Response to GOC consultation on COVID-19 statements

AOP response: Yes

In principle the framework is a sensible way of highlighting that some statements only apply in certain phases of the pandemic.

AOP response: Yes

We think the principles in the statement are sensible.

AOP response: Don't know

We have had little feedback from AOP members about the impact of the statement, but it has been suggested that the statement may have been helpful in confirming that the GOC would take a pragmatic approach to issues generated by the pandemic.

AOP response: Yes

AOP response: Yes

In our view the statement should clearly apply during the red phase, and should not apply in the green phase.

We have considered whether it is necessary for the statement to apply at all times during the amber phase, which is wide in scope – covering anything short of all eye care being provided on an open access basis. The GOC rationale for that is that some patients will be shielding. Some AOP members have suggested that given the wide scope of the amber phase, the statement should only apply in exceptional circumstances.

Since the statement ultimately points to professional judgement being the deciding factor, clinicians will presumably be able to adopt whatever interpretation they think is appropriate – for instance, only supplying spectacles and contact lenses without seeing the patient if the patient is known to be shielding, or cannot be seen for other exceptional reasons, and the other factors point to supply in the circumstances being the best course of action for the patient.

AOP response: Positive

We have had little feedback from AOP members about the impact of the statement, but it has been suggested that the statement has been helpful in emphasising that practitioners should exercise their professional judgement to put the best interests of their patient first.

AOP response: No

We agree with the statement that registrants should use professional judgement and refer to relevant guidance including public health advice, and record their aftercare plan. However, we do not think it is safe for registrants to rely on remote rather than face to face aftercare consultations for an extended period. This is because contact lens patients are at risk of serious issues which may not cause symptoms and can – if not detected by physical examination – lead to sight-threatening consequences. Examples include: corneal infiltrates; scarring from previous corneal ulcers; corneal epithelial staining; poor tear quality; blepharitis and chronic allergic conditions.

We therefore think the statement should be expanded to highlight this risk, and to underline the need for both individual registrants and registered optical businesses to manage the risk appropriately. We also think it would be helpful if the statement included a recommended maximum interval of no more than two years between face to face consultations for contact lens aftercare during pandemic conditions, subject to the use of professional judgement to balance all relevant factors.

AOP response: No

The statement is unlikely to be relevant in the green phase, when there shouldn’t be any major issues around public health guidance, shielding etc. Given our concerns about the current version of the statement as set out in Q7, we do not think the statement should apply in the green phase.

AOP response: Positive

We have had little feedback from AOP members about the impact of the statement to date, but it has been suggested that the statement has been helpful in emphasising that practitioners should exercise their professional judgement to put the best interests of their patient first.

AOP response: No

Paragraph 10 of the statement currently reads:

“The current position is that physical hearings are not taking place at our London office, but this will continue to be subject to review in line with current and future Government guidance. Where possible, we will hold remote virtual hearings via teleconference or video-link, or on the papers. If either party considers that these methods are unsuitable then an application to adjourn should be made in accordance with rule 35”

We think it is important that this paragraph be amended to acknowledge registrants’ right to a fair hearing, along the lines of:

“The GOC is committed to preserving each registrant’s right to a fair hearing and recognises that remote hearings can interfere with that right. Whether a hearing can be heard remotely or on the papers will be assessed on case by case basis by senior GOC staff, taking into account the view of the registrant (and their representatives if represented).

“If a case is deemed suitable, we will hold remote virtual hearings via teleconference or video-link, or on the papers. If either party considers that these methods are unsuitable then an application to adjourn should be made in accordance with rule 35”

This would make the statement more consistent with the GOC’s remote hearings guidance (as updated in November 2020) which says that when considering whether a hearing can be held remotely, the GOC will consider:

“Whether the registrant and other participants have sufficient access to and understanding of technology, and access to an appropriate environment to enable them to take part effectively in a remote hearing, including having access to advice: The GOC are able to allow registrants or witnesses to attend the office to participate in a hearing or attend by other means such as audio.”

AOP response: No

The consultation paper states that “this statement will be required through all phases of the pandemic to support effective and timely delivery of FTP processes”, but the approach in the statement is geared to emergency conditions.

