Over 900 occupational safety, aerosols science, public health, and medical experts have written to new CDC Director Mandy K. Cohen, MD, MPH, informing her that CDC’s Healthcare Infection Control Practices Advisory Committee (HICPAC) must correct their review on COVID infection control measures to reflect the science of aerosol transmission through inhalation and their decision-making process must include patient advocates, infectious disease transmission scientists, aerosols scientists, healthcare personnel (providers and other frontline workers such as cleaning crews), union representatives, and occupational safety and health experts. HICPAC is a CDC committee that oversees policies and protocols on the prevention of infectious diseases in healthcare settings.
People’s CDC Recommendations for CDC/HICPAC:
Seek input on proposed changes during the development of the draft guidelines, using the Federal Register public notice process and town hall meetings with virtual options, from the public and all key stakeholders, including:
Health care personnel and their representatives.
Industrial hygienists, occupational health nurses, and safety professionals.
Engineers, including those with expertise in ventilation design and operation
Research scientists, including those with expertise in aerosols and respiratory protection.
Experts in respiratory protection, including scientists from NIOSH’s National Personal Protective Technology Laboratory (NPPTL) and the Occupational Safety and Health Administration (OSHA).
Patients, patient advocates, and disability justice groups.
Make the process for updating the guidelines fully open and transparent. HICPAC is chartered under the Federal Advisory Committee Act (FACA) and should operate with openness and full transparency.:
Use the Federal Register public notice process to announce the meetings, agendas, draft work products, and planned attendees, as well as to solicit written and oral public comments.
Open work group meetings to the public with virtual options and with ample time set aside for public comments.
Post work group reports, all presentations to the workgroup and committee, public comments, and transcripts and recordings of the HICPAC meetings on the CDC website in a timely fashion (within 30 days).
Final guidelines should include an attachment that lists the public’s comments, and why each one was or was not adopted, with references to scientific evidence.
Ensure the CDC’s and HICPAC’s understanding and assessment of key scientific evidence is up to date with the most current knowledge by seeking input from a multidisciplinary set of scientific researchers and the key stakeholders, and by making those written reviews publicly available:
Fully recognize aerosol transmission through inhalation of SARS-CoV-2 and other infectious aerosols and establish the highest infection prevention protocols for any proposed “transmission by air” category.
Ensure that updated guidance includes the use of multiple control measures that have been shown to effectively prevent transmission of infectious aerosols, including frequent testing, proper ventilation, air cleaning/purifying technology, isolation, respiratory protection, and other personal protective equipment (PPE).
Communicate that each infection control measure is most effective when the other infection control measures are also implemented in a layered approach to reducing transmission risk.
Implement mandatory continuing education with updated aerosol infection transmission information and fit testing for all healthcare personnel.
Recommend development and implementation of education about updated aerosol infection transmission information for all patients and their visitors, in the form of videos and pamphlets that are accessible to all patient populations.
Create concise control guidelines that recognize transmission characteristics of SARS-CoV-2.
Much transmission is asymptomatic. Therefore, all precautions must be universally practiced at all times.
Healthcare settings are where high risk, disabled, and seniors will mingle with infected patients, visitors, and staff. Therefore, healthcare facilities and personnel should employ all precautionary strategies.
Pre-symptomatic and pre-positive-test transmission are possible.
Guidance around what to do when one tests positive must include the latest scientific evidence on how long one is contagious before testing positive and/or showing symptoms so individuals know who to inform about exposures.
All people should be presumed infectious because they might be, and should take all precautions against spreading the virus.
Test all healthcare personnel regularly, including everyone who reports to a healthcare facility of any size or type. Anyone with symptoms of aerosol-transmitted infection of any type (cold, flu, COVID-19, tuberculosis, etc.), or who tests positive, must not enter the healthcare facility and must be supported with paid leave, or if appropriate, remote work.
SARS-CoV-2 is aerosol-transmitted and can remain suspended in the air for hours, similar to measles. Therefore, guidance should state:
The CDC's guidance from January 2020 should continue to apply: "Standard practice for pathogens spread by the airborne route (e.g., measles, tuberculosis) is to restrict unprotected individuals, including HCP, from entering a vacated room sufficient time has elapsed for enough air changes to remove potentially infectious particles.”
Healthcare organizations should maintain and strengthen respiratory protection and other PPE requirements and access as critical methods for preventing health care personnel and patient inhalation and transmission of infectious aerosols.
Universal PPE for healthcare workers and patients in healthcare settings should be employed at all times to control aerosol-transmitted virus spread. Universal masking is necessary to make healthcare settings more accessible to vulnerable people and those who cannot mask, including individuals with conditions that make masking prohibitive, and infants.
Fitted N95s respirator-type masks clearly provide superior protection against the exposure to and transmission of infectious aerosols and droplets, compared to surgical masks. HICPAC should emphasize procedures that would significantly improve implementation, such as fit testing to remove leakage and widespread, free availability of a variety of respirators to fit various face shapes.
Facilities should implement minimum indoor air quality standards that have been set by The American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) ASHRAE to control infectious aerosols in all healthcare settings.
Outdoor transmission is possible. When communicating transmission risk in crowded spaces, explicitly state that it includes outdoor healthcare spaces, such as parking garages, sidewalks, and pop-up tents (as may be used for health fairs and other healthcare outreach events).
Healthcare systems should encourage free vaccination and boosters as recommended per age-appropriate ACIP schedules for all aerosol-transmitted infectious diseases for all healthcare personnel, patients, and visitors, unless medically contraindicated.
Reference guidance from CDC in January 2020
https://stacks.cdc.gov/view/cdc/84639/cdc_84639_DS1.pdf
