Ask the CDC to improve infection control
Join me in supporting universal masking in healthcare and broad use of N95 respirators
Below the divider is my public comment submitted to the CDC’s Healthcare Infection Control Practices Advisory Committee in support of universal masking in healthcare as well as broad use of N95 or better respirators. The current draft guidance does not implement universal masking and includes unsafe recommendations that allow use of loose surgical masks for many airborne infectious diseases, which will almost certainly include COVID under inappropriate interpretations of endemicity.
The written comment period continues to be open until 11:59 pm Eastern time Monday (tomorrow), November 6. Please join me in submitting a comment. Your comment does not need to be lengthy or have scientific references. This committee needs to know about the barriers you have faced in seeking safe access to medical care.
From https://www.cdc.gov/hicpac/meeting.html:
Submission Period to Make a Written Public Comment Opened November 1, 2023, and will Close at 11:59 pm [Eastern time] on November 6, 2023. Please submit your Written Public Comment to HICPAC@CDC.GOV during this Submission Period. All Written Public Comments received before or after the Submission Period opens or closes will not be added to the meeting minutes.
While you’re at it, also send a note to your elected officials. A compilation of resources related to the CDC HICPAC meeting and related letter campaigns to support improving infection control in healthcare can be found on the Teams Human substack: https://teamshuman.substack.com/i/138572407/cdc-hicpac-its-not-done-submit-comments
Public Comment to CDC HICPAC Committee
Submitted via email on 11/5/2023
I am an MD-PhD physician-scientist and pathologist in Madison, Wisconsin. I’m a volunteer with the People’s CDC and Wisconsin Community Health Action. I have no financial conflicts of interest to disclose.
I am writing in support of universal masking in all healthcare settings, with broad use of N95 or better respirators, appropriate ventilatory controls, and other effective methods to reduce the risk of aerosol transmission. Universal masking must be incorporated into CDC guidelines broadly across healthcare settings to protect patients and healthcare workers from transmission from asymptomatic and unrecognized infections that are commonplace in healthcare settings. I gave previous comments supporting universal masking in healthcare at the previous CDC HICPAC meetings in June and August of 2023 [1,2], as did hundreds of others including public health and healthcare professionals as well as patients and members of the public. Yet, the draft proposal continues to dodge the simple, obvious, and scientifically-supported conclusion: both patients and workers want masking in healthcare. You are leaders in this field who can improve the standard of infection control, and you must do so to stop further preventable death and disability in the ongoing COVID pandemic.
In healthcare settings, airborne infectious disease transmission from either patients or healthcare workers who may have unrecognized or asymptomatic infections is unfortunately not a rare event. Healthcare-acquired infections are a preventable cause of death and disability, and following an appropriate patient-centered approach, there is no acceptable level of healthcare-acquired infections. The only reasonable goal is to reduce the rates of these infections as low as possible through effective measures. Aerosol transmitted infectious diseases are no exception. In a recent study of patients hospitalized with COVID in the US, 4% of those COVID cases were hospital onset (first positive test after day 7 of hospitalization) [3]. As we have learned from HIV and the development of bloodborne pathogen standards, we cannot rely only on case identification via symptoms, testing, or identification of particular risk groups. Such an approach perpetuates stigma and puts both patients and healthcare workers at risk. Universal masking is the straightforward solution.
With respect to transmission-based precautions, in the draft proposal, groupings of “Routine,” “Special” and “Extended Air Precautions” are made using a pseudoscientific explanation that airborne pathogens spread shorter or longer distances on the basis of pathogen factors. There is no demonstrated biophysical mechanism to support such claims–it is a de facto perpetuation of droplet dogma that will cause unnecessary death and disability, as loose-fitting surgical masks provide inadequate protection for the wearer against aerosol transmission. Only the Extended Air Precautions incorporate both N95 respirators as well as ventilation controls appropriate to aerosol transmission. An appropriate, science-based proposal would include N95 or better respirators, ventilation controls, and additional multilayered approaches for all airborne pathogens.
Many pathogens, including COVID, can cause a broad spectrum of disease with both short- and long-term consequences. The consequences of infection are unpredictable and depend importantly on medical conditions that may not be recognized prior to exposure. Medical conditions that cause an increased risk of severe COVID are common in the general population, with about 75% of the US population having high risk conditions for severe COVID infection [4].
It is well past time to incorporate universal masking as a new addition to standard precautions. Universal masking, with broad use of N95 or better respirators, is a precautionary approach that would be a significant improvement for infection control, simplifying the logistics of how and when to mask, and aligning our healthcare precautions with well-established science.
References
1. Sundling KE. June 2023 HICPAC public comment. https://precaution.substack.com/p/public-comment-to-cdc-infection-control
2. Sundling KE. August 2023 HICPAC public comment. https://precaution.substack.com/p/cdc-hicpac-infection-control-committee
3. Hatfield KM, Baggs J, Maillis A, et al. Assessment of Hospital-Onset SARS-CoV-2 Infection Rates and Testing Practices in the US, 2020-2022. JAMA Netw Open. 2023;6(8):e2329441. doi:10.1001/jamanetworkopen.2023.29441
4. Ajufo E, Rao S, Navar AM, Pandey A, Ayers CR, Khera A. U.S. population at increased risk of severe illness from COVID-19. Am J Prev Cardiol. 2021;6:100156. doi:10.1016/j.ajpc.2021.100156