Don’t Let the CDC Silence Public Comments: Urge the CDC to Protect Frontline Health Care Workers and Patients Now!

Ahead of the public HICPAC meeting held August 22, 2024, many members of the public submitted written comments. But the CDC did not include those written comments in the meeting record, essentially silencing public comments. This is unacceptable!

UPDATE: On November 7th, the CDC amended its meeting notice to call for written public comments ahead of the upcoming November HICPAC meeting—a victory resulting from our collective action!  

Submit your comment by email to hicpac@cdc.gov by November 22, 2024. 

Forward your comments to healthandsafety@nationalnursesunited.org or copy and paste them in the form below and we will help create a public record. Your perspective is vital! 

Instructions: 

Use our suggested talking points to craft your written comments ahead of the next HICPAC meeting on November 14-15, 2024. Written comments should not exceed one single-spaced typed page in length, not including attachments and must contain the submitter’s name, address, organizational affiliation, and topic being addressed. The most powerful comments draw on your personal experience and expertise. Submit your comment by email to hicpac@cdc.gov by November 15, 2024.  

Talking Points:

Please address at least one of the following points in your comment. You do not need to address each one. Select a point that you feel comfortable speaking about and add any personal experience or expertise that will help CDC/HICPAC understand how their proposals would harm health care workers and patients. 

1. Public input is important. The CDC’s infection control guidance is widely used by health care facilities across the country and other governments around the world. My safety and the safety of all patients and community members is impacted by your work. Receiving input from the public is important to ensure that diverse perspectives are heard as you develop updated guidance.  
2. HICPAC has failed to engage the public effectively. I commend you for the steps you have already taken to improve transparency in your work and to add additional perspectives to both the committee and the Isolation Precautions Guideline Workgroup. However, HICPAC’s process to develop updates to the 2007 Isolation Precautions guidance has continued to fail to effectively invite public input. Most recently, HICPAC failed to solicit written comments in the meeting notice for both August and November 2024, despite it being required by federal regulations (41 CFR Section 102-3.150). Other CDC advisory committees receive written public comment through a public docket on regulations.gov—it is unclear why HICPAC is allowed to operate with less transparency and public accountability than other committees. I commend the CDC for amending the notice for the November 14-15, 2024 HICPAC meeting to include both written and oral public comments and urge HICPAC and CDC to ensure that public comments are received and made available, including both oral and written comments, for all advisory committee meetings through a public docket on regulations.gov.  
3. Updated guidance must follow the precautionary principle. I urge you to ensure that updated guidance on health care infection control ensures that recommendations for infectious disease protections for health care workers and patients are based on the precautionary principle. A precautionary approach would include assessments that evaluate the level of exposure, select appropriate control measures (including PPE) for each job, task, and location, and result in a written exposure control plan following the hierarchy of controls. Control measures like ventilation and respiratory protection must be prioritized.   
4. Updated guidance must create clear obligations for employer protections, not “flexibility.” The guidance must not include the more “flexible” approach that the CDC adopted during the Covid-19 pandemic, which enabled health care employers to avoid providing necessary protection for health care workers and patients, based on cost considerations. Employers failed to protect health care workers during the Covid-19 pandemic and we must not repeat the same mistakes.   
5. Updated guidance must recognize the science on inhalation transmission. Updated guidance must also fully recognize the science on aerosol/inhalation transmission of infectious diseases. Distance is not an acceptable surrogate for a robust exposure and risk assessment.   
6. Updated guidance must recognize the science on respiratory protection. Surgical/medical masks do not provide respiratory protection against inhalation of infectious aerosols and cannot be used to protect health care workers from hazards in the air.   
7. Updated guidance must incorporate the range of control measures for inhalation transmission, including ventilation and respiratory protection. CDC/HICPAC inexplicably fails to acknowledge the importance and function of core control measures for infectious aerosols. The large body of evidence on the effectiveness of respirators and the importance of ventilation and air filtration for controlling worker exposure to infectious aerosols have not been adequately addressed in HICPAC’s proposals.  
8. CDC must redo its flawed evidence review comparing N95 respirators vs surgical masks. CDC’s flawed evidence review on N95 respirators and surgical mask effectiveness must be redone with input from scientific researchers and experts in respiratory protection, aerosol science, and occupational health. The evidence review prioritized the findings of randomized controlled trials and cherry-picked data to conclude there was no difference between N95 respirators and surgical masks, omitting other applicable data and studies. The evidence review failed to look at extensive evidence on respirator effectiveness from laboratory studies and studies in non-health care workplaces. 
9. Protect health care workers and patients! I urge you to ensure that the health and safety of health care workers is prioritized in the updated guidance. As we learned in the Covid-19 pandemic, the health and safety of our communities are all inextricably linked. We must be better prepared to protect each other in the case of another public health emergency.