From the outset of the pandemic and the introduction of remote hearings, the AOP has taken the position is that a remote hearing is not always an adequate substitute for a live substantive hearing. There is much nuance involved in a hearing which is lost when cases are heard remotely – for example the ability of participants to assess (and respond to) the body language of a witness, ease of communication between counsel and registrant, the opportunity to observe the public gallery, and reassurance that witnesses are not referring to notes etc when giving evidence.

We have identified a number of risks which remain unresolved in remote hearings:

• We cannot be certain that witnesses are not under ‘undue influence’ when giving evidence before a panel
• We are concerned that the GOC cannot ensure that only those entitled to attend a private hearing can take part
• There is a risk of online proceedings being recorded and the potential for misuse of recordings
• Remote hearings result in a loss of the facilities that are normally provided to the registrants and their representatives, such as private meeting rooms. 

However, we recognise that in some cases remote hearings have provided tangible benefits to registrants, employers, patients and the public as well as other participants. Some registrants facing fitness to practise proceedings prefer to have their matter concluded remotely rather than facing significant delays. There are also practical advantages in some cases, including the less financially onerous nature of remote hearings for participants, and the fact that some registrants are more comfortable waiting for decision etc in their own home.

If the statement is going to apply to all phases, it needs to set out a more flexible approach which recognises the need for face to face hearings in some cases, as well as support for registrants who aren’t comfortable with using electronic notifications. We would be happy to provide the GOC with input to inform expanded guidance on when a face to face or remote hearing is appropriate, and how to support registrants.

AOP response: Negative impact

See our response to question 11 above.

AOP response: Negative impact

Electronic service

In this statement the GOC sets out its intention to serve all notices electronically stating:

“we have only very limited access to our premises at 10 Old Bailey, and it is no longer practical for us to comply with some of our previous processes. Therefore, with effect from Monday 23 March 2020, in order to continue to be able to maintain our fitness to practise function, and our overarching legal objective under section 2A of the Opticians Act, to protect the public, we have moved to a process of serving all notifications, notices and documents electronically via our secure email systems”

The consultation document said that the GOC is in discussions with the Department of Health and Social Care to underpin this statement with emergency legal powers that allow fitness to practise notices to be served by email, and since the launch of this consultation a statutory instrument has been published, setting out powers to come into force on 14 December 2020, before the close of the consultation. 

We have discussed issues around the legal basis for the GOC’s use of electronic notices further in our responses to the consultation questions on statement GOC/COVID/14 below. In summary, our strong view is that even once the GOC has emergency legal powers that allow all notices to be served electronically, it must be willing to use alternative methods of service where appropriate. This is because we have serious concerns regarding the blanket use of electronic notices.

As a defence body the AOP represents a large proportion of the optometry registrants who come before the fitness to practise and Interim Order Committees. We have recent experience of registrants who have been unable to access electronic documents, either because of a lack of access to appropriate equipment or the skills needed to use that equipment. We are also aware that some members who have previously given the GOC an email address for purposes other than the service of notices may not monitor the address regularly, because they do not expect it to be used for important purposes such as the service of notices. Some members use an email address which is shared with work colleagues or others in their household, and so is not appropriate for this purpose.

Where problems such as these have affected AOP members during the pandemic, we have been able to assist them. However,  unrepresented registrants will not have this assistance, and in the worst case scenario a hearing could be held without a registrant being aware that he or she faces allegations which have been put before a fitness to practise committee.

It is therefore vital that the GOC makes appropriate arrangements which will make it possible for physical notices to be sent in cases where it does not have explicit consent to send them electronically. We have answered ‘Negative impact’ to this question because registrants could suffer significant detriment if the GOC obtains powers to serve all fitness to practise notices electronically without making arrangements to use physical notices where appropriate.

In discussion during the consultation period, the GOC has told us that it will consider its approach to the use of the emergency powers in the light of responses to the consultation, and that it recognises the need to avoid registrants being disadvantaged by the electronic service of notices. We welcome that assurance in principle. But we also think it is important that the GOC’s policy statements on the use of the emergency powers spell out how it will ensure that registrants are not disadvantaged in practice.

Meaning of ‘venue’

We have set out our general concerns about the risks associated with remote hearings in our response to Q11 above. Subject to those points, we broadly support the emergency powers on the meaning of ‘venue’. However, it is important that the GOC is alert to the risks involved and manages them appropriately, bearing in mind the right to a fair hearing under Article 6 of the ECHR.

