016 Target audience: Community Teams Distributed via Website 1

2 Policy for the Administration of Insulin to Adults with Stable Type 2 Diabetes by a Senior Healthcare Support Worker Version Control Sheet Version Section / Para / Appendix Version / Description of Amendments Date Author / Amended by 1 New Policy July 2014 Lisa Green 1.1 Sections 3/4/5/6/7, Appendices 1 and 2 Minor amendments and updates re: adrenaline guidelines added and inclusions re-worded for clarification January 2015 S Ombler 2

3 Sections 4.0 Section 5.0 Added patient over 18years. Added specific criteria Added patient under 18 yrs May 2015 Petra Clarke Rosemary Coffey 7.0 Clarification of stable patient within documented notes of each patient References Appendix 1 Element 3 a Element 6 Element 10 Final Assessment record Appendix 2 Added The HCSW should be supervised on at least 3 occasions administering insulin for each patient before final assessment of competency. Updated link for patient safety suite Added target blood sugars for named patient Added RN to assess named patient on weekly basis Added U100 syringe And insulin vial Added NHS number Added patients NHS number 3 Copyright 2015 Lincolnshire Community Health Services NHS Trust, All Rights Reserved. Not to be reproduced in whole or in part without the permission of the copyright owner 3

4 Policy for the Administration of Insulin to Adults with Stable Type 2 Diabetes by a Senior Healthcare Support Worker Version control sheet Policy document statement Contents 1.0 Introduction and background Scope and Purpose Objectives Inclusion criteria Exclusion Criteria Responsibilities Individual Staff Responsibilities Executive Directors responsibilities Responsibilities of the Senior HCSW Responsibilities of the Registered Nurse Delegation of Care Risk management Training Requirements Competencies Maintaining Competencies References Appendix 1 - Competency Framework Appendix 2 Record of observation of insulin administration by Senior HCSW

5 Policy for the Administration of Insulin to Adults with Stable Type 2 Diabetes by a Senior Healthcare Support Worker Policy Document Statement Background Evidence suggests that the incidence of type 2 diabetes is rising, and the success of implementing evidenced based treatment has meant that more people with type 2 diabetes will be treated with insulin (DOH 2002). However, for some adult individuals who require insulin this may mean difficulty in administering the required injection(s) independently. Statement This policy aims to provide guidance to Lincolnshire Community Health Services workforce, registered and unregistered, who provide care to adults who have stable type 2 diabetes in the community, and who require assistance with insulin administration. It has been developed to ensure best practice Responsibilities Compliance with the policy will be the responsibility of all Lincolnshire Community Health Services staff. Directors/Heads of Service are responsible for making policy authors aware of the development and management process of all policy documents to be adopted by Lincolnshire Community Health Services. Dissemination Website Resource implication The delivery and implementation of this policy will be delivered within existing resources of the Project Management Office, the Business Units and the Clinical Development Team. Consultation Consultation has been undertaken through the business units, with the Diabetes Nurse Specialist team, the Medicines Manager, the Medical Director, the Director of Nursing and through the Workforce & Organisational Strategy group. 5

6 1.0 Introduction and background Evidence suggests that the incidence of type 2 diabetes is rising, and the success of implementing evidence based treatment has meant that more people with type 2 diabetes will be treated with insulin (DOH 2002). In June 2010 the National Patient Safety Agency (NPSA) issued the rapid response alert Safer Administration of Insulin and reported that insulin administration errors occurred due to three mains reasons: 1. Using the wrong insulin product 2. Omitted or delayed insulin dose 3. Wrong insulin dose Omission or delay of insulin has been identified to be one of the main causes of adverse patient incidents with insulin. The reports highlights that some insulins need to be taken at a mealtime, so the timing of insulin in relation to food can be critical. The risks occur when the patient s insulin is given too early or too late in relation to food. The development of insulin devices has meant that more people are able to manage their own care and live more independent lives. However, for some adult individuals who require insulin this may mean difficulty in administering the required injection(s) independently. Historically, individuals who are unable to self-administer insulin are supported to do so either by relatives or a Registered Nurse. However, in order to enable community nursing teams to manage the care of such people, it has been identified that suitably trained Senior Health Care Support Workers (Senior HCSW) could administer insulin to those individuals whose diabetes is stable and where all other avenues to assist in enabling and supporting independence have been exhausted. 2.0 Scope and Purpose The document has been written specifically to provide community nursing teams with a framework to enable delegation by a Registered Nurse of the task of safe insulin administration to a suitably trained Senior Health Care Support Worker. The need to implement this procedure should only be undertaken when all other avenues of patient self-administration have been considered and assessed as not possible. Not all Healthcare Support Workers will be expected to have competence in administering insulin. Those who will be expected to administer insulin must evidence competence for each patient for whom the care has been delegated. In order to reduce risk, the policy will be instigated on a named patient bases and when the patient is on stable dose of insulin (not altered in last 2 months) with an agreed care plan. This policy is to be read in conjunction with the following LCHS Policies: Administration of Insulin Injections Guidelines and Procedures Blood Glucose Monitoring Policy 6

