Beyond the First Line of Defence
Generally considered a model of how to manage risk, the Three Lines of Defence model outlines how to manage the day to day risk, how to manage the more strategic risk, and how to objectively ensure all risk management is effective.
Over the last twelve months we have seen variations on this approach being taken by various governments, but as usual, the emphasis has been on the first line of defence; how do we react to what happened today?
Since COVID19 entered our lives in early 2020, State and Territory Governments have approached outbreaks in other jurisdictions in a very similar way. Close the Border - keep people out! Each Premier or Chief Minister has spoken about a need for public safety and a need to control the outbreak as they rely on their respective Chief Medical Officers' advice.
What has been very clear is that the risk appetite for each of these decision makers is different leading to variations in urgency around closing the border and the variation in duration of border closures.
Each government has stated that the health and safety of their population is the most important priority and have implemented plans which isolate vulnerable members of the community, such as the aged, from the wider community in their own jurisdiction.
After initial failures in many of the supporting processes, such as contract tracing and standards of quarantine, the controls have improved, but it has not consistently changed the approach of all states to lock downs and border closures as a first response. In some jurisdictions, Local Government Areas (LGA) and postcodes are now being used as a basis for lockdowns and for excluding people from entry, but this is far from the accepted norm in every jurisdiction.
In recent months the broader population has accepted this way of working as the introduction of vaccines has become the new hope of a way back to what we consider "normal".
The Aim of COVID19 Vaccinations
The government intent so far has been to protect our most vulnerable or at risk members of the community. Front line health workers, aged care residents and quarantine workers are being vaccinated first as they are vulnerable due to age, other chronic issues, or greater periods of potential exposure to the virus in its various strains.
By vaccinating front line health workers and quarantine workers the government is also minimising the likelihood of transmission to community members. Once this group has been vaccinated the next group of "at risk" community members will get their opportunity and so on until we achieve a level of immunisation known as herd immunity.
The aim of the vaccination program is to reduce the likelihood of positive cases leading to death or serious illness. It is also about keeping hospitals resources available should a new wave of infections break out or for any other of reasons that precious resources are needed.
The hope that continues to be created by our political leaders is that the roll-out of the vaccines will return us to something more like "normal". Normal for many means no more closures, business as usual, earning what we used to earn.
Unfortunately vaccines will not stop people catching or passing on the virus. What has been proven so far is that positive cases are more likely to become mild and positive individuals can isolate at home rather than in hospital and intensive care.
Does this mean the government has done its job?
In recent weeks the debate by our political leaders has shifted from total positive cases to only talking about community cases. In more recent days they are also including vaccination counts.
The usual blame game on numbers continues between the levels of government as the new figures are being released to demonstrate who is doing what in their respective jurisdictions. The usual morning press conference is now about the number of community cases, missing links and the number of vaccinations.
The media, and the opposition, has been slow to highlight the progress and the widening gap between the projected vaccinated total and the actual vaccinated total.
What we are not hearing about is the consequences of not getting the job done or importantly what happens if a state or territory falls behind the rest. This is the second line of defence!
To do this we need to be looking at vaccination rates. How many people per head of population have been vaccinated?
All states and territories know their vaccination rates as they already know the count and the population. What we have not been told by the state and territories doing the work is when we will reach herd immunity in each jurisdiction. Someone needs to say this out loud!
Premiers and Chief Ministers should be forecasting when they expect to be at 70%, 80% and 85%. They should be updating us on how many people will be vaccinated at the end of each month. Yes, it is early days and yes, there are teething issues, but surely they must know. If a jurisdiction expects to be much later than another then surely the Commonwealth has a role to play in bridging this gap.
As a starting point, on the first data available, lets look at the current state of vaccination rates per head of population:
- Northern Territory 3.5%,
- Tasmania 3.2%,
- Australian Capital Territory 3.0%,
- Western Australia 2.1%,
- Victoria & Queensland 1.7%,
- South Australia 1.6%, and
- New South Wales 1.5%.
The two jurisdictions with the greatest results have relatively small populations in relatively small, concentrated geographic locations. So what about the larger states? Surely they can do better?
Larger states or larger populations does not necessarily mean higher vaccination rates. We have heard already about the various challenges around an effective roll-out. These challenges vary state by state with one or more coming into play. The challenges include:
- Temperature requirements of the vaccination;
- Travel distance for and to the vaccine;
- Production and supply issues from the manufacturer;
- Political intrigue as the European Union withhold exports;
- COVID Hesitancy;
- Suitably available hubs; and
- Training for those who administer the "jab".
These are all real issues, but does it matter if the rates are different in each state?
Sound risk management requires consideration of what may happen so the impacts may be considered and planned for. A proven way to do this is to describe a scenario, as realistic as possible, and then look at the appropriate controls that may be used should the impact occur. So, lets consider the scenario where one or more states is way ahead of other states in their vaccination program.
Victoria (Vic) and New South Wales (NSW) have similar vaccination rates of 77% and 80% respectively whilst Western Australia (WA) struggles to get similar numbers, only at 40% due to challenges with distance, remote communities, bush fires, weather, logistics and suitably qualified health workers.
An outbreak occurs on the Northern Beaches of Sydney and WA introduces hotel quarantine for travellers from Greater Sydney immediately. So far this sounds routine.
The media ask the WA Premier, "But why Mr Premier?", NSW ask "But Why Mr Premier?" as business is impacted on, movement is restricted, livelihoods suffer and it feels like more of the same; hope is dashed!
The WA Premier reluctantly acknowledges that whilst the vaccination rates in NSW are higher, his advice is that travellers from the areas listed are still a risk to WA residents and the safety of WA residents is his number one priority. In another display of putting WA first he won't be "told" by anyone how to do his job.
For Greater Sydney residents, having a vaccination is not enough to stop this parochial grandstanding as borders close to them anyway.
Emerging Issue from the Roll-out?
There are three key issues of interest as we look forward to the roll-out of the state vaccination programs:
1. Will the states that are so quick to close their borders be the states that put the most effort to achieving herd immunity? Herd Immunity means less death and serious illness. Herd immunity equals incoming travellers. Herd immunity equals more economic activity.
2. Will industrial parks, logistics hubs, buildings in CBDs, be given special dispensation to travel, by government, if they achieve high rates of herd immunity? Will there be dispensation for highly effective risk management practices? We know this is possible from high profile sporting codes. Furthermore, why can't we have incentives for high vaccination rates to keep business moving.
3. What role will the Commonwealth, or other states for that matter, play in assisting those states that fall significantly behind. If we hope to allow greater freedom of movement across borders, and take the economic sting out of any local outbreak between regions and states, there is a genuine role for the Commonwealth Government as the second line of defence.
Consider the Three Lines of Defence model in your business. Does your risk framework allocate responsibility for all three lines of defence? Contact our team to discuss your needs today.
About Micheal Martin FAICD, Managing Director, C-Suite Safety Solutions
Micheal is the Executive Director of C-Suite Safety Solutions and a Fellow of the Australian Institute of Company Directors. He brings over two decades’ experience in working directly with key leaders from a diverse range of major global organisations; to deliver expert solutions in governance, risk and strategy that effect positive advancements in workplace safety.
Micheal has first-hand knowledge of the importance of safety practices, from the lunch-room, to the board-room, and the court-room; and combines this experience with a wealth of knowledge in fields of Business; Corporate Governance; Auditing; Industrial WHS; HR and Administrative Leadership.