‘UK Legal Position

Biological Agents (such as SARS-CoV-2) are covered under the Control of Substances Hazardous to Health (COSHH) Regulations 2002.

COSHH provides a framework of actions designed to control risk. from exposure to hazardous substances.’

#AFRSMisNotPPE

/1
‘The Approved Code of Practice (ACOP) to COSHH Regulation 7 states that if employers cannot prevent exposure to a biological agent, they should take steps to ensure that it is controlled adequately & consider all the requirements set out in regulation 7(3), (4), (6) and (7).’

/2
‘They [employers] should apply the principles of good practice and use each requirement where, and to the extent that:
• it is applicable;
• the assessment carried out under regulation 6 shows that it will lead to a reduction in risk.’

/3 #AFRSMIsNotPPE
‘HSE guidance document HSG53 states ‘when in an airborne state, micro-organisms can be classed as particles, so can usually be removed by filter-type Respiratory Protective Equipment (RPE).’

/4

#AFRSMIsNotPPE
‘You should always use equipment fitted with the highest efficiency filter possible (protection factor of at least 20) to control exposure down to the lowest levels.’

Therefore HSE recommends the use of an FFP3 for use against viruses.’

/5


#AFRSMIsNotPPE
Miss that?

‘Therefore HSE recommends the use of an FFP3 for use against viruses.’

‘Therefore HSE recommends the use of an FFP3 for use against viruses.’

‘Therefore HSE recommends the use of an FFP3 for use against viruses.’

/6


#AFRSMIsNotPPE
‘Whilst FFP3 is the usual recommended control measure, it may not be reasonably practicable to use these if global supplies of FFP3 masks are low during a pandemic.

In this scenario, an FFP2 could be used as an alternative, as this is consistent with WHO guidance.’

/7
17 Nov 2021

IPC Cell guidance - unknown members, within @UKHSA

Droplet IPC precautions for SARS2 as it is not ‘wholly’ airborne, unless during an AGP, or in an AGP hotspot.

/8


#AFRSMIsNotPPE
Conclusions:

☣️ UK IPC guidance is in breach of COSHH

☣️ When employers are known to be unable to ‘reasonably question’ IPC guidance, its authors should also be legally accountable.

☣️ The health & safety regulator has failed in its duty to regulate.

/9

#AFRSMIsNotPPE
☣️ 1,600 🇬🇧 HCW deaths isn’t enough to change HMG-linked IPC Cell’s approach, who are *still* more interested in saving their own skin & covering up past errors.

☣️ #Omicron immune escape with greater transmissibility: ready for round 4 of Red Zone Russian roulette?

/10
Summary:

🇬🇧 HCWs 😇

vs

☣️ IPC guidance writers @UKHSA
☣️ @H_S_E
☣️ @CMO_England (all 4 nation CMOs)
☣️ SAGE, NERVTAG,
☣️ @DHSCgovuk (they all know)
☣️ @WHO

‘Pile the bodies high’ 😷🙏🏻💙@YouAreLobbyLud

⚰️ A FRSM is not PPE 🪦

/end.
@mvankerkhove
blogs.bmj.com/bmj/2021/01/29…
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More from @DRTomlinsonEP

3 Dec
Paediatric critical care & ECMO: interim
update Nov 2017

'Paediatric critical care is a highly valued service that saves the lives of children in England every day.'

#OmicronVarient #RWCS?

1/4
'@NHSEngland analysis supports an initial hypothesis that – if the model of paediatric critical care does not change – the services will not be sustainable or affordable in the medium to long term.'

#OmicronVarient #RWCS?

2/4
'There is variation in the number of patients from each hub who receive ECMO' [extracorporeal membrane oxygenation]

👇 4 yrs' data (2011-15): per annum ECMO Rx

E Mids: 70
London: 66
NE: 31
NW: 14
SW: 6
Wessex: 9
W Mids: 17
Yorks & Humber: 6

#OmicronVarient #RWCS?