7 Hypoglycaemia Recognition and Treatment Guidelines 3.0 Objectives 3.1 To outline the responsibilities, training and competencies required to enable delegation of insulin administration to Senior HCSWs. 3.2 To provide a safe framework for the Senior HCSW, supervising Registered Nurse and patient in the administration of an insulin injection. 3.3 This policy defines the requirements for safe and effective delegated administration of insulin. 3.4 This policy sets out the full hierarchy of accountability and responsibility for ensuring this procedure is administered safely with reviews and monitoring at least weekly. 3.5 This policy provides guidance to all registered nurses and Senior HCSWs employed by Lincolnshire Community Health Services Trust (LCHS) who administer insulin to patients 18 years old and over. 4.0 Inclusion criteria The following criteria must be met before considering delegation of care to a Senior HCSW: The patient has Type 2 diabetes. Patient is 18 years or over. The patient must be delegated on a name patient only The insulin to be administered is contained within an insulin vial. The patient s diabetes is deemed stable by GP, diabetes specialist team or District Nurse Case Manager. A patient can be described as stable where the patient s treatment regime has remained unchanged for 2 months and blood glucose are stable for that individual named patient. The blood glucose range for the named patient will be explicit in care plan. In the event of hospital discharge there will be reassessment by Registered Nurse before delegation to SHCSW support. If all of the above criteria are met then The HCSW must then be assessed as competent by their RN Mentor to undertake the procedure to that named patient. Appendix 1 competency framework and Appendix 2 Record of Observation must be completed and HCSW assessed as competent for each individual patient. The delegating Case Manager/Team Leader will retain overall responsibility and a accountability for the safety of the named patient 5.0 Exclusion Criteria People will not be considered for this type of care if: 7

8 They have been diagnosed with type 1 diabetes. Insulin can not be drawn up and given from insulin pen or cartridge Patient is under the age of 18 years Insulin treatment has been initiated within the past six months. Potential for self-care is still evident. There is a risk that the patient could become unstable. If insulin type is changed during the period of transition until patient is stable. There is evidence of other chronic illness and unstable diabetes that may indicate that the patient will have complex care needs. The nursing team is not able to support the delegation of care and weekly visit assessment and monitoring of patient by registered nurse 6.0 Responsibilities 6.1 Individual Staff Responsibilities It is the responsibility of every Registered Nurse and Senior HCSW employed by Lincolnshire Community Health Services who administer or wish to undertake insulin administration to patients to be familiar with this and related policy and procedure. There will be an expectation from both to evidence relevant training and competency in the task. 6.2 Executive Directors responsibilities It is the responsibility of the Director of Nursing and the Medical Director to officially sign this document before it is approved and implemented. 6.3 Responsibilities of the Senior HCSW The Senior HCSW will be expected to: Maintain a portfolio of evidence of competence. Revisit and have competencies signed off every year. Work within competency and refer to the Registered Nurse as necessary. Evidence competence for each patient for whom the care has been delegated. Access in house Senior HCSW and diabetes training programme every 2 years. Attend regular supervision/support sessions with the District Nurse or Registered Nurse (at least every three months). Complete documentation in the patient s home when injection completed and SystmOne notes as per insulin administration policy and in line with NMC Recording Keeping Standards. Treat individuals, for whom they have responsibility, to the best of their ability. 6.4 Responsibilities of the Registered Nurse 8

