National Assembly for Wales / Cynulliad Cenedlaethol Cymru
Health and Social Care Committee / Y Pwyllgor Iechyd a Gofal Cymdeithasol


Safe Nurse Staffing Levels (Wales) Bill / Bil Lefelau Diogel Staff Nyrsio (Cymru)

Evidence from Royal College of Speech and Language Therapists – SNSL(Org) 13 / Tystiolaeth gan Coleg Brenhinol y Therapyddion Iaith a Lleferydd – SNSL(Org) 13


Wales Policy Office


Suite 2.3, 2nd Floor

33-35 Cathedral Road

Cardiff CF11 9HB








Health and Social Care Committee,

National Assembly for Wales

Cardiff Bay,

CF99 1NA



21st January, 2015



Dear Committee Member


Safe Nurse Staffing Levels (Wales) Bill – Written Evidence from the Royal College of Speech and Language Therapists


The Royal College of Speech and Language Therapists (RCSLT) welcomes the opportunity to provide written evidence to the Health and Social Care Committee on the above Bill. In providing evidence, we wish to reiterate our commitment to provide the highest standards of patient care and to the best outcomes for patients.  However, we are firmly of the view that this can only be achieved through a holistic, multi-disciplinary approach based on the individual needs of the patient.  We are also concerned that if resources are diverted to increase nurse staffing levels following legislation then this may have a detrimental impact on other essential services.


We also question whether legislation for minimum nurse staffing levels will hinder or enhance the Welsh Government’s Prudent Healthcare Policy for Wales.  Prudent Healthcare has not yet had sufficient time to become properly embedded in the delivery of healthcare in Wales and is likely to have an impact, not only on staffing levels, but also on the development of a more diverse workforce and mix of skills required in the future.  We are of the view that the proposed legislation will fetter the ability of NHS Health Boards and Trusts to respond to the Prudent Healthcare principles – particularly in terms of workforce planning, promoting equity and co-production.


For these reasons we do not support a legislative approach that is entirely focused on nurse staffing levels. 







Response to consultation questions


  1. General


1.1       Is there a need for legislation to make provision about safe nurse staffing levels?


We are committed to ensuring the highest quality patient care based on a   person-centred approach that is safe, compassionate and effective.  We are firmly of the view that delivering the best outcomes for patients can best be achieved through a multi-disciplinary approach based on the needs of the patient.  Legislation for mandatory staffing levels will not guarantee patient care.


We are concerned that a focus on nurse staffing levels in isolation risks overlooking other important factors that affect outcomes and experience for patients.


1.2       Are the provisions in the Bill the best way to achieve the Bill’s overall purpose (as set out in section 1 of the Bill?)


We have concerns over clarity in terms of terminology used.  For example, the Bill states that nurses should be deployed in ‘sufficient numbers’, to enable ‘safe nursing care’.  However, it is unclear as to what ‘sufficient numbers’ or what ‘safe nursing care’ should be in relation to staffing levels.


We support the view of the NHS Nurse Director in Wales that there needs to be clear professional judgement to ensure that flexibility in staffing remains a critical part of meeting patient needs.  In the wake of the Francis Report, there is already an assessment process to determine staffing levels on wards based on the severity of patients’ conditions rather than on patient numbers. 


1.3       What, if any, are the potential barriers to implementing the provisions of the Bill?  Does the Bill take sufficient account of them?


The focus of the Bill is on nurse staff