Isolering

Helsedirektoratet åpner for tvangsisolering av utviklingshemmede

Helsedirektoratet har godtkjent en søknad fra Horten kommune om å tvangsisolere utviklingshemmede i en hytte som Helsedirektoratet har godkjent til formålet. Godkjenningen er ulovlig og heller ikke i samsvar med smittevernlovens intensjon.

Vi trenger ikke mer tvang, men tiltak for å bli kvitt tvangsbruken

Helsedirektoratets godkjenning er ytterst problematisk både faglig, menneskelig og juridisk. I utgangspunktet mangler myndighetene kontroll med tvangsbruken. Riktig nok skal all tvangsbruk være nødvendig og andre tiltak skal være prøvd først, men forståelsen av disse skjønnsmessige begrepene varier. Når det gjelder vedtak etter helse- og omsorgslovens kapittel 9, så lå tidligere Hedmark fylke på topp med tvangsvedtak på rundt 12 prosent av voksne utviklingshemmede, mens Finnmark lå på bunn med tvangsvedtak på rundt 1 prosent.

Kontrollen med tvangsbruken er tradisjonelt svært svak.

Med Cov-19 epidemien, ble det verre. Kommunene innførte et hav med ulovlige og inngripende tvangstiltak overfor voksne med utviklingshemming. Verken Helsetilsynet eller Fylkesmannen grep inn. Helsedirektoratet ga riktignok informative veiledere som de ansvarlige i kommunene enten ikke leste eller ikke brudde seg om. Selv nå, når landet er gjenåpnet, er det mange kommuner, inkludert Oslo, Bærum, Asker og et hav med andre kommuner som opprettholder ulovlige smitteverntiltak overfor mennesker med utviklingshemming selv når landet er på vei tilbake til normalen.

I denne situasjonen er det ikke flere tvangshjemler som trengs. Det trengs en innsats for å redusere tvangsbruken.

Smittevernloven ble sist revidert våren 2019. Stortingsrepresentanter som var aktive i lovrevisjonen stiller seg undrende til Helsedirektoratets lovforståelse som avviker betydelig fra lovgivers forståelse.

Saken fra Horten

Horten kommune skriver:

"I enhet for voksenhabilitering i Horten kommune er det flere tjenestemottakere som ved behov for kortvarig karantene og/eller isolasjon grunnet Covid-19 smitte, vil motsette seg dette. Noen av disse personene har ikke kognitive forutsetninger (psykisk utviklingshemming) til å verken forstå eller tilegne seg forståelse for karantene og/eller isolasjonsregler. Med bakgrunn i den kjennskap vi har til noen av disse tjenestemottakerne gjennom flere års tjenesteutøvelse – er det svært sannsynlig at enkelte av disse tjenestemottakerne vil yte motstand mot å bli satt i karantene og/eller bli holdt på isolat."

Kommunen argumenterer for at personene dette gjelder vil få det bedre på hytten som kommunen søker om å få godkjent for tvangsisolasjon. Videre argumenterer kommunen med bakrunn i andre beboere i bofellesskapet hvor personene har sitt hjem.

Jeg kjenner ikke personene som voksenhabiliteringen i Horten sikter til, men det gjør heller ikke juristene i Helsedirektoratet. Tillatelsen som Horten kommune fikk, gjelder en ubestemt krets av utviklingshemmede.

I praksis betyr det at kommunelegen sammen med vakthavende infeksjonsmedisinske overlege ved sykehus i helseregionen, er tildelt myndighet til å sende innbyggere med utviklingshemming til Horten kommunes hytte for tvangsisolasjon. Rettsikkerheten er i praksis fraværende. Rett nok skal slike hastevedtak bringes inn for smittevernnemnda. Både hastevedtaket og vedtaket i smittevernnemnda kan bringes inn for tingretten. Men rettsikkerhetsprosedyrene er rimelig irrellevante i forbindelse med Covid-19. For de fleste vil isolasjonsperioden være 7 døgn etter at symptomene viste seg. Det har lite for seg om en får vedtak om opphevelse av isolasjonen fra smittevernnemnda den 8. dagen. Det å få tingretten til å behandle isolasjonsvedtaket noen måneder etter at isolasjonen er over, er meningsløst.

