Brexit Statement

« View all News items
09 Feb 2017

The Royal College of Surgeons of Edinburgh’s sole purpose – and the main concern of our Fellows and Members - is to ensure the safety of our patients and provide them with the best possible care. For over 500 years our charitable aims have focused our work on providing the education, training and examinations which support the surgical workforce.

As a College which represents many thousands of professionals working in the NHS in all four nations of the UK, we are well placed to advise on the issues that affect the whole of the UK, and on the specific problems that can occur in each individual healthcare system. Therefore, following the decision to leave the EU, we have written to the three Health Secretaries in England, Wales and Scotland, in order to outline a number of the implications the UK Government’s approach will have for the NHS structures in the UK, and to offer our assistance. We have already had useful talks with the Chief Medical Officer for Northern Ireland and his deputy, and look forward to continuing this dialogue with the new Health Secretary once the appointment is made.

Whatever the merits or otherwise of the decision to leave the EU, the College’s primary concern relates to the need to maintain the quality and standards of health and social care in the UK and the likely impact on the NHS and UK health services. We have started by outlining the following areas of consideration. Although this list may not be comprehensive as new issues will arise during the transition, we consider the following to be of primary concern.

  • Working Time Regulations [EWTR] – As applied to the medical profession, working time regulations have been a matter of controversy with the lack of flexibility, as well as the impact on training opportunities and service delivery, being a cause for concern for some groups. Withdrawal from the EU gives the opportunity to develop proposals which explicitly suit the needs of the UK health services. Whilst some people would welcome greater liberalisation of the regulations we would argue that any changes should not result in an increase in the maximum number of hours which it is legal to work.
  • Recognition of qualifications and education issues - There are a range of issues relating to the regulation and education of health professionals which need to be addressed. These include transferability and recognition of European qualifications for doctors, routes of access to the specialty register (CESR/CEGPR and CCT), and requirements for language testing. It is recognised that in some instances Brexit may provide the opportunity for a more flexible approach which suits the UK’s requirements. There will, however, be issues where the College would want to see consistency maintained on a UK-wide basis to ensure there are no barriers to free movement within the UK.
  • Science and Research – There are four main threats: the loss of a net benefit of €3.4billion from the EU research budget across the UK; potential restriction to the freedom of movement of academic and scientific staff; potential restriction of access to European clinical trial databases, and finally; the need to replace EU research regulations. Brexit negotiations must develop clear and coherent plans to safeguard scientific research across the UK, and we must develop a specific plan to ensure it is not at a disadvantage.
  • Reciprocal Health Arrangements/EHIC - There are approximately 2 million UK citizens currently living, working and travelling in the EU, although it is not clear how many of these are from each constituent part of the UK. Currently, EU membership entitles our citizens access to the host country's public healthcare system on the same basis as the indigenous population. There has to be clarification if current EHIC arrangements would continue to operate. Post-Brexit, it remains to be seen what the impact on the NHS would be of large numbers of UK citizens choosing to repatriate to the UK to access healthcare, recognising that many will be older people with more complex needs.
  • Regulation of Medicines and health procedures - If not part of the European Medicine Agency (EMA) the UK would be unable to participate in the European wide approval system for new medicines and revisions to already approved products. We would not be able to participate in the Orphan Drug Designation and the Small to Medium Sized Enterprise schemes that the EMA operate nor to participate in the specific centralised approval process for paediatric drugs and the process that supports new medicines development for children. We would also lose access to the EU wide Pharmacovigilance networks and the EU Clinical Trials Database. Appropriate legislation will need to be developed to replace existing regulatory pathways and to interface where appropriate with ongoing European legislation.
  • Organ Donation - The European Union Organ Donation Directive (EUODD) sets minimum standards that must be met across all Member States in the EU, ensuring the quality and safety of human organs for transplantation.  NHS Blood and Transplant implements the EU rules on the procurement, storage, use and monitoring of all human tissue and blood in the UK. Decisions will need to be made about future arrangements and a potential opt-out system implemented in Scotland, as is the case in Wales, would mean a divergence from the rest of the UK in this area.
  • Communicable Diseases Network - Disease epidemics, infections and antimicrobial resistance all cross borders. It will be essential for the wellbeing of the whole population that the UK can continue to participate in the European Centre for Disease Prevention and Control.
  • Procurement - At present there are EU wide rules regarding procurement of public projects through open tender through OJEU (Official Journal of the European Union).  Whilst this is obviously not an issue exclusive to healthcare the NHS will need clarity over the rules for public project procurement in the future.
  • Environmental legislation and public health protection – Regulations that have maintained food safety, air, water and environmental quality, maintained health workplaces and employment conditions will need to be replicated across the UK.
  • Other safeguards to worker health that have been established through EU regulations - Requirements for health and safety in the workplace and the promotion of health employment need to be retained. In terms of NHS staff, existing directives govern the protection from exposure to chemical agents (e.g. Latex, glutaraldehyde, cytotoxic), biological agents (blood borne pathogens, viruses etc.), physical agents (radiation). These will need to be replicated after exit from the EU.
  • Infrastructure expenditure - Infrastructure projects affecting communities such as transport links, leisure facilities, community enterprises and support to businesses have been supported by the EU and promote wellbeing and employment. These are more likely to affect areas of higher deprivation and increase the risk of greater inequalities. This is a particular concern for the most rural and remote populations around the UK.


back to top of page