9 The Registered Nurse will be expected to support individual Senior HCSWs to attain and maintain competence. Registered Nurses involved in the administration of subcutaneous injections and management of patients with diabetes will be responsible for maintaining and updating their knowledge and practice (NMC 2008). Registered Nurses administering any medicines, assisting with administration or overseeing any self-administration of medicines must exercise professional judgement, apply knowledge and recognise their professional accountability as per NMC Standards for Medicines Management (2008). They must maintain a portfolio of evidence of competence. The Registered Nurse must be assured that the Senior HCSW has acquired the knowledge outlined in the training section of this document and that this is evidenced in line with the competency framework. It is the responsibility of the Registered Nurse to explain to the patient when undertaking the initial supervised visit that the HCSW, as part of their role, will be undertaking administration of the patient s insulin, having undertaken training to enable them to do so. The nurse will clarify that the HCSW will be fully supported by the Registered Nurse /Team who will remain responsible for his/her nursing care, and they will review this on a regular basis or should their medical condition change in any way. 6.5 Delegation of Care Delegation of care can be defined as `the entrusting of a task to another person' and can support successful team working. Registered Nurses retain accountability and responsibility for care where a decision to delegate care is taken. A nurse should only delegate an aspect of care to a person who has had appropriate training and whom they deem competent to perform the task. When a nurse is delegating they must be assured that the person to whom they have delegated (the Senior HCSW) fully understands the nature of the delegated task, particularly in relation to what is expected of them. The Senior HCSW remains accountable for their actions and is responsible for the task they undertake. They must not work beyond their level of competence. (NMC 2007) They are not able to delegate care to another member of staff. 7.0 Risk management Wrong administration of insulin, leading to patient harm, is a never event within the NHS. (The never events policy framework - An update to the never events policy, DOH 2012) All adverse incidents and significant untoward events are to be reported by normal reporting arrangements and communicated to all involved in the patient s care immediately. Should a drug error occur, or the Senior HCSW competency is in question, then the procedure will be stopped immediately. All LCHS staff involved in the administration of and/or delegation of insulin administration must be fully trained and assessed as competent to carry out this task. 9

10 In line with Lincolnshire Community Health Services policies:- Registered Nurses are required to carry and be trained in the administration of emergency use adrenalin. Senior Health Care Support Workers are not required to carry or be trained in the use of adrenalin and have defined baseline anaphylaxis training delivered at annual mandatory training. The patient will be seen and reviewed by a Registered Nurse at least once per week, ensuring adequate supply of insulin and correct insulin syringes. Senior HCSW must demonstrate competency to the required standard for each individual patient before care can be given unsupervised. Therefore insulin is only administered to patients on a named patient basis. Competencies (see Appendix 1) should be assessed and met within 3 months of this training if not achieved then refresher training by Diabetes Specialist Nurse or suitable experienced Registered Nurse will be required In order to reduce the risk of patient harm delegation of insulin administration is on a named patient basis only. Insulin is not to be administered where the insulin dose that has been prescribed using the abbreviation u or iu instead of the full word unit. Target blood glucose monitoring - acceptable and stable ranges are to be decided and documented for each patient. If the patient s blood glucose level is outside the agreed level then the Senior HCSW will not administer the insulin but must contact the Registered Nurse immediately All LCHS staff members who, as part of their role prescribe, prepare, handle or administer insulin will access the Safe Use of Insulin elearning package to ensure up to date knowledge and practice every 2 years. Accessed via Training Requirements Prior to commencing the Insulin Administration:- The Senior HCSW will have completed Blood Glucose Monitoring training and have completed and achieved the Blood Glucose Monitoring competency standards. The Senior HCSW will undertake a programme of study which will involve a study session for underpinning theoretical knowledge and then assessment of knowledge and competences through assessment in a learning environment and in practice. 9.0 Competencies The competency document is patient specific. 10

