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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Flood and Floods Management and Safety Policy

1. Purpose

The purpose of this policy is to ensure that {{org_field_name}} identifies, assesses, manages and, so far as is reasonably practicable, mitigates risks arising from flooding and associated disruption to the premises, utilities and care service.

{{org_field_name}} will maintain arrangements designed to protect the health, safety, welfare and continuity of care of people we support, staff and other persons who may be affected by flooding.

Flood planning and emergency arrangements will form part of the service’s wider risk management, health and safety and business continuity systems. Arrangements will be proportionate to the flood risks associated with the location and premises and to the individual needs and dependencies of people we support.

This policy is intended to support compliance with the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, including Regulation 12 (Safe care and treatment), Regulation 15 (Premises and equipment) and Regulation 17 (Good governance), together with applicable CQC statutory notification requirements and health and safety legislation.

2. Scope

This policy applies to all relevant premises operated by {{org_field_name}}, all staff, agency workers, contractors where applicable, and all people we support who may be affected by flooding or associated disruption.

It covers:

• identification, assessment, monitoring and mitigation of site-specific flood risks;
• arrangements for monitoring flood warnings and severe weather information where relevant;
• preventive and protective measures appropriate to the assessed level of flood risk;
• emergency response arrangements;
• procedures for evacuation, sheltering in a safer part of the building or temporary relocation;
• individual arrangements for people whose mobility, cognition, communication, behaviour, medical condition or other needs may affect their safety during an emergency;
• arrangements for maintaining essential care, treatment, medicines, nutrition, hydration and clinical support during disruption;
• maintaining essential utilities, equipment, communications and environmental conditions, or implementing suitable contingency arrangements when these cannot be maintained;
• business continuity and alternative accommodation arrangements where the premises cannot safely continue to be used;
• communication with people we support, representatives, staff, emergency services, commissioners, local authorities and other relevant organisations;
• protection and availability of essential care records and other information required for continuity of care;
• statutory reporting and notification requirements, including notifications to the Care Quality Commission where applicable;
• staff instruction, training and exercises appropriate to employees’ responsibilities; and
• post-incident assessment, recovery, investigation and learning.

3. Legal and Regulatory Framework

This policy will be implemented in accordance with applicable legislation and regulatory requirements, including:

• Health and Social Care Act 2008, including the statutory framework governing regulated health and social care activities in England.
• Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, Regulation 12 – Safe care and treatment. Care and treatment must be provided safely. This includes assessing risks to the health and safety of people receiving care and doing all that is reasonably practicable to mitigate identified risks. The service must also have appropriate arrangements to respond to major incidents and emergency situations affecting safe care.
• Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, Regulation 15 – Premises and equipment. Premises and equipment used in providing the regulated activity must be clean, secure, suitable for their purpose, properly used, properly maintained and appropriately located.
• Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, Regulation 17 – Good governance. Effective systems and processes must be established and operated to assess, monitor and improve the quality and safety of services, assess and mitigate risks to people we support and others, and maintain appropriate records.
• Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, Regulation 18 – Staffing, where applicable to ensuring that staff have appropriate support, training, professional development, supervision and appraisal necessary to carry out the duties they are employed to perform.
• Care Quality Commission (Registration) Regulations 2009, Regulation 18 – Notification of other incidents. The registered person must notify CQC without delay of incidents specified by the regulation, including events that prevent, or appear likely to threaten to prevent, the service provider’s ability to continue to carry on the regulated activity safely or in accordance with registration requirements.
• Health and Safety at Work etc. Act 1974. {{org_field_name}} must, so far as is reasonably practicable, protect the health, safety and welfare of employees and persons other than employees who may be affected by its undertaking.
• Management of Health and Safety at Work Regulations 1999. Suitable and sufficient assessment of relevant health and safety risks must be undertaken and appropriate preventive and protective arrangements maintained, including procedures relating to serious and imminent danger.
• Flood and Water Management Act 2010, where its provisions are relevant to flood risk management arrangements and interaction with relevant flood risk management authorities.

The Civil Contingencies Act 2004 establishes emergency preparedness and civil protection duties for specified Category 1 and Category 2 responders. A care home provider is not, solely by reason of operating a care home, a Category 1 or Category 2 responder under that Act. However, {{org_field_name}} will co-operate as appropriate with local authorities, emergency services and other responder organisations when planning for or responding to flooding and other major incidents.

