P-06-1450 Welsh Government to take action to protect people from airborne infections in health care settings – Correspondence from the Petitioners to the Committee, 25 January 2025
https://petitions.senedd.wales/petitions/245982
Welsh Government to take action to protect people from airborne infections in health care settings
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25 Jan 2025
Dear Senedd Petitions Committee
The response from Covid-19 Bereaved Families for Justice Cymru to the Cabinet Secretary for Health & Social Care's letter to the Petition Committee dated 18 Dec 2024
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The Minister's assertion that "for most people, Covid-19 is like any other common respiratory illness" and that any intervention is futile is the fundamental issue.
He is rejecting the precautionary principle which must be applied to a novel virus. He is also clearly ignorant of the immune suppression caused by SARS-CoV-2, its affinity for vascular and other cell tissue and the risk of Long Covid.
He is unaware that immunity to infection induced by 'natural infection' wanes quite rapidly:
https://www.thelancet.com/journals/ebiom/article/PIIS2352-3964(22)00584-9/fulltext
As does that provided by vaccination: “Doses offer time-limited protection, protection increases after each dose but then wanes over the following few months"
For all these reasons, hospital-acquired infection should be avoided.
The comparison of current Covid admission statistics with those from earlier in the pandemic is unscientific and deeply flawed due to the changed criteria for testing. The testing of everyone on admission for surveillance purposes was universal in the early years, but since April 2023 testing has only been undertaken on admission when deemed clinically necessary. So, the signal is not consistent across that change of policy.
Given that up to 50% of infectious people are asymptomatic he should double the currently published admissions figures for a more realistic number. This greatly tempers the Welsh Government’s claim of decreasing levels of Covid admissions.
As Health Minister, he cannot be excused for not knowing the current level of nosocomial SARS-CoV-2 infection in NHS hospitals in Wales. The data used to be quite obscure, but it is now published in the PHW Weekly Influenza and ARI Report, which he must read regularly.
His response focuses solely on the risk to a healthcare worker (HCW) from an infectious patient, not the risk to the patient from an infectious HCW. His assumption that the cause of hospital-acquired Covid is patients with community acquired Covid is inaccurate. If that is the case, then the testing of patients on admittance and every 3 days then isolate would immediately address this. There must be recognition that infectious healthcare workers are transmitting Covid to patients. These patients who are already unwell & vulnerable, they have no way to protect themselves from Covid whilst in hospital.
The Minister has a duty to provide upfront protection of the already vulnerable in hospitals. Providing a test & treatment only when symptomatic is not adhering to the precautionary principle. The Minister & Welsh Government must act now to mitigate airborne viruses in hospitals.
We have provided further questions and recommendations to each point in the letter:
1. Airborne vs.
Droplet Transmission:
-There's an overemphasis on droplet transmission in the response.
He states "Person-to-person transmission of Covid-19 primarily
occurs through direct transmission (involving droplets which land
on mucous membranes) or by airborne transmission" and focuses
heavily on surgical masks for droplet protection.
- 'direct transmission' - is not a term not used to describe any form of transmission and has no scientific meaning
- See Professor Clive Beggs definitive and expert report to the UK Covid Inquiry on the physical sciences underpinning Covid-19 transmission and its implications for infection prevention and control in healthcare settings'
- Improvement
needed: He must acknowledge that COVID-19 is predominantly
airborne and adjust the protective measures accordingly:
- Prioritize proper ventilation and air filtration
- Emphasise the use of well-fitting respirators
(FFP3
or to an equivalent standard approved by the HSE)
as
Cambridge did)
-
Implement air quality monitoring more systematically eg
Addenbrookes
2. Long-term
Health Impacts:
- There's no acknowledgment of Long COVID or chronic health impacts
of Covid from even a mild initial infection and especially repeated
infection.
- Improvement
needed:
- Include risk assessment for long-term health impacts
- Develop protocols specifically aimed at preventing chronic
complications
- Consider long COVID impact on healthcare workforce
planning
3. Ventilation Monitoring:
- Current approach seems fragmented:
- No centralized reporting of ventilation status
- CO2 monitoring not included in testing requirements
- Ad-hoc testing based on individual Ventilation Safety
Group decisions
- Improvement needed:
- Implement mandatory CO2 monitoring and
data-logging
- Create centralized reporting system for ventilation
status
- Set minimum ventilation standards that must be
met
4. Testing
Strategy:
- His position on reduced testing seems based primarily on
population immunity. There is no immunity from Corona Viruses ever
and a 'current' reduction in acute reactions but no change in long
term chronic problems from a neurovascular chronic
infection.
- Improvement needed:
- Reintroduce and mandate regular testing of HCWs and patients
- Stop HCWs working when infectious with Covid -both asymptomatic & pre-symptomatic
- Encourage HCW uptake of Covid vaccination as currently low in Wales
- Include asymptomatic Covid stats in nosocomial reporting
-
Implement strategic surveillance testing
- Account for chronic virus persistence and to be
proactive on new circulating variants
-Recommence the Wastewater in Wales -sampling weekly alerts. The award-winning programme was one of the best in the world, led by one of the currently most published scientists in Wales. It gave an indication of regional infection prevalence and variant dynamics across Wales, important both to inform NHS and Public Health policy in Wales, especially giving advanced warning of likely hospital admissions and feeding into global surveillance, as requested by WHO.
5. Air
Purification:
- The response indicates no standardized approach: eg
CADR
- No recognised industry standard for testing
- No systematic monitoring of infection rates in relation to
air purifier use
- Improvement needed:
- Develop standardised testing protocols
- Conduct systematic studies on effectiveness
- Create clear guidelines for when, where and how much air
purification is required for each level of risk.
6. Staff
Protection:
- Focus seems to be on managing sickness absence rather than
prevention. This is already a huge problem, from viral
persistence and immune T-Cell exhaustion (aka Leonardi
effect)
- Improvement needed:
- Implement proactive protection measures inc regular
testing
- Provide high-quality respiratory protection
i.e HSE
requirements = FFP3 or equivalent, such as elastomeric reusable or
Powered Air Purifying Respirators)
-
Mandatory regular IPC training & not a reliance on
manuals - they don't protect anyone.
- Regular risk assessments considering airborne
transmission.
7. Nosocomial Covid Protection
- Over the past year 60% or more of NHS inpatients in Wales with Covid acquired it in hospital. These are just inpatients who have been tested because their symptoms are of clinical concern to the Consultant. There will be many more untested.
For example, 05 January 2025, there were 176 inpatients in Welsh NHS hospitals with confirmed Covid infection, 111 of which (63%) had acquired it nosocomially.
- The current IPC measures in place cannot therefore be described as effective when there are so many nosocomial cases of Covid, flu etc in hospitals in Wales
- Improvement needed:
- implement all the above plus:
- Introduce Welsh Government targets to reduce nosocomial infection
Regards
Anna-Louise Marsh-Rees
Group Lead
Covid-19 Bereaved Families for Justice Cymru