11 The competencies required to support safe delivery of insulin by the Senior HCSW are defined in competency standards framework (Appendix 1). The HCSW must evidence competency separately for each patient that he/she delivers the care to. The HCSW cannot practice the task independently until they have been assessed as competent to do so for each individual patient, The HCSW should observe the administration of insulin by a registered nurse on a minimum of two occasions The HCSW should be supervised on at least 3 occasions administering insulin for each patient before final assessment of competency. (Appendix 2). At the end of the Insulin Administration education programme, the Senior HCSW will have knowledge of: Diagnosis and treatment of type one and type 2 diabetes. Dietary recommendations for people with diabetes. The action of insulin, the different types of insulin and their duration of action. The causes, signs, symptoms and treatment of hypoglycaemia. The causes, signs, symptoms and treatment of hyperglycaemia. How insulin should be stored, and equipment used. The preparation of insulin using a syringe. Preparing the patient for the injection of insulin. How to perform the injection of insulin. How to dispose of sharps/syringes, according to LCHS policy. Be aware of the procedure for recording and reporting of needle stick injuries. Demonstrate accurate legible documentation and record keeping in line with LCHS policy. How to report identified problems to the appropriate persons Maintaining Competencies Senior HCSW must participate in on going supervision and assessment by the mentor /Registered Nurse and to complete reassessment of competence yearly. Senior HCSW and Registered Nurses will attend appropriate in house training sessions annually. Completion of the Safe Use of Insulin elearning package will be included within the training package. If it has been completed prior to the course by either Senior HCSW or Registered Nurse, evidence of prior completion will be required. If completed more than 12 months ago or no evidence available, it will expected to be completed within the Insulin Administration training. Competence in this area of practice must be achieved within a three month period following the theoretical component of the training. 11

12 Competency must be maintained by performing the procedure on a regular basis. If not undertaken at least twice in one month the Senior HCSW is responsible for informing the Registered Nurse and must arrange to reassess the competencies against the named patient. References NMC (2008) The Code Standards of Conduct, Performance and Ethics for Nurses and Midwives NMC (2008) Standards for Medicines Management, Record keeping Safer administration of insulin Reference number 1243Central Alert System (CAS) reference NPSA/2010/RRR013 Issue date16 June 2010 Department of Health / Patient Safety (October 2012) the Never Events Policy Framework - an update to the Never Events Policy NHS Diabetes Healthcare e-academy The Insulin Safety Suite, Safe Use of Insulin elearning package LCHS policy for monitoring of blood glucose levels- CPS 030 LCHS Infection Prevention policy P_IPC01 LCHS Hand hygiene policy - Standards of Infection prevention and control precautions G_IPC 26 LCHS Infection and Prevention Control Guidelines - Sharps safe handling and use GuCPS035 LCHS Infection and Prevention Control reporting GulC003 NICE guidelines type 2 diabetes management CG 66 NICE guidelines long acting insulin analogues for the treatment of diabetes- insulin glargine TA53 NPSA Patient Safety First 2008 NICE guidelines type 2 diabetes: management of type 2 diabetes 2008 CG 87 DOH reference guide to consent for treatment of examination August 2009 MCA act 2005 MCA Code of Practice 2005 LCHS MCA and safeguarding policy 2014 The Royal College of Nursing (2006) Supervision, accountability and delegation of activities to support workers - A Guide for registered practitioners and support workers RCN London Policy for the administration of insulin of insulin to adults with stable type 2 Diabetes by a HCA - Heart of England NHS Foundation Trust 2014 Policy for the administration of insulin of insulin by a HSW United Hospitals of Stafford Trust

13 Appendix 1 - Competency Framework 3.0 COMPETENCY TITLE ADMINSTRATION OF INSULIN TO DEFINED STABLE PATIENTS AS DELEGATED BY A REGISTERED NURSE. ESR CODE COMPETENCY STATEMENT The safe administration of insulin via a needle and syringe to patients with stable type 2 diabetes requiring long term support and who are unable to self-administer. ELEMENT COMPETENCY STANDARD EVIDENCE TYPES SUPPORTING DOCUMENTS 1 2 Demonstrate a clear understanding of diabetes: its causes, symptoms and associated risks including hypoglycaemia and hyperglycaemia Understand the potential long term complications of diabetes Fully converse with the scope of practice within the Policy for Administration of Insulin able to define inclusion and exclusion criteria and circumstances and respond appropriately Understand why medication has been prescribed and the side effects Completion of Face to Face classroom training - Basic Awareness of Diabetes Questions and answers Reflective practice Supervised practice Witness statements Competency achievement Completion of blood glucose monitoring training Completion of hand hygiene competency LCHS Policy for Administration of Insulin by Senior HCSW LCHS policy for monitoring of blood glucose levels- CPS 030 LCHS Infection Prevention policy P_IPC01 Standards of Infection prevention and control precautions G_IPC 26 LCHS Hand hygiene policy 13