Powers to postpone or adjourn hearings

During the consultation period we asked the GOC to provide more information about how these powers will be used in practice. The GOC has advised us that:

• The FTP committee will retain the power to adjourn or postpone a hearing, and the new powers will enable the Head of Hearings to agree to postpone a hearing without referral to the committee where it has been agreed by both parties 
• The Head of Hearings would be the decision-maker for these agreed applications  
• The GOC will produce guidance for the decision-maker and will consult on this guidance
• The further consultation will consider detailed arrangements, such as whether time limits will apply to decisions to postpone and adjourn hearings, and how to adapt the GOC’s case management system to record these decisions and the reasons for them, to ensure consistency and transparency in the use of the powers. 

In view of this information, and particularly the clarification that the power to adjourn hearings will only be used where both parties are in agreement, we think the new powers to adjourn and postpone hearings are potentially helpful and we support them.

AOP response: No

Our response to question 15 explains the reasons for our answer.

Under rule 22 (b) of The General Optical Council (Committee Constitution Rules 2005) a fitness to practise committee must consist of two registered optometrists and three lay persons.

The consultation paper states that moving to a quorum of three would align the GOC with other regulators. We do not think this is a sufficient rationale for this change. This is of some concern, because the GMC’s panels are made up of three members, one of whom must be medically qualified and one of whom must be a lay member. If the GOC follows this model, there will not be a consistency between hearings which is central to ensuring fairness.

The current GOC fitness to practise committee quorum safeguards against professional members having a disproportionate influence over decisions by making provision for three lay members. It also allows for detailed and careful questioning of clinical experts who attend hearings. Under the proposed approach, both of these elements - which set the GOC apart from comparable regulators - will be lost.

AOP response: Yes

Overall we agree with the content. We note that paragraph 8 of the statement refers to the expectation that registrants obtain six CET points each year as a “requirement”. This is not in fact a requirement of the current scheme, but a steer to registrants to spread their learning across the CET cycle.

AOP response: Positive impact

The ‘waiver’ provided by the statement seems to have been unnecessary for most registrants. The availability of remote CET has helped registrants to maintain CET activity – the November 2020 GOC Council papers reported that interactive CET activity by optometrist registrants is slightly higher than at the same point in the previous cycle, despite a fall in the number of approved events.

However, we expect the waiver will have been helpful for those registrants who have faced difficult circumstances because of the pandemic, either because of illness or being unusually busy managing the impact of the pandemic.

AOP response: Yes

The AOP and other providers expect to offer plenty of CET activity in 2021. Given the availability of CET in 2021 and the evidence that the pandemic has not had a significant impact on levels of interactive CET activity during 2020, we do not expect registrants to have difficulty in meeting the overall CET requirements over the whole of the 2019-21 cycle.

AOP response: Yes

The statement includes helpful material about indemnity cover only applying to registrants’ usual role, and advises registrants to check with their insurance provider or employer that appropriate insurance is in place, as we suggested during consultation on the original draft of the statement in spring 2020.

We have one small drafting suggestion on the statement. In para 5, the wording “when [a registrant] is providing support to the wider NHS or healthcare system, the same professional standards apply as in any other situation” looks potentially confusing – this paragraph could be simplified to say that when a registrant is working in a non-optical role, they must ensure they are appropriately trained, competent, indemnified and (where necessary) supervised.

AOP response: Yes

The statement is likely to be much less significant in the green and amber phases than the red phase, because registrants will usually be employed in their usual roles outside of the red phase. But in principle the statement is relevant to non-COVID situations as well, and it doesn’t cause any problems if it applies outside the red phase.

AOP response: Positive impact

We expect the statement has had a positive impact for registrants considering working in different settings.

AOP response: Yes

AOP response: Yes

As a major CET provider, the AOP has welcomed both the statement itself and the pragmatic and flexible way in which the GOC has applied it. For instance, the confirmation in the statement that providers can use a nominated ‘table lead’ to facilitate discussion in online peer discussions, with the support of a trained expert facilitator working with up to four sessions, is proportionate and has enabled the provision of good-quality online peer discussion events.

AOP response: Yes

The arrangements in the statement will remain important for the remainder of this cycle, given the uncertain duration of the pandemic and the likely ongoing need for social distancing among at least some parts of the population, including some GOC registrants.

