The SAWC’s Vaccination Policy

The Southern African Wildlife College (SAWC) Vaccination Policy (MVP) serves as the policy framework for all Covid-19 management and mitigation activities to reduce the risk of Covid-19 to staff, visitors, residents, students and contractors, both on and offsite.

The implementation of the policy is to protect the lives of our employees, their families, our students and stakeholders, visitors to the College and the communities at large.

Legislative compliance

The policy derives its mandate and regulatory requirements through the following pieces of legislation:

• The Constitution of the Republic of South Africa, Act 200 of 1993, including the Section 36 the limitation of rights clause.
• Direction issued in terms of regulations 4 (10) of the regulations made under section (27)2 of the Disaster Management Act, 2002: Measures to address and combat the spread of Covid-19 in certain workplaces in the Republic of South Africa.
• SAQA Act – as amended by the National Qualifications Framework Act (Act no. 67 of 2008)
• Skills Development Act – as amended by the Skills Development Amendment Act (Act no. 37 of 2008)
• Higher Education and Training Act – as amended by the Higher Education Amendment Act (Act no. 39 of 2008)
• Basic Conditions of Employment Act, Act 75 of 1997
• Occupational Health and Safety Act, Act 85 of 1993
• The Employment Equity Act, Act No 55 of 1998
• The Labour Relations Act, Act No 66 of 1995
• CATHSSETA ETQA Regulations
• Requirements of the ETQA / QC with whom the Organization is accredited / registered
• Higher Health notices and mandatory requirements
• The POPI Act (POPIA) which came into effect in respect of compliance in 2021, which governs how we keep personal data.

Principles

The Southern African Wildlife College adheres to the following principles of employer-employee and workplace safety:

• To create and enable a safe and conducive work environment for employees.
• To ensure dialogue and transparency between the employer and employee.
• To respect the employment and personal rights of employees.
• To provide a safe and secure living environment for residence-based employees and their families, including minors.
• To educate and create awareness on health and safety issues that may impact an employee and via extension their families and social systems.
• To provide a safe and secure service to our students, clients, donors, partners, service providers and visitors.

Scope

The policy scope covers the footprint of all of the SAWC infrastructure on the SAWC portion of the Kempiana Nature Reserve, as well as the deployment of trainers/assessors and staff to external or third-party site for training or research purposes. It includes and is not limited to:

1. The main entrance gate
2. The public campus areas
3. The ranger training base
4. The K9 unit kennels and dog master’s house
5. The residential areas of employees and families
6. The recreational and social facilities, gym, swimming pool,
7. The vehicles and aircraft computer laboratories, lecture rooms
8. The canteen, pub and dining areas
9. The training resources and specialist equipment
10. The library and resource centre
11. The maintenance workshops and storage facilities
12. The shooting range
13. The staff, external contractors, visitors and donors

Exclusions: Ngala Game Lodge staff, SANParks staff, Online only lecturers, Online only consultants and service providers. Public Law Enforcement personnel, ESKOM staff, SANDF staff, Correctional Services etc.

Rationale

The rationale for the development of the SAWC policy on vaccinations was based on the risk-based assessment that was prompted by the gazette Direction issued in terms of regulations 4 (10) of the regulations made under section (27)2 of the Disaster Management Act, 2002: Measures to address and combat the spread of Covid-19 in certain workplaces in the Republic of South Africa which was released in May 2021.

The SAWC Covid-19 and Occupational Health and Safety Committee were required to conduct a Risk-based Assessment of each job, function and service risk at the SAWC.

Secondly, if deemed necessary the SAWC would be required to develop a Vaccination Policy to proactively mitigate and combat the spread of Covid-19 in the workplace.

Thirdly, if a staff member refuses to obtain a vaccine on constitutional or medical grounds, the SAWC would have to provide a procedure for the individual to communicate and engage the SAWC management on their challenge.

Findings of Risk-based Assessment

It overwhelmingly found that all jobs are rated at high risk of infection, either by exposure or by infecting others. This also included onsite students, who travel in and out on a training and social basis. In addition, many students travel to the College from countries with low vaccination rates and similarly, many students travel in and out of the campus on a weekly basis into areas with low vaccination compliance. Furthermore, students and lecturers/trainers often have to train in close proximity, such as in firearms training, environmental monitoring and in one-to-one skills support, such as handling equipment such as power tools, electrically-charged/high voltage equipment, firearms and in a first aid/first responder context. The need to take reasonable measures to preserve life, or train and correct certain behaviour to preserve life and maintain safety means that breaking the social distancing requirements is a regular practical event in a conservation and law enforcement context. Thus alleviating risk to a trainer, student and first responder from Covid-19 infection is crucial to the performance of training and research programmes.

Due to the nature of the college campus, especially with served meals and communal learning, the rate of transmissibility is relatively high, even with the establishment of social distancing norms in place.

Lastly, the college has residents that are non-employees, including minors. It is the policy of the SAWC that residents must all be vaccinated, as they reside in, utilize and socialize with SAWC staff and infrastructure. Residents also receive external visitors on a social basis, which provides a risk to the SAWC staff and residents. The SAWC will therefore require all residents to be fully vaccinated Added to this many residents employ or utilize domestic and service worker within their houses for cleaning and related purposes. Likewise, all domestic and service workers will be required to be vaccinated. In addition, the policy developed and now requiring sign off by the SAWC’s Audit and Risk committee, addresses:

• Dates by which vaccination will be required
• Visitor types
• Main Gate Vaccination and PCR testingVaccination deadlines
• Staff and students on campus
• Offsite staff and students
• Offsite training and research
• Vaccination refusal
• College procedure for employee Vaccination refusal
• Vaccination refusal by external lecturers and related occupations
• New employees
• Exemptions

It must be noted that the Southern African Wildlife College’s Vaccination Policy may change from time to time due to legislative and operational requirements.