14 3 a) Describe the effect of insulin on blood glucose levels b) Be aware of the time interval required between injection and eating for the particular insulin being given c) Knowledge of common types of medication used in diabetes management and where to access information about these medications and effects/ side effects Able to demonstrate action needed if patient experiences any side effects of medications a) Aware of target blood sugars for each named patient b)signs, symptoms and treatment of hypoglycaemia (including if hypoglycaemia should occur at the same time injection due) c) Signs, symptoms and treatment of hypoglycaemia (including if hypo should occur at the same time as injection due). d) Appropriate, reporting and treatment of hyperglycaemia e) Appropriate reporting and recording of Completion of Face to Face classroom training - Basic Awareness of Diabetes DATIX training Supervised practice Question and answer LCHS Infection and Prevention Control Guidelines - Sharps safe handling and use GuCPS035 LCHS Infection and Prevention Control reporting GulC003 NICE guidelines type 2 diabetes management CG 66 NICE guidelines long acting insulin analogues for the treatment of diabetes- insulin glargine (TA 53) NPSA Patient Safety First 2008 NICE guidelines type 2 diabetes: management of type 2 diabetes 2008 CG 87 14

15 4 identified adverse effects. Able to demonstrate the dietary advice and support appropriate for the patient, to include checking when the patient plans to eat in relation to the timing of the insulin and when it may be appropriate to check blood glucose (individual to the patient) Understand how the dietary needs of the diabetic patient may change during periods of illness and the potential for this to cause instability. MUST training Reflective practice NVQ unit Level 3 CHS optional units 29 Questions and Answers DOH reference guide to consent for treatment of examination August 2009 MCA act 2005 MCA Code of Practice 2005 LCHS MCA and safeguarding policy 2014 NMC Code of Conduct Medicines and Record Keeping 5 6 Demonstrates the correct procedure for undertaking a finger prick blood glucose test as per LCHS policy (see competency ) Able to explain the procedure to the patient using an appropriate communication style. Gains patients consent to the procedure and patient is aware that registered nurse will visit weekly. Blood glucose monitoring training Blood glucose monitoring competencies achieved NVQ Level 3 CHS optional units 47 Information governance e training NVQ unit Level 3 CHS optional units 29 Can describe and provide examples of the MCA and safeguarding issues in practice. On-line BNF Medicine.org.uk Manufacturers specific product characteristics leaflet 7 Is able to demonstrate and describe the correct NVQ unit Level 3 CHS optional units LCHS Safe and Secure 15

16 8 9 hand washing techniques and describe their understanding of sharps, waste, inoculation injury, personal protective equipment. Be able to understand their knowledge of what to do in the event of a sharps injury. Correctly demonstrates the preparation of equipment and the patient including choice of injection site (understand the need to refer to patient s records in relation to injection site and site rotation). In the event of lumps, atrophy and hypertrophy avoids area and reports to the registered nurse Makes checks which include:- a) Checking of the prescription for the dose required b) The insulin vial for correct type of insulin c) Manufacturers expiry date d) Recording the date when the dial was first opened e) To discard after 28 days of first use f) Ensure no foreign particles apparent g) For pre-mixed insulin roll several times for solution to appear milky 29 Completion of LCHS hand hygiene assessment Witness statement of practice DATIX training Completion of Face to Face classroom training - Basic Awareness of Diabetes Questions and answers Reflective practice Supervised practice Witness statements Competency achievement 100% accuracy in checking medication and administration Handling of Medicines P_CIG_04 LCHS :Policy for the Management of Medication Errors P_CIG_15 Diabetes.org.uk 16