AOP response: Yes

We welcome the GOC’s decision to leave the arrangements set out in the statement in place until at least the end of 2021, and recommend that they continue indefinitely. The widespread use of online CET has clear efficiencies and benefits for registrants and CET providers. Becoming competent at engaging in remote education also helps registrants develop other skills, such as undertaking remote consultations in a clinical environment.

AOP response: Positive impact

Readily accessible CET in both interactive and non-interactive forms without the need to travel has been warmly welcomed by registrants, as reflected in the highly positive feedback for remote CET.

This is also positive for employers, because their employee registrants have had access to convenient education without the burden of travel or risk of face-to-face engagement.

The statement has had a positive impact on CET providers such as the AOP, which have been able to continue to provide a large quantity of good-quality CET through lockdown and beyond, meeting member demand and receiving very positive feedback from participants.

AOP response: No

When we were first consulted on a draft of this statement in April 2020, we said we didn’t support it because the GOC hadn’t explained why it was removing the important regulatory requirement to verify specifications. In response the GOC added some explanatory material to the statement setting out a patient protection rationale, including enabling patients to obtain lenses from suppliers that comply with UK law. In our view this rationale is not strong, since the effect of the statement is to remove one of the key legal requirements that UK suppliers must meet.

In June 2020 the GOC asked for our views again as part of a review of the statement, and we said it should be withdrawn because practices had reopened for routine care in England, Northern Ireland and Wales, and for face to face essential care in Scotland, so there should be no difficulty in verifying specifications.

The GOC has now proposed that the statement should only apply where routine care is suspended, and it seems reasonable that in that situation there should be some flexibility, because information stored in practices may not always be easily accessible. However, a more proportionate way of meeting the aim of the statement in these circumstances would be to retain the requirement for specifications to be verified, but to waive verification in cases where the supplier has access to a copy of the original verification (eg a photograph or scan of the original) and has no reason to believe the copy has been tampered with.

In discussion during the consultation period, the GOC has told us it recognises the complexity involved in making temporary changes to the rules on contact lens use during a pandemic, and intends to set up a working group to review the GOC’s approach to contact lens issues in the light of responses to the consultation. We welcome that, and would be happy to provide input to this work.

The impact assessment that the GOC has published alongside this consultation includes a reference (page 7) to plans to “consult on whether we should have temporary or permanent powers to enact guidance on waiving contact lens specification verification and allow prescribing on out of date contact lens and spectacle prescriptions, in pandemic emergencies”. This proposal has not been included in the current consultation, and we would be interested to know why not.

AOP response: Yes

As set out in our answer to Q27, we recommended to the GOC in June that the statement should be withdrawn in circumstances where practices are open for routine or face-to-face essential care. This proposal would put that recommendation into effect, so we support it.

AOP response: Negative impact

AOP members have provided little substantive feedback about the impact of the statement, but it has been said that the temporary removal of an important legal protection has caused some confusion for registrants and employers, potentially leading to differing outcomes for patients.

AOP response: No

Overall the statement is helpful in setting out the respective responsibilities of business registrants and individuals under the GOC standards. However, events since the resumption of routine care in June have demonstrated that the GOC needs to take a more robust approach to the responsibilities of employers in ensuring that IPC is carried out effectively, and in particular to ensuring that appointment times allow sufficient time for cleaning and disinfection between patients.

The statement currently says that employers are responsible for ensuring appropriate “IPC systems are in place including … cleaning and disinfection”, while individual registrants are responsible for “alerting their employer ... to the lack of compliance” with IPC including “not having ... sufficient time to use appropriate IPC materials”. Members have raised concerns with us that employers are imposing appointment times which are around the same as those pre-COVID, and which are clearly not designed to accommodate IPC measures.

We have discussed these concerns with employers, representative bodies and the GOC, but have not yet seen any progress in resolving them. We therefore recommend that the statement should be expanded to spell out the risks if IPC measures are not implemented thoroughly, and to emphasise that employers’ responsibilities include ensuring that appointment times allow for appropriate IPC measures including cleaning and disinfection of premises.

AOP response: Yes

Some degree of IPC will remain necessary as long as COVID-19 is in circulation, and the statement points to Government and College guidance which should reflect the progress of the pandemic and enable practices to take proportionate measures as risk levels change.

AOP response: Negative impact

This is because the statement does not do enough to reinforce employers’ responsibilities to allow enough time for IPC measures between appointments.

