CDC HICPAC Nov 2024 Meeting Concludes with Low Standards of Infectious Disease Protections in Healthcare - The Public Must Respond by Nov 22!
CDC’s health care infection control committee (HICPAC) met on Nov 14-15 unwilling to establish robust, science-based infection control guidelines, universal masking, broad use of N95s
The CDC’s Healthcare Infection Control Practices Advisory Committee (HICPAC) met November 14 and 15 with the majority of members voting to maintain current standards and not elevate them in infection control guidelines for healthcare settings. Their responses will be returned to the CDC who will develop a final set of recommendations. We originally asked you to send a comment asking HICPAC to ensure the highest standards in infectious disease protection. The public spoke up in support of evidence-based guidelines during the public comment session while our community and advocacy groups have continuously pressured HICPAC to strengthen CDC’s infection control recommendations.
At this recent meeting, four key questions were reviewed and voted upon by the committee based on recommendations developed by the Isolation Precautions Guidelines and Healthcare Personnel Guideline Workgroups. Ultimately, HICPAC voted on responses to these questions that do not ensure adequate protection of patients and healthcare workers. During the course of this meeting, it was the recently appointed member and representative from the NY State Nurses Association, who primarily voiced the strongest support of higher standards of protection in healthcare settings. However, remaining members failed to incorporate public feedback and elected to not adopt science-based infection control measures.
Below is a summary of HICPAC’s responses to each of the four questions:
Should there be a category of Transmission-based Precautions that includes masks (instead of NIOSH Approved® N95® [or higher-level] respirators) for pathogens that spread by the air? Should N95 respirators be recommended for all pathogens that spread by the air?
A Summarized Response: The committee supports a category for transmission-based precautions; however, not all pathogens spread by the air do not need N95 respirators or higher.
Can the workgroup clarify the criteria that would be used to determine which transmission by air category applies for a pathogen? For the category of Special Air Precautions, can you clarify if this category includes only new or emerging pathogens or if this category might also include other pathogens that are more established? Can you also clarify what constitutes a severe illness?
A Summarized Response: The committee updated guidance of pathogens to include level of transmission, burden of morbidity and mortality, and spread over long distance through ventilation systems. The majority recommended routine air precautions to pathogens based on observed effectiveness of surgical masks in reducing risk of transmission and special air precautions could include other pathogens that are established, and severe illness was revised to morbidity and mortality and other outcomes to consider a broader set of adverse outcomes.
Is the current guideline language sufficient to allow for voluntary use of a NIOSH Approved N95 (or higher-level) respirator? Should the document include a recommendation about healthcare organizations allowing voluntary use?
A Summarized Response: The committee recommended that current guidelines are not enough to ensure healthcare personnel a voluntary option to use N95 or higher level respirators and recommended against a guideline that specifies that healthcare organizations must allow a voluntary option, as they believe current language was sufficient for this option.
Should there be a recommendation for use of source control in healthcare settings that is broader than current draft recommendations? Should source control be recommended at all times in healthcare facilities?
A Summarized Response: The committee recommended against broader guidelines for source control (such as universal masking) in healthcare settings and that the decision instead be based on the local risk of transmission and epidemiology.
Using the suggestions/template below, we urge you to submit another comment to HICPAC in response to their response to questions by their final meeting comment deadline this Friday, November 22, in order to show to the committee and the CDC that we disagree with their decisions. We provide additional supporting rationale below the template.
By November 22nd, we ask you to write to HICPAC and urge your disagreement with their responses to CDC’s questions, and that the CDC must ensure stronger guidelines that protect patients, healthcare workers, and the public, including universal masking in healthcare, and clear, strong protective protocols such as N95 respirators or higher for all diseases spread via inhalation of aerosols. You can either email them directly at HICPAC@CDC.gov or submit your demands through their website, by scrolling down to “Contact HICPAC Committee Management.”
We provide a template letter below. You may borrow or modify it for your own comment to HICPAC. Please personalize your comments. We also highly recommend National Nurses United’s talking points to strengthen healthcare infection control broadly. Learn more about the history of NNU’s impact on HICPAC and a recent article about the work.
How to use the letter to HICPAC, (which should be a maximum of 1 single-spaced page):
Either email them directly at HICPAC@CDC.gov or submit a comment via their website. Edit the letter as you wish (or write your own using the letter for inspiration or talking points). Submit your comments by Nov. 22 as a response to the committee’s recommendations.
Please personalize your letter/comment, ideally starting with a brief statement on why you value the highest infection control standards in healthcare (including the importance of N95 or higher respirators), and how lack of universal masking in healthcare or lack of a layered mitigation approach has impacted your life or your community. For example:
Delayed or missed medical appointments
Unsafe healthcare experiences, such as with workers or other patients who showed symptoms of COVID or other aerosol-transmitted infectious diseases
Infections or potential exposures that occurred in healthcare settings
Challenges faced in asking healthcare workers to mask
Disproportionate impacts of the lack of masking in healthcare on high-risk patients and marginalized communities.
