EU Exit actions for medical devices and clinical consumables

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Information for NHS providers about the extensive planning and contingency measures that have been put in place for the healthcare system nationally and the additional actions that we are asking providers to undertake as a priority as part of the wider preparations for a ‘no deal’ EU Exit.

We, along with NHS England, are working to support the Department of Health and Social Care (DHSC), who is responsible for ensuring the continued supply of medical devices and clinical consumables in the event of a ‘no deal’ EU Exit.  

The government continues to work to secure an EU Exit deal, but time requires that some actions need to be taken now to ensure  effective contingency arrangements can be in place ahead of 29 March 2019 that ensure you can continue to access the products you need to deliver safe, effective patient care in any scenario.

This information was sent directly to chief executives and heads of procurement on 11 February 2019 by Professor Keith Willett, EU Exit Strategic Commander, Medical Director for Acute Care and Emergency Preparedness, NHS England.

Centralised stock build

Levels of stock holding in the national procurement and logistics operation, NHS Supply Chain, have been increased for medical devices and clinical consumables routinely held in the UK distribution network. This stock build provides additional resilience to enable NHS Supply Chain to fulfil orders placed by customers in the normal manner with priority being given to clinical products. Delivery of products to customers is envisaged to follow normal patterns, however, subject to the variation in the flow of supplies that may result, some flexibility might be required in terms of delivery windows, including night-time or weekend deliveries.

Supplier preparedness

More than 1,300 suppliers of medical devices and clinical consumables have been contacted by DHSC to understand their supply chains, reliance on supply from the EU and proposed contingency measures for a ‘no deal’ EU Exit, where relevant. Suppliers that have stock holding capability within the UK are working to increase their levels of stock holding to complement the centralised stock build activity with NHS Supply Chain. 

Of those contacted, DHSC has identified around 200 suppliers that provide in excess of 80% of products used by NHS trusts (by spend). They are particularly working with these suppliers to establish their level of preparedness, applicability of national contingency arrangements, and where necessary, agreeing specific measures to improve the robustness of their plans. 

We are confident if everyone does what they should do, the supply of medicines and other medical supplies will be uninterrupted in the event of exiting the EU without a deal.

Prioritisation of medical products entering the UK

In December, you were informed by government that the preparations were being put in place to mitigate against the potential for severe delays developing on roll-on, roll-off freight services operating across the short Channel straits. 

New additional freight capacity has now been secured by Department for Transport (DfT) on alternative routes from the continent to the UK by the UK government. Medicines and medical products on which the NHS depends will have priority access. DfT advise us this capacity will be sufficient to maintain supplies to the NHS and social care. 

Dedicated NHS shipment channel

It is recognised not all suppliers have the capability to hold stock of their full product range in the UK and routinely supply product directly from distribution centres in the EU to UK care providers or patients. Suppliers operating these distribution models are working on their own contingency measures, however, national contingency arrangements have also been put in place to enable the continued movement of these products. This arrangement will apply to products ordered directly from suppliers or via the NHS Supply Chain ‘Blue Diamond’ and ‘E-Direct’ services. 

While DHSC is confident these contingency arrangements will ensure continued access to a full range of products ordered on this basis, it should be recognised that lead times (the time from order placement to order receipt) could be longer using this alternative system. 

It is estimated by DHSC that the increase in lead times may be up to three days longer than currently experienced.

Guidance for heads of procurement on the implementation of EU Exit actions

The contingency arrangements that are being implemented nationally will provide a significant level of supply resilience for a full range of medical devices and clinical consumables, but to enhance this resilience further, we would ask you now to take the following actions within your organisations, ahead of 29 March 2019. 

  • NHS trusts are being asked not to stock pile products. However, where your organisation relies on receiving products direct from the EU on a short lead time basis (24 to 72 hours), you should plan for lead times of around three days longer.
  • Assess with your trust business continuity and emergency preparedness, resilience and response co-ordinator the ability to receive stock deliveries outside your current normal goods receipting hours. Please provide details of this by 1 March to the DHSC central MDCC team (mdcc-contingencyplanning@dhsc.gov.uk) which will liaise with us. Please see the guidance for further details.
  • It is sensible as part of business continuity, also to plan for any transport delays and therefore goods delivered to your trust will need to be received regardless of time. 

  • ensure all staff are aware of these changes in practice and that business continuity plans are in place.

It is important the NHS is prepared to respond to any supply disruption incidents that may arise in the event of EU Exit with no deal. National Supply Disruption Response processes and operations will be in place to monitor the supply situation and co-ordinate actions to address any supply disruption incidents. Further details of the national supply disruption response arrangements and how NHS trusts should interact with this system will be communicated at the beginning of March.

Should you have any queries relating to these contingency measures or any of the actions you need to take, then please do not hesitate to contact us using the regional contacts provided in the guidance.

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