There are many critical errors in HICPAC’s proposed revised isolation precautions guidelines.
These core concepts of disease spread and mitigation are not being acknowledged or given due consideration:🧵
1. SARS-CoV-2 is airborne. It spreads by inhalation exposure to infectious aerosols at both close and long range. Not by droplets. Not by fomites. It can spread and linger in the air for hours, and can infect in an empty space previously occupied by an infectious person.
Approximately half of infections originate from pre-, pauci-, or asymptomatic sources.
2. The equating of surgical masks with N95 respirators for both source control and personal protection is false and goes against abundant, robust data on the superiority of respirators, one-way masking is less effective than universal PPE use,
and many patients are unable to effectively wear appropriate protection (eg babies, children, the disabled or unconscious, or those undergoing procedures where it is impossible).
3. Arbitrarily assigning tiers of precautions based on reported levels relies on constrained and therefore unreliable testing and reporting, and on lagging indicators such as hospitalizations.
While levels of infections, hospitalizations, disabilities and deaths may vary and are undercounted, even at the reported levels they remain consistently significant and warrant ongoing mitigations.
Loosening protections when levels are relatively lower is irrational, as time has repeatedly demonstrated that continued spread consistently drives the evolution of new variants and repeated surges.
4. Transmission of airborne pathogens can be effectively mitigated by readily available measures which prevent the sharing of unfiltered air: consistent, proper respiratory protection, and appropriate indoor air quality controls including ventilation, HEPA filtration, and UV.
5. Vaccines, for which access & uptake in the US are poor, are a necessary but inadequate layer of protection. They temporarily reduce the probability of acute-phase severity, hospitalization & death but are inefficient at preventing infection, transmission & Long Covid.
6. Herd/community immunity is literally unattainable because both vaccine- and infection-derived immunity do not endure over time or against newer variants.
7. Long Covid affects at least 1:5 to 1:7 Americans and it is not linked to acute-phase severity. It is typically disabling and can be fatal, and it affects all ages, including children.
Repeated infections do not confer immunity; rather they damage the immune system and increase the risk of developing long Covid. Resources for testing, treatment, and support are lacking. Yet #longCovid has been completely omitted from consideration in HICPAC proceedings.
8. No pre-exposure prophylaxis or monoclonal antibody treatments are currently authorized, having been outpaced by evolving variants. Three antivirals are currently authorized:
Paxlovid, the price of which has just nearly tripled, Remdesevir, administered by IV and costing thousands, and molnupiravir, currently under suspicion of causing new variants and fueling viral evolution
9. PCR tests are expensive & difficult to obtain. Lucira is expected to return to market at an inflated cost. Rapid antigen tests have a high false negative rate, the U.S. has not updated specimen collection guidance
to include cheek and throat swabbing to improve accuracy, & serial testing to offset low accuracy is expensive.
10. Healthcare workers (HCWs) who are denied appropriate protections are at risk of contracting Covid and of spreading it to coworkers, patients, and visitors as well as to their households. Thousands of HCWs have died of Covid and thousands more have been disabled by long Covid.
11. A recent study found half of healthcare workers with symptomatic Covid-19 present to work in patient care. Surgical masks, when worn, are inadequate for source control.
12. Both the infectious and those vulnerable to infection congregate in healthcare settings. Many lack the ability to effectively protect themselves from exposure, yet they share waiting rooms, hallways, elevators, restrooms, treatment areas
and, with the end of testing on admission, hospital rooms. Risk of infections and their sequelae are causing many people to forego needed care, and when encounters are unavoidable, they are forcibly exposed.
13.Those injured & killed downstream in the chain of Covid transmission are invisible to their infectors, & the you-do-you approach to infection prevention is a public health failure.But HCWs, who should know better, can refuse to protect patients if they just don’t feel like it.
Protections should be strengthened, and proper PPE & optimal IAQ should be mandated in all health and dental care settings. By weakening protections, HICPAC is saying that it’s acceptable for HCWs to infect patients and each other because transmission is lower and less impactful,
in complete disregard of these facts. HICPAC asks for respectful comments: this asks us to “respectfully” beg HICPAC to do their job and protect us, and to “respectfully” beg HCWs not to infect, maim, and kill us.
It is long past time to pause the proceedings, reconstitute HICPAC in compliance with its charter and with the law, factor in all of the evidence, and generate guidelines which DO NO HARM. These are my submitted comments to HICPAC. Fin.

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