Applicable Environment Agency flood warnings, local authority emergency arrangements and other official emergency information will be taken into account when assessing risk and implementing this policy.

4. Related Policies

This policy is linked to other emergency and risk management policies within {{org_field_name}}, including:

• CH18 – Risk Management and Assessment Policy
• CH19 – Emergency and Business Continuity Plan
• CH16 – Health and Safety at Work Policy
• CH20 – Fire Safety and Evacuation Procedures
• CH25 – Notification of Other Incidents Policy

5. Policy Statement

{{org_field_name}} is committed to protecting the health, safety and welfare of people we support, staff and others who may be affected by flooding.

The service will take a risk-based approach to flood preparedness and response and will:

• identify foreseeable flood risks affecting the premises and service;
• maintain suitable and sufficient documented risk assessments;
• take reasonably practicable measures to eliminate or reduce identified risks;
• maintain arrangements for receiving and acting upon relevant flood warnings;
• maintain emergency arrangements proportionate to the location, premises and needs of people we support;
• ensure that individual needs and dependencies are considered when planning evacuation, relocation or sheltering arrangements;
• maintain, so far as reasonably practicable, continuity of safe care, medicines, essential equipment, food, hydration, staffing, communications and other essential services;
• ensure that premises and equipment remain safe and suitable before, during and following a flooding incident;
• involve emergency services, local authorities, commissioners, healthcare professionals and alternative providers where necessary to protect people and maintain continuity of care;
• ensure staff understand the emergency arrangements and are competent to perform the duties allocated to them;
• make required statutory notifications to CQC and reports to other relevant authorities; and
• review incidents, exercises and changes in risk so that appropriate improvements are implemented.

The safety and continuity of care of people we support will take priority over the protection of property or other assets.

6. Flood Risk Assessment and Prevention

{{org_field_name}} will maintain a documented, site-specific flood risk assessment where flooding is a reasonably foreseeable risk to the premises or service.

The assessment will consider, as applicable:

• whether the premises are within or near an area at risk of river, coastal, surface water, groundwater or reservoir flooding;
• Environment Agency and other relevant flood risk information;
• previous flooding of the premises or surrounding area;
• local drainage arrangements and known drainage problems;
• access and egress routes that may become inaccessible;
• the location and vulnerability of electricity, gas, water, sewerage, heating, communications and other essential services;
• the location of medicines, medical devices, mobility equipment, food, records, hazardous substances and other essential supplies;
• the safety of lifts or other equipment that may become unavailable during flooding or electrical failure;
• the individual needs of people we support, including mobility, cognition, communication, sensory impairment, medical conditions, dependency on electrically powered equipment and the assistance required for safe evacuation or relocation;
• staffing requirements during an emergency;
• the potential need for evacuation, internal relocation or alternative accommodation; and
• foreseeable consequences of interruption to utilities, access, staffing, medicines, clinical services or supplies.

Identified control measures will be proportionate to the assessed risk and may include:

• maintaining gutters, drains and downpipes for which the service is responsible;
• protecting vulnerable entrances and other points at which water may enter;
• locating essential equipment, medicines, records and supplies away from areas reasonably likely to flood;
• maintaining access to appropriate flood protection equipment where identified by the risk assessment;
• protecting essential electrical or other equipment where reasonably practicable;
• identifying safe areas within the premises where temporary internal relocation may be appropriate;
• identifying alternative evacuation routes where normal routes may be affected; and
• establishing appropriate arrangements with landlords, building owners, contractors, utility providers, local authorities, commissioners or neighbouring services.

Flood risk assessments will be reviewed:

• at planned intervals determined by risk;
• following a flooding incident or significant near miss;
• following a material change to the building, drainage, utilities, access arrangements or use of the premises;
• where new information indicates that the flood risk has materially changed; and
• where monitoring, an exercise, audit or incident identifies that existing controls may no longer be effective.

Actions identified by the assessment will be allocated to a responsible person, recorded and monitored to completion.

7. Emergency Response Plan

a. Activation and Command Arrangements

The Registered Manager will ensure that clear arrangements are established for managing a flooding emergency.

A competent person will be identified to co-ordinate the immediate response. A deputy or alternative competent person will be identified for circumstances in which the nominated person is unavailable.