3/4
Read 5 tweets
22 Nov
🚨 NEW 🇬🇧

Guidance on IP&C for seasonal respiratory infections including SARS-CoV-2

Welcome to the world of SEASONAL SARS2 [does this sound more 'cuddly' to you?] & alternative reality according to the IPC Cell.

🧵

gov.uk/government/pub…
Hot on the heels of the new campaign where dCMO @Thomas_Waite states:

'People with COVID-19 release virus particles into the air whenever they speak, breathe or cough & these can linger in unventilated settings.'

Will the IPC Cell sustain the AGP myth?

gov.uk/government/new…
Reviewing this on the fly...

'This guidance is intended to prevent transmission of seasonal respiratory viral infections focussing on influenza, SARS-CoV-2, & respiratory syncytial virus (RSV) in health & care settings'

Nice tactic: Try to remove focus on SARS2 alone
Read 27 tweets
20 Nov
Problem: RTAs kill drivers

Mechanism: High velocity injuries

Physical laws-based fix: A seat belt

Null hypothesis: A seat belt is w/o effect on RTA death

Randomise drivers: Unblinded=flaw (may affect driver behaviour)

Start RCT

Pre-specified interim analysis shows benefit…
Problem: RTAs kill passengers

Mechanism: High velocity injuries

Physical laws-based fix: A passenger seat belt

Null hypothesis: A passenger seat belt is w/o effect on RTA death

Randomise passengers: Unblinded=flaw (may affect driver behaviour)

…seriously?
Universally applicable physical laws are the ‘highest order of evidence’.

Engineers can help ‘fix’ the problem, based on physical laws.

Different engineering ‘fixes’ will have trade-offs: cost, comfort, efficacy; materials (CO2 impact / recycling options) etc.
Read 4 tweets
18 Nov
@WHO director of communications suggests that we need 'a consensus on terminology'; i.e. meaning of the word 'airborne'.

Logical possibilities:

1. She's right: 'airborne' has so many meanings as to render its use invalid.

2. She's wrong: 'airborne' has a single, clear meaning.
🚨 Dictionary evidence

Does this indicate multiple, potentially conflicting meanings, or a single, clear meaning?
🚨 Evidence from WHO teams' use

2014: IPC of epidemic & pandemic-prone acute respiratory infections in health care

'The spread of an infectious agent caused by the dissemination of droplet nuclei that remain infectious when suspended in air over long distances and time. (9)'
Read 11 tweets
18 Nov
Coronavirus: how to stay safe and help prevent the spread - GOV.UK

This guidance needs to be reported for misinformation.

As ever during this pandemic, the 🇬🇧 medico-political complex display an aversion to reporting empirical truths. gov.uk/guidance/covid…
THE GOOD

✅ ‘Airborne transmission is a very significant way that the virus circulates.’

Correct: aerosols are formed & exhaled during breathing, speech, singing, coughing & sneezing.

Can you live without breathing? Image
THE BAD

☣️ Symptoms requiring PCR testing STILL reflect the BS affirmed by @CMO_England in May 2020 based on data marred by selection bias: ISARICA4.

These data should NEVER have been used to prop up erroneously narrow test criteria.
@ProfCalumSemple now agrees: BMJ, July 2021! Image
Read 7 tweets
18 Nov
Canada admits aerosols are major source of COVID-19 transmission after nearly two years of denying it wsws.org/en/articles/20…
‘The PHAC’s belated admission constitutes a devastating indictment of the political establishment’s prioritization of corporate profits over human life, which has gone hand-in-hand with a systematic repudiation of a science-based response to the virus.’ @trishgreenhalgh @Ozbilgin
Guidance change ‘on the quiet’: sound familiar?
@doctorsoumya @mvankerkhove @DrMikeRyan @DrTedros ImageImage
Read 5 tweets

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