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VVI Concerned About Covid Vaccine Plan

VVI (Voice of Vision Impairment) is Ireland’s national DPO for issues relating to the rights and needs of people with a visual impairment., and we have serious concerns regarding the accessibility of the Covid vaccination programme. These concerns are, along with the required solutions, are set out below:

In sum, they are:

  1. Neglect of the particular vulnerabilities of people with a visual impairment in the prioritization levels.
  2. Lack of planning to make vaccination centres reachable by people with severe visual impairments.
  3. Lack of planning for accessible consent process and accessible information for blind and partially sighted recipients of the vaccines.

More Details and Solutions

1. Prioritization:

In the Provisional Vaccine Allocation Groups published by the Dept. of Health on December 7th, 2020, there is no acknowledgement of the heightened susceptability of people with a severe visual impairment to contracting covid.

https://www.gov.ie/en/publication/39038-provisional-vaccine-allocation-groups/#provisional-vaccine-allocation-groups

For example, people with a visual impairment cannot effectively socially distance when we are out and about, since the faculty of sight is the primary sense used in the fulfilment of a person’s social distancing requirements. Also, we often rely on touch much more, for navigation and stability/support, especially in enclosed environments such as public transport. Furthermore, when entering a public building, such as a supermarket, we cannot independently locate hand sanitizers.

Using the rationale and ethical principals laid out in the Dept. of Health document, people with a severe visual impairment, especially those living alone, or living on the streets, should be prioritized to at least the equivalent of level 9 on the current scale.

Level 9 applies to ‘People aged 18-64 living or working in crowded settings’

Rationale: Disadvantaged sociodemographic groups more likely to experience a higher burden of infection.
Ethical Principles: The principles of moral equality, minimising harm (especially in the context of multi-generational households) and fairness are relevant. Prioritising this group recognises that structural inequalities make some people more vulnerable than others to COVID-19

While the situational specifics are clearly not identical, the rationale and ethical principles are clearly equivalent.

Solution:

We are concerned that the vulnerability of thousands with a severe visual impairment is not being recognized or factored into the current roll-out prioritisations. We ask that in the interest of public health and the safety of people with a visual impairment in the State, that this vulnerable sector be better prioritised in the roll-out, at least to the equivalent of what is currently level 9.

2. Accessibility of Vaccination Centres:

We have seen no evidence of planning for people with mobility impairments, including those with visual impairments, regarding how we are supposed to find our way to the vaccination centres. 86% of those with a severe visual impairment are not in official employment, and therefore, are at the lowest end of the socio-economic scale. The principle of moral equality means that we should not have to pay €50+ in taxi-fares in order to get to and from vaccination centres. With large hospital campuses, etc., taxi is usually the only way a blind person can independently access particular clinics etc.

Solution:

While an appointment is being made with a person who has a visual impairment, arrangements should be facilitated whereby a prepaid taxi will collect and return the person for whom the appointment is being made.

3. Accessible Information:

On an interview on RTÉ’s Morning Ireland on December 28th, 2020, the Tánaiste, Leo Veradkar, stressed the importance of consent forms to be signed by each person at the vaccination centre, and that when the vaccination had been given, the vaccinated person will be given an After-care advice leaflet and a vaccine record card.

All of this is verified in the HSE’s online information:

https://www2.hse.ie/screening-and-vaccinations/covid-19-vaccine/

The State already has a legal obligation to provide all published material in accessible formats, including online, and in braille. There is no evidence of ongoing or planned work in this regard in the HSE’s advice information.

Solution:

Signed Consent: There are many alternatives to the traditional means of verification, but vaccinators need to be made aware of these alternatives in advance so that blind and partially sighted people receiving the vaccine can be facilitated, and not be discriminated against. VVI (Voice of Vision Impairment) is the only national DPO focussing specifically on the needs and rights of people with a visual impairment, and therefore, need to be prioritized in any consultations in this matter (see General Comment 7 of the Convention on the Rights of People with Disabilities). VVI is happy to advise the State in the alternatives to paper signatures, and all other relevant matters.

Accessible Information: Likewise, we in VVI are happy to fulfil our function by giving our expert advise on the needs of people with a visual impairment in relation to the production of accessible information.

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