The emergency plan will identify:

• who has authority to activate the plan;
• arrangements for contacting emergency services;
• internal escalation and management arrangements;
• emergency contact details;
• arrangements for contacting staff and obtaining additional support;
• arrangements for contacting people we support, representatives and relevant professionals where appropriate;
• arrangements for communication with local authorities, commissioners and alternative care providers; and
• the location of emergency information needed to maintain continuity of care.

b. Flood Warnings and Escalation

Where relevant to the service’s assessed flood risk, designated staff will monitor appropriate Environment Agency flood warnings, severe weather warnings and information issued by relevant local agencies.

On receipt of a relevant warning or evidence of imminent flooding, the person in charge will assess the risk and activate appropriate elements of the emergency plan without unnecessary delay.

Actions may include:

• informing staff and allocating emergency duties;
• checking the safety and availability of evacuation routes;
• ensuring that essential medicines, care records, emergency contact information, medical devices and supplies can be readily accessed;
• moving people we support from areas at immediate risk where this can be undertaken safely;
• implementing flood protection measures identified by the risk assessment;
• checking staffing, transport and alternative accommodation arrangements;
• contacting emergency services or relevant authorities where necessary;
• protecting essential equipment and supplies where this can be done without exposing staff or people we support to danger; and
• preparing for evacuation or relocation where continued occupation may become unsafe.

Staff must not enter floodwater or undertake actions that place themselves or others at unreasonable risk.

Electricity, gas, water or other utilities will only be isolated where this is necessary and can be done safely by a person competent or authorised to do so. Staff must not attempt unsafe electrical or utility isolation.

c. Evacuation, Internal Relocation and Alternative Accommodation

The decision to evacuate, internally relocate or continue to shelter safely within the premises will be based on the circumstances of the incident, advice from emergency services where available, and the assessed needs of people we support.

The emergency arrangements will identify, so far as reasonably practicable:

• primary and alternative evacuation routes;
• safe assembly or transfer locations;
• arrangements for people who require mobility assistance;
• appropriate moving and handling equipment;
• arrangements for people with cognitive impairment, dementia, learning disability, autism, sensory impairment, communication needs or behaviours that may affect evacuation;
• arrangements for people who require oxygen, electrically powered medical equipment or other essential clinical support;
• transport requirements, including accessible transport where necessary;
• staffing and supervision requirements;
• essential medicines and medication administration information;
• essential care plans, risk assessments and emergency healthcare information;
• nutrition and hydration requirements;
• arrangements for maintaining dignity, privacy and safeguarding during evacuation and relocation;
• arrangements for maintaining contact with representatives where appropriate; and
• arrangements with suitable alternative accommodation providers, commissioners, local authorities or other organisations where temporary relocation may be required.

Where a person may lack capacity to make a relevant decision, any decision taken on their behalf will be made in accordance with the Mental Capacity Act 2005 and applicable legal requirements.

A record will be maintained of people evacuated or relocated, their destination and the staff accompanying them so that people can be accounted for throughout the incident.

d. Emergency Services

Where there is an immediate threat to life or serious risk to health or safety, emergency services will be contacted without delay.

Instructions from the emergency services concerning immediate safety and evacuation will be followed unless doing so would create a clear and immediate additional danger that must be brought to their attention.

8. Business Continuity Planning

Flood risk will be incorporated into {{org_field_name}}’s business continuity arrangements.

The Registered Manager will ensure that suitable contingency arrangements are identified for foreseeable disruption that could prevent safe delivery of care.

Business continuity arrangements will address, as applicable:

• loss or restriction of access to the premises;
• damage to accommodation or areas used to provide care;
• interruption of electricity, gas, water, sewerage, heating, telephone, internet or other essential services;
• failure or unavailability of essential equipment;
• interruption to medicines supplies;
• interruption to food and drinking water supplies;
• staffing shortages or inability of staff to reach the service;
• interruption to clinical or healthcare support;
• disruption to waste arrangements;
• loss of access to paper or electronic records;
• emergency transport requirements; and
• temporary or longer-term alternative accommodation.

Alternative power supplies, generators, battery systems or other resilience measures will be provided where the service’s risk assessment identifies that they are necessary to maintain safe care. Any generator or alternative power equipment used by the service must be suitable for its intended purpose, maintained appropriately and operated safely by competent persons.

