As part of the policy development process, DOC undertook a risk assessment of the measures needed to best protect staff from the risks posed by COVID-19. This is required by health and safety law and is an expectation of all government agencies.
The risk assessment looked at what additional benefits there would be from a vaccination mandate, over and above existing measures such as mask wearing.
It concluded that vaccinated staff have a far lower risk of being severely affected by an infection at work and mandatory vaccinations are necessary to manage the risk.
DOC’s COVID-19 staff policy is that:
- (From 1 February 2022) all DOC employees are required to be fully vaccinated and hold a My Vaccine Pass.
- (From 10 January 2022) contractors/suppliers/volunteers/members of the public visiting DOC work premises are required to be fully vaccinated and be able to provide verification of their vaccination status.
DOC consulted with staff and the Public Service Association (PSA) on the policy and the vast majority are in favour of the policy.
This policy also provides New Zealanders with greater certainty when using huts and campsites, knowing that staff are fully vaccinated.
Full text of COVID-19 vaccination policy
Based on community transmission
The purpose of this policy is to set out DOC’s approach to COVID-19 vaccinations in line with DOC’s Health and Safety risk assessment: Transmission of COVID-19 in the Workplace. That risk assessment relates to situations where there is a highly transmissible variant and community transmission. This policy sits within broader health and safety policies, including those relating to COVID-19. This policy does not apply to staff who are subject to a legal requirement to be vaccinated in order to undertake their work, such as border workers.
Our priority is to keep our people safe and well. We do this because it is the right thing to do and we have legislation (Health and Safety at Work Act 2015) that protects and supports this.
COVID-19 is a significant risk to those who are infected. With community transmission, the risk of DOC staff being infected within the workplace has increased and needs to be managed through a suite of measures put in place in the workplace.
A health and safety assessment has been carried out to understand the risk and associated factors to staff, visitors, contractors and suppliers, volunteers and community groups (including Jobs for Nature projects) in different work scenarios. Mitigating and assuring ourselves that we can effectively and safely manage risks associated with COVID-19 in the workplace has led us to develop a COVID-19 vaccination policy.
This policy will require all staff to be fully vaccinated to enter and work in DOC workplaces. Vaccination is central to mitigating risk. You must be fully vaccinated and have a My Vaccine Pass by 1 February 2022.
Health and Safety risk assessment - vaccination
DOC has assessed the risk and impact of a COVID-19 infection for all our people based on an assumption of a highly transmissible variant and community transmission. You can see our current Health and Safety risk assessment here DOC-6841665. The COVID situation is constantly changing and the risk assessment will be updated when there are significant shifts in context. The first scheduled review is by 31 May 2022. The risk assessment is based on multiple, layered controls such as physical distancing, hygiene, signage, limiting numbers, barriers, and masks. Vaccination presents a higher level, additional control and significantly moves the profile of risk down in both likelihood and severity. Vaccination reduces the risk that the vaccinated person will be infected, suffer serious illness if they are infected, and infect others they are in contact with. Additional measures will be in place, including mask wearing, social distancing and the use of vaccine passports as reflected in the Governments Traffic Light System.
It is recognised that vaccination and a vaccination mandate can have wellbeing effects on some individuals and teams. Those risks have been taken into account in development of the policy and implementation processes.
What that means for DOC staff
Given our risk assessment, DOC will require all staff to be fully vaccinated to enter and work in DOC workplaces. This will be in place for the foreseeable future.
As an employee, if you are not vaccinated, or choose not to be vaccinated, or are unable to be vaccinated for medical or religious reasons, or have a medical exemption, we will work with you individually to understand your situation and what options might be available to you. Whether you can stay in your current role will depend on the nature of the work you undertake, whether you can undertake your work from an alternative location in the short term, the availability of alternative work, and any other factors that are relevant to your situation.
Where you have chosen to not be vaccinated (as opposed to being unable to be vaccinated), it will be necessary to ensure that there are no undue effects on the business and your team colleagues due to the arrangements put in place. Working from home on a long-term basis with no entry into the workplace or in-person interaction with teams and managers is not likely to be considered a viable option.