AOP response: Yes

We think this could be helpful if the responsibilities of employers are clarified, as we have recommended in our answer to Q30. The content of the statement could be incorporated into the GOC’s standards for individual and business registrants.

AOP response: Yes

The statement is largely for information, including the channels through which registrants can express interest in being redeployed. It includes a reminder that registrants should check that appropriate indemnity cover is in place, and a steer to seek guidance from the optical professional bodies if needed.

AOP response: Don't know

The statement seems much less relevant in the amber and green phases than the red phase.

AOP response: Don't know

We are not aware of any cases of AOP members working in pharmacy during the pandemic.

AOP response: Yes

The statement is very thin but doesn’t contain anything wrong or unhelpful. The material in para 9 might be helpful to registrants in listing sources of advice and information that registrants can take into account when exercising their professional judgement.

AOP response: Yes

It might as well.

AOP response: Don't know

AOP response: No

We don’t think the statement is significant enough to become a permanent policy position. The information in para 9 could be incorporated into the GOC’s standards when they are next reviewed, as with statement GOC/COVID/11 on infection control.

However, we think it would be helpful if the GOC could develop new guidance for registrants on the use of remote consultations after the pandemic. The joint regulators including the GOC have already published high level principles for good practice in remote consultations and prescribing, but this only applies to ‘healthcare professionals with prescribing responsibilities’ and so does not apply to most GOC registrants. This means that registrants without a therapeutic specialty have no guidance they can rely on if they want to provide remote consultations post-COVID-19. These kinds of technologies are already commonplace in other healthcare sectors, and we think it is likely that our members will want to continue using them post-COVID, with appropriate safeguards in place.

AOP response: No

In previous discussions on this statement we have repeatedly asked the GOC to amend it, because the statement didn’t make it clear that the GOC was acting outside its legal powers by serving notices electronically without explicit consent, and didn’t give sufficient assurance that the GOC will treat registrants fairly if they are disadvantaged by electronic service.

Section 23A of the Opticians Act enables the GOC to make rules allowing statutory notifications to be served electronically, but the GOC hadn’t made such rules when the statement was issued or when this consultation was launched. Section 23A also requires that any such rules “shall secure that a notice cannot be served by an electronic communication unless [the recipient] consents in writing to the receipt of notices from the Council by electronic communication”. The GOC’s statement was therefore inconsistent with these statutory requirements.

We expect the GOC as a statutory regulator to be clear in its statements about the legal powers underpinning its work, and to align its approach to those powers. This is not just an abstract point. As discussed in previous exchanges between the AOP’s professional discipline team and the GOC’s casework team, before and during the pandemic, and as outlined in our response to Q13 above on statement GOC/COVID/05, the practice of sending documents via electronic means only can cause real practical difficulties for some of our members, at what is already naturally a difficult and stressful time for them. We have therefore proposed previously that the GOC should agree to send notifications by hard copy as well where a member requests a hard copy.

The GOC made some changes to its initial draft statement in response to our comments, but didn’t address our fundamental concerns. The GOC told us it accepts that the legislation does not provide for electronic service of statutory notices, but that its current approach is “a proportionate measure to maintain our overarching objective to protect the public during the pandemic”.

We replied that while a decision to breach part of the statutory framework on the grounds that it’s a proportionate measure in pursuit of the GOC’s over-arching objective may be quite reasonable, it is still a significant and unusual step. We therefore thought that it should be spelt out clearly in the policy statement – so those affected can understand what the GOC is doing and why, and can challenge it if necessary.

As discussed in our response to Q13 above, since the launch of this consultation a statutory instrument has been published, setting out powers to come into force on 14 December 2020, before the close of the consultation. These include powers to serve statutory notifications electronically. This finally brings the legislation into line with the GOC’s policy statement. It remains our view that it is not reasonable for a regulator to issue a statement which gives a misleading impression of the legal basis for its actions.

On the practical issue of the impact of electronic service on registrants, the GOC has told us that:

“The GOC fully recognises that some registrants may be disadvantaged by the service of statutory notices by email, and we will be sensitive to any personal or practical difficulties caused by, for example, health, accessibility or technological issues.  In addition to serving removal notices by recorded delivery, and telephoning those registrants to ensure that they are aware of the situation, we will serve all statutory notices by post where this is requested.  The public consultation will provide further opportunity for us to understand and address the impact on registrants”.