Essential information required to continue care must remain accessible during an emergency. Appropriate arrangements will be maintained for secure backup and recovery of electronic information and protection of essential paper records, in accordance with applicable information governance and data protection requirements.

Where people are transferred to another service, sufficient information will accompany or be securely transferred with them to enable the receiving provider to meet their immediate care and treatment needs safely.

The service will not resume normal use of flood-affected areas until the Registered Manager or other authorised person is satisfied, taking competent professional advice where necessary, that the premises, utilities and equipment required for care are safe, hygienic and suitable for use.

9. Staff Training and Awareness

Staff will receive information, instruction and training appropriate to their duties and responsibilities under this policy.

Staff who may be required to perform specific emergency functions will be provided with sufficient instruction, training and practical familiarisation to enable them to carry out those functions safely and competently.

Relevant training and instruction will include, according to role:

• how to raise the alarm and report a flooding risk;
• the service’s flood warning and escalation arrangements;
• emergency communication arrangements;
• individual assistance required by people we support;
• evacuation and internal relocation procedures;
• arrangements for maintaining essential medicines and care information;
• safe use of flood protection or emergency equipment where staff are expected to use it;
• circumstances in which emergency services must be contacted;
• the need to avoid unsafe entry into floodwater or unsafe interaction with electrical equipment;
• individual roles and responsibilities within the emergency plan; and
• arrangements for accounting for people we support during an evacuation or relocation.

New staff will be made aware of relevant emergency arrangements as part of their induction.

Emergency exercises or other suitable tests of the arrangements will be undertaken at intervals determined by the risks associated with the service. Exercises must not expose people we support or staff to unnecessary risk.

The Registered Manager will record relevant training and exercises and ensure that deficiencies identified through exercises, incidents or feedback are addressed.

10. Monitoring and Compliance

The Registered Manager will ensure that the flood risk management arrangements are monitored through the service’s governance and risk management systems.

Monitoring will include, where applicable:

• review of flood risk assessments;
• checks that identified control measures remain in place and effective;
• checks of emergency contact information;
• checks of emergency supplies and equipment;
• review of training and exercise records;
• review of business continuity arrangements;
• monitoring of outstanding risk-reduction actions;
• investigation and review of flooding incidents and significant near misses; and
• implementation and monitoring of improvement actions.

Flood-related incidents will be recorded and reviewed proportionately to their seriousness and potential impact. Where an incident exposes a person to harm or significant risk of harm, appropriate investigation, safeguarding, duty of candour, health and safety reporting and other statutory requirements will be considered and applied as required.

Records relating to flood risk assessments, incidents, exercises, decisions, actions and statutory notifications will be retained securely in accordance with {{org_field_name}}’s records management arrangements.

Where flooding or associated disruption creates an event that must be notified to CQC under the Care Quality Commission (Registration) Regulations 2009, the registered person will ensure that the appropriate statutory notification is made within the required timescale.

11. CQC and Other Statutory Notifications

The Registered Manager and registered provider will ensure that flooding incidents and associated disruption are assessed promptly to determine whether a statutory notification or report is required.

Under Regulation 18 of the Care Quality Commission (Registration) Regulations 2009, the registered person must notify the Care Quality Commission without delay of applicable incidents occurring while regulated services are being provided, or as a consequence of carrying on the regulated activity.

A flood or associated incident must be considered for CQC notification where it prevents, or appears likely to threaten to prevent, {{org_field_name}} from continuing to carry on the regulated activity safely or in accordance with registration requirements.

This includes, where applicable:

• physical damage to premises used for carrying on the regulated activity where the damage has, or is likely to have, a detrimental effect on the treatment or care provided to people we support;
• interruption of electricity, gas, water or sewerage to premises used by the service where the interruption lasts for more than a continuous period of 24 hours;
• failure or malfunction of relevant safety devices lasting for more than a continuous period of 24 hours;
• insufficient suitably qualified, skilled and experienced staff where this prevents or threatens to prevent the service from operating safely; or
• another flood-related event that prevents or appears likely to threaten the service’s ability to continue the regulated activity safely.

Other consequences of a flood must also be assessed against the full range of statutory CQC notification requirements. These may include, depending on the circumstances:

• death of a person using the service;
• serious injury;
• abuse or an allegation of abuse;
• an incident reported to or investigated by the police; or
• another event specified by the applicable registration regulations.

