FOI 2025/1501

Please provide the following information relating to your Integrated Care Board’s (ICB’s) policies and guidance concerning the “bare below the elbows” approach or any equivalent dress-code policies for healthcare staff:

1. Policies and Guidance

Please supply the current version of any formal policies, protocols, guidance documents, or standards issued by the ICB relating to:

•  “Bare below the elbows”
• Infection prevention dress-code requirements
• Clinical or non-clinical staff attire expectations
• Any occupational health or safety requirements related to staff appearance or uniform

2. Scope and Application

Please clarify whether these policies apply to:

• All staff within the ICB
• Staff working in provider organisations commissioned by the ICB
• Primary care (GP practices), community providers, or other contracted services

3. Implementation and Compliance

Does the ICB require, monitor, or enforce provider compliance with ‘bare below the elbows’/dress-code expectations as part of:

• Commissioning contracts?
• Quality schedules (e.g., infection prevention requirements)?
• Assurance frameworks?

If monitoring occurs, please provide any documentation describing how this monitoring is carried out.

4. Exemptions or Adjustments

Please provide any guidance you hold on:

• Exemptions or reasonable adjustments for cultural, religious, or clinical reasons
• How exemptions are assessed or approved

5. Changes Since 2020

Have there been changes to these policies since 1 January 2020?
If yes, please provide:

• The dates of changes
• A brief description of what changed
• Any archived versions of the policy still held by the ICB

1. Policies and Guidance

The ICB does not directly provide clinical care and therefore does not have a specific policy on “bare below the elbows” or clinical dress codes. We do hold general policies on infection prevention and control (IPC) that apply to all ICB staff, but these are not specific to clinical attire. When visiting provider premises, ICB staff are expected to comply with the provider’s IPC and dress-code requirements.

All ICB job descriptions include the following statement:

“It is the duty of every member of staff to take personal responsibility for the prevention and control of infection, as laid down in the GM ICS policies and procedures which reflect the statutory requirements of the Hygiene Code.”

2. Scope and Application

• Our IPC responsibilities apply to ICB-employed staff only.
• We do not set or enforce dress-code policies for staff working in provider organisations, primary care, or other contracted services. These remain the responsibility of the individual providers.

3.Implementation and Compliance

The ICB follows the national standard contract which states the following –

The Provider must:

1. Comply with the Code of Practice on the Prevention and Control of Infections and put in place and implement an infection prevention programme in accordance with it.

• The ICB does not specifically monitor or enforce compliance with ‘bare below the elbows’, or dress-code requirements as part of commissioning contracts, quality schedules, or assurance frameworks.
• Providers are responsible for their own IPC and dress-code compliance. The ICB does not hold documentation on monitoring of these requirements.

4. Exemptions or Adjustments

• • The ICB does not issue guidance on exemptions or adjustments for dress codes, as we do not have a dress-code policy. Providers manage exemptions for cultural, religious, or clinical reasons within their own policies.

5. Changes Since 2020

• There have been no changes to ICB policies relating to “bare below the elbows” or dress-code requirements since 1 January 2020, as the ICB does not hold such policies.