Re: Proposed changes to the CDC’s Isolation Precautions: Preventing Transmission of Infectious Agents in Healthcare Settings

September 07, 2023

To whom it may concern,

I echo calls from National Nurses United, the People’s CDC, and other concerned stakeholders to urge the Healthcare Infection Control Practices Advisory Committee (HICPAC) to strengthen, not weaken, airborne infection controls in healthcare settings. Weakening these protections will jeopardize the safety of everyone who needs or works in healthcare, and will be especially dangerous for medically vulnerable people.

COVID-19 transmission continues despite the availability of vaccines, and reinfections and so-called ‘breakthrough’ infections are common. SARS-CoV-2 is subject to Biosafety Level 3 protocols for a reason. Each case of COVID-19 carries risk in both the acute stage and longer term. This includes the risk of developing or exacerbating Long COVID, which can be debilitating. Nosocomial cases of COVID-19 tend to be deadlier than the average community-acquired case because the affected population is more likely to be medically vulnerable. Weakened protocols will be especially perilous for this population, and are at odds with best practices for including and protecting the rights of people with disabilities.

The proposed guidelines will result in weakened protections that put workers and patients at risk. They include continued, limited recommendations for use of surgical/medical masks, rather than N95 respirators, and fail to account for asymptomatic and presymptomatic disease transmission. HICPAC should instead recommend universal N95 respirator use in healthcare facilities to protect both workers and patients. HICPAC’s guidelines should also better address early identification and isolation of infected people.

Healthcare facilities should also implement engineering controls to reduce airborne transmission. At a minimum, facilities should implement the indoor air quality standards suggested by The American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) to control infectious aerosols. Ventilation and filtration are key to reducing the airborne spread of dangerous pathogens like SARS-CoV-2. Their exclusions from HICPAC’s draft must be rectified.

Rather than weakening the current guidelines, HICPAC should move to protect both workers and patients by updating protocols to reflect the latest science on the airborne spread of disease. The CDC and HICPAC should also move to improve their development and review process by increasing transparency and stakeholder outreach.

HICPAC must acknowledge the substantial toll of recurrent COVID-19 infections and Long COVID, and take seriously the duty of medical providers to “do no harm.” Medically vulnerable individuals should not have to choose between accessing the care they need and protecting themselves from a serious infection. Workers should not have to choose between fulfilling their job responsibilities and keeping themselves and their families safe. HICPAC can and should provide guidance that ensures the safety of both of these groups.

Thank you,

Hayley Brown
Research Associate
Center for Economic and Policy Research

An earlier draft of this letter was submitted to the CDC as a public comment on August 25, 2023.

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