REPLY TO HEALTH AND FAMILY WELFARE DEPARTMENT, GOVT OF NCT, DELHI

May 1st 2020 Dear madam,

This is in response to your notice dated May 1st 2020, vide letter no. 52/DGHS/PH-IV/COVID- 19/2020/prsecyhfw/6363-6412.

In response to the Notice served by Health and Family Welfare Department, New Delhi I wish to submit this letter as my response.

You will be quite surprised to know that the answer to your query also lies in some of the extracts in the “Guidelines for the use of Personal Protective Equipment” laid out by Health Ministry itself. I have also attached links for the evidence (some of them are from renowned medical journals like The New England Journal of Medicine, The Lancet, JAMA etc) in this letter for your kind perusal.

1. COVID 19 is an infectious disease with propensity of transmission from human (patient) to human (doctor/health care workers- assuming that you consider health care workers as human; although the non humanitarian nature of the notice issued by the ministry makes me wonder if my “assumption” is correct)

Abstract-
“There is clear evidence of human-to-human transmission of SARS-CoV-2.”

Source-
Guidelines on Rational Use of Personal Protective Equipment- MOHFW “https://www.mohfw.gov.in/pdf/GuidelinesonrationaluseofPersonalProtectiveEquipment.pdf”

2. It is also known that COVID 19 can spread through cough, sneeze or exhalation and I guess the health care worker has no control over these aspects of any of the patients he/she may encounter.

Abstract-

“It is thought to be transmitted mainly through respiratory droplets that get generated when people cough, sneeze, or exhale.”

Source-
Guidelines on Rational Use of Personal Protective Equipment- MOHFW “https://www.mohfw.gov.in/pdf/GuidelinesonrationaluseofPersonalProtectiveEquipment.pdf”

3. COVID19 is caused by a novel Coronavirus and not much is known about the minute details of the mode of transmission of the virus and research is ongoing currently to look into this aspect. I hope that you do understand that since much is not known in this aspect, the health care workers are working in an uncharted territory and hence have potential chances of getting infected.

Abstract-

Source-

 

“However, the mechanisms and risk factors for transmission are largely unconfirmed. Whilst

awaiting robust evidence, a precautionary approach should be considered to assure healthcare

worker safety.”

“Airborne transmission of severe acute respiratory syndrome coronavirus‐2 to healthcare workers: a narrative review N.M. Wilson A. Norton F.P. Young D.W. Collins

https://onlinelibrary.wiley.com/doi/abs/10.1111/anae.15093?af=R

    

4. Coronavirus may survive as aerosol for hours and may survive on surfaces for days making health care workers to be highly susceptible to get infected. (Unlike your offices, hospitals have a high viral load, and I guess I don’t need to provide an evidence for this fact.)

Abstract-

“Our results indicate that aerosol and fomite transmission of SARS-CoV-2 is plausible, since the

virus can remain viable and infectious in aerosols for hours and on surfaces up to days

(depending on the inoculum shed). These findings echo those with SARS-CoV-1, in which these

5

forms of transmission were associated with nosocomial spread and super-spreading events,

and

they provide information for pandemic mitigation efforts.”

Source-

Aerosol and Surface Stability of SARS-CoV-2 as Compared with SARS-CoV-1.

N Engl J Med 2020; 382:1564-1567 DOI: 10.1056/NEJMc2004973

Abstract-

“Coronavirus my spread through asymptomatic carrier state.”

Source-
Presumed Asymptomatic Carrier Transmission of COVID-19

Yan Bai, MD1; Lingsheng Yao, MD2; Tao Wei, MD3; et alFei Tian, MD4; Dong- Yan Jin, PhD5; Lijuan Chen, PhD1; Meiyun Wang, MD, PhD1

Author Affiliations Article Information JAMA. 2020;323(14):1406-1407. doi:10.1001/jama.2020.2565

Abstract-

April 16, 2020

 

5. Coronavirus may spread through asymptomatic individuals making health care workers all the

more susceptible to infection.

         

6. There have been numerous instances of health care workers getting infected in other countries

like China, Italy, USA, UK (probably proving that health care workers are not immune to this

disease; quite contrary to the “assumption” depicted in the essence of your notice).

“Figures from China’s National Health Commission show that more than 3300 health-care

workers have been infected as of early March and, according to local media, by the end of

February at least 22 had died. In Italy, 20% of responding health-care workers were infected, and

some have died.

Reports from medical staff describe physical and mental exhaustion, the torment of difficult

triage decisions, and the pain of losing patients and colleagues, all in addition to the infection

risk.”

Source-

COVID 19- Protecting health care workers. The Lancet: Editorial- Volume 395, Issue 10228,

P922, March 21, 2020.

7. N95 masks are able to filter out 95 % of the particles effectively which means that the 5 %

chance of failure may lead to infection. ( Also assume there is nothing “Ideal”- assuming you

have read physics during your school tenure)

Abstract-

“Respirator filters that collect at least 95% of the challenge aerosol are given a 95 rating.”

Source-

CDC (USA)

N95 Respirators and Surgical Masks Posted on October 14, 2009 by Lisa Brosseau, ScD, and Roland Berry Ann

N95 Respirators and Surgical Masks

8. The poor public health infrastructure in India has left the health sector as vulnerable and is one of the important factors for the spread of the infection among health care workers. The lack of Personal Protective Equipment at most places and delay in acquisition of PPE has already made Health Care workers exposed to the disease and many have died in the line of duty as well.

Abstract-

Source-
The New Indian Express 2019

“India’s public expenditure on health now stands at 1.28 per cent of the GDP but even then, it

is way lower than the average expenditure by countries clubbed as among the “poorest”. More

embarrassingly, the country’s public health expenditure is lower when compared with other

South-East Asian countries like Nepal, Sri Lanka, Bhutan, Indonesia, Thailand and the tiny

island country of Timor-Leste.”

9. Last, but not the least I assume that you would agree to the fact that no health care worker

would get exposed to the disease just to sit in the hotel for a few days knowing that this

infection may be deadly and may kill him/her.

Abstract-
This is an Assumption Source-

“I don’t have a source for this. You can figure this out if you have common sense although

not depicted in the essence of your notice”

9. Countries like UK have laws in place for the protection of employees at work place and

British Medical Association has even allowed that Health care workers can refuse to work if

adequate PPE is not provided at work place. Contrary to such examples, the government

failed to provide adequate PPE as well as failed to provide basics like work place safety for

the front line workers and enacted laws (Amendment Epidemic Act) and notices like this, to

provide false assurances to an already aggrieved work force.

Abstract-

Source-

https://www.bma.org.uk/advice-and-support/covid-19/your-health-and-wellbeing/covid-19-refusing-to- treat-where-ppe-is-inadequate

“The law also requires you and your employer to protect your safety and the safety of

others. Employers must provide a safe system of work, which includes provision of

appropriate PPE. If you have the employment status of ’employee’ you are also specifically

protected under employment law to take steps to avoid serious and imminent danger in

your workplace without fear of detriment or dismissal.”

  

I would also like to state that asking the question that you have asked through this notice is

akin to accusing a soldier of negligence and recklessness, when he laid down his life for the

service of nation and is a huge disrespect.

I hope that the above mentioned response in reply to notice of the ministry would be adequate

and may provide enough evidence to prove that Health Care Workers are susceptible to

COVID 19 infection.

In case of further enquiries/explaination, you may issue another letter. I have a few other

references which I can share with you for your next enquiry.

Thanking you
A Doctor of India

     

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