Notifications will be made using the current CQC-approved notification process and within the statutory timescale applicable to the event.

Where the legal requirement is to notify CQC “without delay”, notification must not be postponed until the incident investigation has been completed.

A record of the notification, the date submitted, information supplied, CQC acknowledgement or reference number and any subsequent correspondence will be retained.

Flood incidents will also be reported to other statutory bodies where separate reporting requirements apply, including the Health and Safety Executive, local authority, safeguarding authority, emergency services or other relevant body, according to the circumstances and applicable legal requirements.

12. Responsibilities

Registered Provider

The registered provider has overall responsibility for ensuring that appropriate governance systems are in place to manage foreseeable flood risks and that the service complies with applicable legal and regulatory requirements.

The registered provider will ensure that adequate resources and organisational arrangements are available to implement necessary flood risk controls and emergency arrangements.

Registered Manager

The Registered Manager is responsible for the day-to-day implementation of this policy and will ensure that:

• appropriate flood risk assessments are completed, reviewed and acted upon;
• emergency and business continuity arrangements are maintained;
• individual needs of people we support are reflected in emergency planning;
• staff receive appropriate information, instruction and training;
• emergency exercises and reviews are undertaken where required by the service’s risk assessment;
• relevant premises, equipment and emergency arrangements are monitored;
• incidents are recorded, reviewed and investigated appropriately;
• required statutory notifications and reports are made within the applicable timescales; and
• identified improvement actions are implemented and monitored.

Where responsibility for submitting a CQC notification is delegated, the Registered Manager and registered provider remain responsible for ensuring that the notification is made correctly and within the required timescale.

Person Co-ordinating the Flood Response

The person designated to co-ordinate a flooding incident will:

• assess the immediate situation;
• activate relevant emergency procedures;
• seek emergency assistance where required;
• co-ordinate staff actions;
• support the safe evacuation, relocation or protection of people we support;
• maintain communication with relevant persons and organisations; and
• maintain an appropriate record of significant decisions and actions during the incident.

A deputy or alternative competent person will be identified wherever practicable.

Staff

All staff must:

• follow this policy and associated emergency procedures;
• take reasonable care for their own health and safety and that of others;
• report flood risks, defects, incidents and concerns promptly;
• follow instructions given during an emergency;
• undertake duties for which they have been trained and which it is safe for them to perform;
• support people we care for in accordance with their individual needs and emergency arrangements; and
• not place themselves or others at unnecessary risk by entering floodwater, interfering with unsafe electrical equipment or undertaking activities outside their competence.

13. Consequences of Non-Compliance

Failure to comply with applicable flood risk management, emergency preparedness or statutory notification requirements may place people we support, staff and others at risk and may constitute a breach of health and social care or health and safety legislation.

Depending on the circumstances, consequences may include:

• regulatory action by the Care Quality Commission;
• prosecution where the relevant legislation creates an offence;
• enforcement action by another competent statutory authority;
• requirements to make improvements to risk management, premises or service arrangements;
• civil liability;
• contractual consequences; and
• action under {{org_field_name}}’s employment procedures where an individual employee has failed to follow a reasonable instruction, policy or procedure and such action is appropriate following proper investigation.

Failure by a registered person to make a statutory CQC notification when required may constitute an offence and may result in regulatory or enforcement action.

Any suspected non-compliance will be investigated proportionately, and immediate action will be taken where necessary to protect people we support and others from harm.

14. Policy Review

This policy will be formally reviewed at least annually and sooner where necessary.

An earlier review will be undertaken where there is:

• a relevant change in legislation, regulation or statutory guidance;
• a material change to CQC requirements affecting this policy;
• a significant change to the premises or service;
• a change in the known flood risk affecting the location;
• a flooding incident or significant near miss;
• a failure or deficiency identified through an emergency exercise;
• a material change to the needs or dependency of people using the service where this affects emergency arrangements;
• an identified weakness in business continuity arrangements; or
• learning from an incident, investigation, audit or regulatory assessment that indicates that the existing policy or procedures are no longer adequate.

The Registered Manager will ensure that changes arising from a review are communicated to relevant staff and incorporated into risk assessments, emergency arrangements, training and other associated documents where necessary.

Records of reviews and material amendments will be maintained in accordance with {{org_field_name}}’s governance and document control arrangements.

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Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
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