This is more detailed and helpful than the current wording in paragraph 8 of the statement, which says “if an applicant is having particular difficulty in receiving emails, we will consider advance requests to send a specific communication by hard copy”. We therefore recommend that these commitments be incorporated into a revised version of the statement.

AOP response: No

For the reasons set out in our response to Q41 we do not think this statement as currently drafted should continue to apply. If the GOC amends the statement on the lines we have requested, to include suitable safeguards for registrants who are disadvantaged by electronic service, then in principle it would be reasonable for the statement to apply at least in the red and amber phases of the pandemic, while social distancing requirements remain in place and it is more difficult than usual for the GOC to serve notices by other means.

AOP response: Very negative impact on optoms and DOs

As discussed in our response to Q41 above, the use of electronic service without explicit consent for significant statutory notices has caused significant detriment for some AOP members, and is likely to cause greater detriment to registrants who do not benefit from representation in the course of GOC proceedings.

We note the draft impact assessment the GOC has published alongside this consultation accepts the potential for electronic service of notices to cause “issues for registrants with poor computer skills which could be related to possible characteristics such as age, disabilities or those in lower socio-economic groups” (p5), and says that in response, the GOC “should take care to ensure that we clearly communicate that [service of notices] is one of the usages of the email addresses that we collect and that adjustments are made should a registrant raise an issue related to access” (p9-10). We expect the GOC to act on this commitment, as we have recommended in our response to Q41.

As discussed in our response to Q41 above, the emergency powers bring the legislation into line with the GOC’s policy statement. However, now that the GOC has secured these powers, it must still ensure that it treats registrants fairly where they are disadvantaged by electronic service of notices. The GOC should therefore be prepared to use other channels to serve notices where appropriate, as we have said in our response to Q41.

Since long before the pandemic the AOP and the other optical sector bodies have argued for changes to the list of medicines exemptions applying to GOC registrants. These changes would be particularly helpful in the context of the pandemic and any future similar emergencies, since they would enable optical practices to prescribe a wider range of antibiotics and anti-allergy medicines without sending the patient to their GP, and would also support the Coronavirus Urgent Eyecare Service and other extended services delivered in primary care.

The GOC is aware of and supports this proposal, but the changes does not seem likely to come into force for at least another year because of capacity constraints in DHSC and MHRA relating to COVID-19 and Brexit. We would welcome any influence the GOC can bring to bear to help ensure the changes are introduced as soon as possible.

Many of the COVID-19 statements the GOC has produced have been helpful, and despite the unavoidable time pressures involved the GOC has sought to give us and other stakeholders at least a brief opportunity to provide feedback on statements in draft. However, we do not feel that this feedback has always been properly considered, as discussed in our response to Q41 above. More generally, in our view and that of many of our members, the GOC should have done more to provide direction to registrants at the start of the pandemic, particularly on issues relating to patient safety. 

The GOC’s statement of June 2020 on the reopening of optical practices caused a great deal of confusion and concern within the sector, not least because it appeared to overlook the public health implications of practices providing private routine care during the lockdown. The GOC issued a revised statement later in June and has acknowledged that its original statement could have been clearer. The GOC’s registrants, including our members, naturally give considerable weight to the GOC’s regulatory statements, and it is important that the GOC avoids similar problems in future.  

During the COVID-19 crisis, we have consulted with the GOC on new policy and guidance on its fitness to practise processes, which has been required to adapt to a new way of working. As outlined in our answers to some questions in Part 2 of this consultation, we have been concerned that the GOC has been unwilling to acknowledge that not all cases are appropriate for remote hearings. Although the remote hearings protocol now states that “some matters may require a physical hearing, and the hearings team will take account of all relevant factors in determining whether a case can be conducted remotely” it also states that “The GOC's position is that all events are suitable for a remote hearing”. This is inconsistent.

The GOC has at times focused on the concept of the “interests of justice” rather than on the GOC’s statutory purposes. Conversely, at times in these discussions the GOC seemed reluctant to address fundamental issues of natural justice, such as the right to a fair hearing.  

We have referred to the draft impact assessment in our responses to Q28 on the verification of contact lens specifications, and Q43 on the electronic service of notices. We have no further comments on the impact assessment.