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  • julie8780

Covid Protection Framework preparation November 2021

Updated: Dec 20, 2022

Dear Valued Professionals,

We understand the confusion that exists as the Government manages the differing Covid alert levels and an eventual transition to a Regional “Traffic Light” Covid response framework (officially called the CRF). Indications (which of course may change) are that the move to Traffic Light levels will occur around 29 November at the “RED” level.

So here are some vital considerations clinic owners and therapists need to be aware of and to consider prior to reopening or continuing ongoing business.

The definitive source of information on Government’s requirements are on the website The COVID-19 Protection Framework | Unite against COVID-19 (

At present, the Government are not mandating Vaccinations for “close contact businesses” e.g., skin therapy professionals or their clients. However, under the Traffic Light scheme, clinics that DO NOT follow the Vaccination Certificate rules WILL NOT be allowed to operate under ORANGE or RED levels Note that the restrictions control the right to enter premises, the “vaccination entry requirement for customers this is the legal basis to avoid treatment discrimination. At all levels whether you elect to operate with or without Vaccination certificate, you will still be required to offer the Covid-19 QR code scanning or keep manual entry records.

There are several aspects of this Framework that have yet to be announced by the Government, the NZBPST is monitoring updates and will provide this information as soon as practicable.

What clinic owners need to consider ahead of the traffic light environment Before the Traffic Light System comes into effect, you will need to decide if you are going to

  1. Require your staff to be vaccinated and /or

  2. If you wish to treat Clients who are, or are NOT, Vaccinated and

  3. If you are going to require vaccination certificates (to enter the Clinic)

It’s essential that clinic owners have staff meetings to establish their clinic’s position and put measures in place so clinics can function across the new Traffic Light levels At staff meetings all new changes and clinic entry protocols need to be agreed and explained, so staff are aware of their roles in maintaining staff and client safety. These meetings should be documented to avoid future misunderstandings. Key points to be discussed are,

  • What is your policy in receiving unvaccinated people into your facility?

  • How (or will) you still treat clients who are unvaccinated due to medical conditions that prevent vaccination?

These requirements should be in staff hand outs and amendments made where applicable in clinic procedures and protocol documentation. Owners will need a one-on-one discussion with employees to discuss ongoing Covid clinic employment requirements for vaccinations and expectations and explain how staff can meet them.

These meetings also need to be documented.

NOTE: Clinic owners are required to follow the Employment Relations Act 2020 for staff that do not meet your new Covid clinic vaccination employment requirements. Unfortunately, Businesses | Unite against COVID-19 ( page has not yet been updated with guidance for the Traffic Light Levels. The NZBPST is lobbying for clarification, and we will provide this as soon as it becomes available.

You must also have provisions in place to maintain and store all staff personal information confidentially as required under the Privacy Act 2020.

Staff need to be prepared and trained on how to explain their Covid clinic policies to their clients so as not to cause undue stress for all concerned.

How to reply to clients who ask if staff are vaccinated. As your vaccination status is your personal information you are not required to disclose it if you chose not to.

It is helpful to develop a standard tactful and explanatory explanation that can be given by staff along with an explanation of your reasoning.

Form and practice your replies. This can be practiced through role play to build confidence.

Before opening, practice PPE protocols to maintain the highest standards of hygiene.

The Consultation Process and Consent Forms How will you conduct consultations in the Covid environment? With client health issues and long-term post Covid being recognised, it’s essential that the consultation process and consent forms are amended to identify any further risks and a wavier added. Further understanding on what is required in the consultation process and how to conduct that should be considered and include, Are you vaccinated?

  • The date of the last vaccination [ This is essential to identify the potential of an inflammatory skin response to any semi or invasive skin treatment immediately post vaccination].

  • Have you been diagnosed or suffered from Covid?

  • Recovery Date

  • Changes in sensitivity to or heightened allergic reactions to anything

  • Any noticeable health of body changes e.g., poor auto immune response, chronic fatigue, sleep disturbances, etc

At what point is a consultation terminated and how and when and under what grounds can a therapist refuse to treat a client. Should a client refuse to disclose their medical history, it’s important to explain that as their therapist you have a responsibility to provide a duty of care to them. It’s therefore essential that a full medical history be taken to make sure that the treatments you are providing does not compromise the treatment outcome and to identify any contraindications that may prevent them from receiving the treatment safely.

The Health and Safety act Work Act 2015, allows a therapist who feels that their health and/or safety is at risk, to have the right to refuse to provide their treatment. Ventilation.

As an aerosol virus, Delta has proven to be more contagious and spreads quickly. Still air is more likely to contain viruses and pollutants and increase infection risks than moving air. Therefore, ventilation also needs to be reviewed. It has been recommended that air needs to be regularly moving out of the room.

If you do not have Air Conditioning that cycles air out of your building, open windows wherever possible to circulate fresh air (one suggestion is to have a fan close to a window blowing air OUT). If you have Air Conditioning (remember that Heat Pumps do not cycle air out of the building) ensure filters are cleaned regularly.

For any further assistance please email ( or phone the NZBPST for advice. Kind regards, Julie Martin Chair NZ Board of Professional Skin Therapies E: M: 021 02294638 W:

Posted: Thu 11 Nov 2021

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