Letter template (Title of Email: Response to HICPAC Nov 2024 Decision)
CDC and HICPAC Members:
This past week’s HICPAC responses in November 2024 failed to incorporate public feedback to ensure the highest standards of protection and instead weakened infection control guidelines for healthcare workers and patients. The CDC must reconsider HICPAC responses instead prioritize the health of patients and healthcare workers before finalizing recommendations. Healthcare should not make us sick.
Instead, I urge the CDC to take public comments seriously and develop recommendations that ensure higher standards of protection than the response by HICPAC on infection control guidance. The CDC must ensure recommendations that align with scientific evidence. HICPAC must establish universal masking in healthcare as a new standard of infection control across all settings for the following reasons:
Many healthcare exposures to aerosol-transmitted infectious diseases (including COVID, measles, influenza including avian influenza, and TB) are preventable through multiple mitigation measures including isolation procedures, universal masking, ventilation, and air purification.
Many aerosol-transmitted pathogens are transmissible without symptoms and without predictable seasonality. Diagnosis and isolation may be delayed, leading to exposures that could have been prevented by universal masking.
Well-fitting N95 or better respirators provide both protection for the wearer and source control. One-way masking offers limited protection; respirator masks should ideally be worn by all to reduce transmission. Hospitals should distribute N95 grade masks to visitors and staff, and also to patients for use when feasible.
Universal masking protects patients when they cannot mask (such as infants, people with specific medical conditions and during procedures involving the nose or mouth).
When masking is only on request, people are unprotected in many shared spaces such as lobbies and waiting rooms.
HICPAC must recommend N95 respirators or higher for pathogens spread in the air and ensure protective measures in all types of healthcare facilities: higher HVAC standards including air filtration and ventilation, clear and robust isolation protocols to separate infectious people from others – including by routinely testing staff and patients for COVID and other infectious diseases, isolating and cohorting infectious patients, and keeping staff with an active infection away from healthcare facilities and in-person patient contact.
The public expects guidelines that ensure the highest levels of protection in healthcare settings from pathogens spread in the air. HICPAC and ultimately the CDC must develop a set of revised recommendations that not only effectively protect patients and healthcare workers but also protects and allows for the most protective tools against infectious diseases.
Additional points you could make, in place of some points above, to help convey that CDC guidance for infection control in healthcare must be stronger in multiple ways:
With documented avian influenza cases in humans continuing to rise, CDC must act vigorously to prevent its spread and the spread of other emerging pathogens in healthcare. CDC guidance on this – and in general – must follow the precautionary principle, promoting strong protective measures against potential risks, rather than waiting to react to outbreaks.
HICPAC recommendations for updated CDC guidance failed to recognize the science on aerosols and inhalation transmission of infectious diseases, including that distance alone is not sufficiently protective.
The science is clear: for healthcare workers, patients, and others, loose-fitting surgical masks are not sufficient to prevent transmission of infectious aerosols.
CDC guidance must establish clear obligations for employers to provide protections; CDC must not allow early pandemic crisis standards of personal protective equipment (PPE) use to become permanent. Allowing the “flexibility” for healthcare systems to provide inadequate PPE puts both patients and healthcare workers at risk for the benefit of healthcare system profits.
Many problems continue to arise from a narrow composition of the committee and its workgroups and the failure to consult appropriate sources, experts, and representatives from affected communities. As National Nurses United recently urged the CDC, “expand the perspectives represented on HICPAC and its IPG Workgroup, including by adding direct care health care workers, patients, their families, unions, and experts in other fields such as respiratory protection, aerosol science, occupational health, and industrial hygiene.”
HICPAC’s current approach overlooks the public. Most similar committees solicit public comment through the federal government’s regulations.gov portal, which makes them publicly viewable, while HICPAC has instead asked the public to send comments either through their website or via email. Meanwhile, some organizations have received reports that individuals who submitted written comments did not see those comments included in HICPAC’s official records.
Additional rationale for strengthening CDC’s infection control guidance
For at least the last year and a half, public health advocates have been trying to stop HICPAC from weakening healthcare infection control guidelines and putting healthcare systems costs above worker and patient safety. Our path forward is clear: To protect patients and healthcare workers, we must speak up to demand effective, scientifically-supported standards in infection control for aerosol-transmitted infectious diseases in healthcare settings.
HICPAC’s current approach overlooks the scientific evidence in many ways that increase infection risks across multiple infectious diseases. CDC’s Isolation Precautions guidance must recognize that many infectious diseases, including COVID, pose year-round risks. Healthcare Personnel guidelines must recommend science-based isolation periods for healthcare workers infected with COVID as well as other infectious diseases that pose a risk to patients, coworkers, and the community.
Despite the demonstrated benefits of universal masking in healthcare settings in the ongoing COVID pandemic, HICPAC’s recommendations have failed to integrate this lesson to prevent avoidable healthcare-acquired infections. In order to properly protect patients and healthcare workers from these preventable infections, HICPAC must recommend consistent use of N95 or higher quality respirators for aerosol-transmitted pathogens in its infection control guidance and protective isolation protocols. In addition to implementing universal masking and expanding the use of N95 respirators, CDC guidance must address the full range of measures to control aerosol infectious disease transmission broadly throughout all healthcare settings, including enhanced ventilation, air filtration, isolation, and routine testing.