Kommunen må ha en plan for hjemmeboende tjenestemottakere og deres pårørende i ulike faser av covid-19-epidemien, i følge Helsedirektoratet. Etter Helsedirektoratets vedtak, er det åpenbart at Horten kommunes plan er tvunget isolasjon av noen av innbyggerne med utviklingshemming. Fra kommunens side, er slike planer enkle å forholde seg til. Når Helsedirektoratet har godkjent at personene skal flyttes og tvangsisoleres ved eventuell smitte, så er det heller ingen grunn til å planlegge tilrettelegging av bosituasjonen, tjenestene og leveforholdene slik at en unngår tvangsbruk.

Saken fra Horten er prinsipiell

Helsedirektoratets imøtekommelse av Horten kommunes søknad, viser at direktoratet aksepterer at utviklingshemmede kan tas ut av sitt hjem og plasseres i et kommunalt bygg som Helsedirektoratet har godkjent til slik bruk. Når Horten får anledning til å plassere utviklingshemmede på en hytte, så er kan en ikke nekte en annen kommune å plassere utviklingshemmede på den nedlagte internatskolen.

I praksis betyr Helsedirektoratets vedtak at kommunene kan flytte og tvangsisolere utviklingshemmede etter eget skjønn. Et skjønn som vi har svært dårlige erfaringer med, spesielt når det gjelder smittevern og Covid-19-tiltak.

Samtlige tvangslover krever at en skal forsøke frivillige tiltak. Hvor seriøse og gjennomtenkte slike forsøk er, varierer i stor grad.

Helsedirektoratets vedtak er ulovlig

  • I smittevernloven § 5-4 tredje ledd står det at Helsedirektoratet kan godkjenne isolasjon i andre institusjoner når «særlige forhold krever det». Helsedirektoratet sagt at «den foreliggende situasjon med en pågående pandemi fyller kravet til «særlige forhold» i bestemmelsen. Påstanden er feil. I forarbeidene er det påpekt at «bestemmelsen tar først og frem sikte på å gjennomføre isoleringstiltak ved et alvorlig utbrudd». Til om med den 15. mai har 26 personer i Horten fått påvist smitte. Den siste måneden er det registrert en ny smittet persone i kommunen.  Det er altså ikke et alvorlig utbrudd i Horten, slik som smittevernslovens § 5-4 krever.
  • Den aktuelle hytten er, i følge søknaden fra Horten kommunes søknad, ment å være brukt overfor mennesker med utviklingshemming. Etter Grunnloven § 98 er alle like for loven. Ingen skal utsettes for usaklig eller uforholdsmessig forskjellsbehandling. Helsedirektoratets godkjenning er utvilsomt forskjellsbehandling. Svært få, om noen, tvangsisoleres. De fleste pålegges egen isololasjon, uten kontroll. Det å etablere egne institusjoner for tvangsisolering av utviklingshemmede står verken i forhold til hvordan andre grupper behandles eller i forhold til smittesituasjonen.
  • Horten kommune trekker frem utfordringene de aktuelle personene representerer overfor andre som bor i bofellesskapet. Det er kommunen som i praksis bestemmer hvor, hvordan og med hvem innbyggere med utviklingshemming skal bo. I stedet for å tvangsisolere utviklingshemmede, kan kommunen bedre bosituasjonen. Det er helt sikkert ikke bare i forbindelse med smitte at de aktuelle personenes oppførsel kan være til ulempe for andre beboere.
  • En egen måte for å isolere mennesker med utviklingshemming er diskriminerende i henhold til likestillings- og diskrimineringslovens § 6.

Flere forhold vil påpekes når NFU sender brev til Helsedirektoratet og ber dem omgjøre sitt vedtak.

Jens Petter Gitlesen

18 mai 2020

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