17 Draw prescribed dose of insulin from vial using correct U100 needle and syringe using safe handling techniques: 10 a) Remove white plunger guard, then carefully remove orange needle cap b) Pull back plunger of the syringe to measure amount in units of air equivalent to the amount of insulin required c) insert needle into vial and push plunger in d) Pull plunger back to dose of units prescribed e) ensure no air bubble in syringe f) check correct dosage Demonstrate safe administration of insulin: Completion of Face to Face classroom training - Basic Awareness of Diabetes Questions and answers Reflective practice Supervised practice Witness statements Competency achievement 100% accuracy in checking medication and administration 11 a) Senior HCSW checks site is clean b) Correctly administers insulin subcutaneously at an angle of 90 degrees, injecting insulin slowly leaving the needle in the skin for a slow count for ten, withdrawing quickly c) Demonstrates application of pressure to bleeding point d) Safely disposes of used insulin needle 12 Can describe why accurate and timely Completion of Face to Face 17

18 documentation is important Correctly records insulin administration including dose, site, expiry date and route in the patients records/ SystmOne classroom training - Basic Awareness of Diabetes Questions and answers Reflective practice Witness statements 100% accuracy in recording medication administration FINAL ASSESSMENT RECORD HCSW NAME : PATIENT NHS NUMBER MENTOR / ASSESSOR NAME : MENTOR / ASSESSOR SIGN OFF SIGNATURE: DATE FINAL SIGN OFF: (This evidence must be presented initially and bi-annually to the registered nurse delegating responsibility) 18

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20 Appendix 2 Record of observation of insulin administration by Senior HCSW Record of witnessed insulin administration by Senior HCSW observed by Registered Nurse The Senior HCSW should be observed administering insulin on a minimum of three occasions over a two week period to a named patient. All of the competency standards in the Framework must be met for each named patient before the Senior HCSW can take on the insulin administration unsupervised. Competence in this area of practice must be achieved within a three month period following the theoretical component of the training. SENIOR HCSW NAME. PATIENT NHS number. NAME & DESIGNATION DATE COMMENTS OF RN 20

21 NHSLA Monitoring Template Appendix 3 Minimum requirement to be monitored Process for monitoring e.g. audit Responsible individuals/ group/ committee Frequency of monitoring/audit Responsible individuals/ group/ committee (multidisciplinary) for review of results Responsible individuals/ group/ committee for development of action plan Responsible individuals/ group/ committee for monitoring of action plan Achievement of SHCSW competencies Appraisal process ESR capture Documentation of competency framework Staff undertaking insulin administration. Team leads for SHCSW staff Annually aligned to appraisal HoCs / matrons team leads and mentors appointed for individual HoCs HoCs group Safe administration by SHCSW Incident reporting Datix/ SUI HoCs group Q&R 3 monthly initially following implementation of new policy HoCs Chief Nurse office Q&R Matron aligned to team Practitioner performance supported HoCs 21

22 Appendix 4 Equality Analysis Name of Policy/Procedure/Function* Policy for the Administration of Insulin to Adults with Stable Type 2 Diabetes by a Senior Healthcare Support Worker Equality Analysis Carried out by: Kirby Hussain Date: Equality & Human rights Lead: Kirby Hussain Date: Director\General Manager: Sue Cousland 22

23 A B C Briefly give an outline of the key objectives of the policy; what it s intended outcome is and who the intended beneficiaries are expected to be Does the policy have an impact on patients, carers or staff, or the wider community that we have links with? Please give details Is there is any evidence that the policy\service relates to an area with known inequalities? Please give details Responsibilities, training and competencies required to enable delegation of insulin administration to Senior HCSWs. To provide a safe framework for the Senior HCSW, supervising Registered Nurse and patient in the administration of an insulin injection. This policy defines the requirements for safe and effective delegated administration of insulin. This policy sets out the full hierarchy of accountability and responsibility for ensuring this procedure is administered safely with reviews and monitoring at least weekly. This policy provides guidance to all registered nurses and Senior HCSWs employed by Lincolnshire Community Health Services Trust (LCHS) who administer insulin to patients 18 years old and over. No None D Will/Does the implementation of the policy\service result in different impacts for protected characteristics? Yes No Disability x Sexual Orientation x Sex x Gender Reassignment x Race x Marriage/Civil Partnership x Maternity/Pregnancy x Age x Religion or Belief x Carers x If you have answered Yes to any of the questions then you are required to carry out a full Equality Analysis please complete section 2 The above named policy has been considered and does not require a full equality analysis Equality Analysis Carried out by: Kirby Hussain Date: 27 August 2014 Agreed by: Equality & Human Rights Lead: Yes Date: 27 August