In good faith, we will ensure that you have opportunities to respond to any proposed changes to your employment and will take into consideration your responses. This process will be managed centrally by the Human Resources Team, with the support of your manager and you can involve a support person of your choice (e.g. a union delegate).
The final decision on vaccination rests with the individual. The decision by DOC to require vaccination does however mean that ultimately if you choose not to be vaccinated or to tell us your vaccination status, we may need to consider termination of your employment.
Vaccination will greatly increase your safety and reduce the risk of you infecting a colleague. But vaccination is in addition to and does not replace other safety measures, including wearing masks, maintaining social distancing, and staying home if you may have been exposed or are unwell. All the identified safety measures must be taken to ensure that our staff remain safe.
To support you receiving your vaccination, the Department has put in place policies to make it easier for you to get vaccinated and implement other safety measures. Approved Discretionary Leave with Pay is available for you to get your vaccinations during your normal working hours, if you need time to recover from vaccination, you are sick due to a COVID-19 related illness, or you are self-isolating due to COVID-19. It is also available if you need to support a dependent (e.g. elderly parent, child) in getting their vaccination.
Collection, use and storage of personal medical information
You will be required to provide evidence of your COVID-19 vaccination status to your manager. This can be a vaccination certificate, or vaccine pass. Your manager will sight the above and send an email to email@example.com confirming your vaccination status.
This information will be stored in a secure file accessible only to Human Resources/Health & Safety staff who are managing the process and who will be involved with a manager in any follow up, such as potential redeployment options.
If there is a reason to hold information, then that would be done in accordance with the Health Information Privacy Code 2020.
If you cannot or choose not to provide evidence of vaccination, your manager will note that you are unvaccinated. If you are subsequently vaccinated, you can at that time provide evidence to your manager and that change in status will be recorded.
Protecting our staff from other people entering DOC workplaces
In the interests of keeping our people safe, DOC will be ensuring that contractors and suppliers who do work in or visit DOC premises are vaccinated. All people entering our premises will need to provide proof that they are vaccinated.
The term “premises” is defined for the purposes of this policy as:
"A DOC workplace and premise is a DOC building and immediate surrounds where DOC has influence and control over entry to the building. Where DOC shares a building, the DOC workplace is the area of the building that DOC controls."
“DOC workplace and premises” does not include an outdoor work environment, for example Public Conservation Land where work is not occurring on a given day"
The mandate will also apply where a contractor or volunteer is working in close proximity to DOC staff or in an enclosed space with DOC staff. For example, working together in a helicopter or vessel, travelling in a DOC vehicle. Contractors and volunteer groups who are working in protected areas without close contact with DOC staff will not be subject to this policy but will be be expected to determine their own health and safety procedures, including how to protect against COVID-19 risks.
DOC will be writing to all contractors and suppliers to advise of our vaccination requirements, which will come into effect on 10 January 2022.
Suppliers will be able to do contactless drop-offs of goods to DOC premises.
Restrictions on entry of visitors to DOC workplaces and premises will come into effect on 10 January 2022. Signage and procedures to ensure this can be safely implemented will be in place by that date. Groups who may be affected, including volunteer groups and iwi, will be advised.
DOC visitor centres
People entering DOC visitor centres must be fully vaccinated. In the visitor centre:
- have your My Vaccine Pass ready for checking;
- wear your face covering at Orange and Red settings (unless exempt);
- scan the QR code or keep a record of your visit using the record keeping slips and box; and
- keep your distance from people you don’t know.
It’s vital to plan and prepare before heading outdoors. If you can’t visit in person, contact your local visitor centre.
DOC’s visitor centres offer customised advice and up-to-date, local information. For example local gems to visit or the latest weather forecasts and track conditions. This means people can plan and prepare to enjoy their outdoor experiences safely and really make the most of their time in nature.