The duty of equivalence says infection control in custody cannot fall below the community standard. Yet the community's main hand-hygiene product is the one custody cannot safely use.
Prisons are classed as higher risk for respiratory transmission: confined, over-crowded and high-turnover, with the adult men's estate running at around 97.7% capacity and an outbreak declared on as few as two linked cases in five days. A single UK men's prison saw COVID-19 attack rates of 9.2% and then 18.7%. When infection moves, it moves fast.
But the standard tool is restricted. UKHSA infection-control guidance for adult prisons limits wall-mounted alcohol hand rub because dispensers carry a risk of ingestion and unintended use. Alcohol gel is also a Class I flammable liquid, pulling it into DSEAR and COSHH duties, and a documented intoxication, self-harm and contraband route in secure settings.
So the estate carries the community's infection risk under the duty of equivalence, while being denied the community's primary defence against it. That gap is not a preference, it is written into the regulator's own guidance, and it is what an alcohol-free option is built to close.