CRITCON-Pandemic Levels with an associated Operational Responsibility Matrix were recently published by the Intensive Care Society as a modification to Winter Flu CRITCON levels, to better account for differences between a winter flu surge in critical care activity and the capacity challenges of the COVID-19 pandemic1. In this paper we propose an expansion and explanation of the Operational Matrix to suggest a stepwise ethical approach to clinician responsibility. We propose and outline the main ethical risks created at each level and discuss how those risks can be mitigated through a balanced application of the predominant ethical principle which in turn provides practical guidance to clinician responsibility. We thus seek to specify the ethical and legal principles that should be used in applying the Operational Matrix, and what the practical effects could be.