Organization
[May 09, 2024 3:37 PM]
Ontario Medical Association (OMA)
 
Response in PDF format:
OMA Response_20240509.pdf
Member of the public
[May 06, 2024 11:00 PM]
Safe access to healthcare is an equity and accessibility issue. Please acknowledge that viruses such as COVID are airborne and update your IPAC policies to account for ways to mitigate spread in healthcare settings. Universal use of N95 respirators for everyone: doctors, healthcare workers, patients, and visitors alike. Masks must be used in healthcare settings permanently to help prevent the spread of HAIs. Focus on cleaning the air with HEPA filtration and improve ventilation. Safer healthcare spaces will help everyone; the most medically vulnerable as well as healthcare staff.
Member of the public
[May 06, 2024 10:59 PM]
Masking, proper air ventilation/HEPA filters, and monitored air quality are necessary in any healthcare setting; no one should have to face - or weigh the odds of - potentially acquiring a new illness, whether visiting their family physician, a walk-in clinic, a specialist, having surgery, visiting the ER, or caring for a hospitalized loved one. Pre-Covid-19, surrounded by obviously-ill patients waiting at the multi-doctor clinic where I was a patient, I many times thought it would be a miracle if I didn't go home with something contagious. The last 4 years has highlighted that this is a critical aspect of patient care, while also protecting everyone working in those facilities. Lay-people who have followed the science have homes that are safer than medical facilities. During the 2-metre, masks required period, I encountered physicians who did not mask, or were unaware it should cover mouth and nose. One without a mask needlessly entered a small exam room within 30 cm of me and when spoken to, did not bother to apologize. A more recent visit to a heart care centre saw no masks on anyone, neither staff nor patients - many of whom were brought by family members, also mask-less. This is shocking, two years after published studies about the impact on the heart. There are so many studies on the hazards of Covid-19, along with the usual hazards of the flu, RSV, pneumonia, etc. This should not be left to individual physicials or facilities, nor the government. It should be required by the CPSO, it is literally patient care. Interesting additional insight on the 2m... https://www.wired.com/story/the-teeny-tiny-scientific-screwup-that-helped-covid-kill/
Member of the public
[May 06, 2024 10:57 PM]
I find that the infection prevention and control measures by doctors in Ontario is totally inadequate with respect to respiratory illnesses, which are heavily airborne. We need universal audits of ventilation and filtration in all doctors' offices and other medical facilities. I know that the ventilation in my doctor's office in Toronto is awful -- I've tested it. Doctors and patients are spreading and catching illnesses unnecessarily. My doctor is interested in such issues, but has never received an information or assistance to deal with such matters.

We need CO2 meters and the like so all patients and the public can see that ventilation is adequate.

We also need universal masking with N95 or similar in medical facilities, especially when ventilation is not perfect. Medical procedure masks are not adequate.
Member of the public
[May 06, 2024 10:57 PM]
Health care settings should require universal worker masking with respirators, not medical masks, for patient and physician safety. Leaving it to patients to ask providers to mask leaves them open to reprisal and refusal due to the power imbalance. Nosocomial infections are particularly dangerous and COVID circulates all year, not just during "respiratory season" - never mind other airborne viruses. Air quality and ventilation should be emphasized in health care settings, including the use of HEPA filters. Virtual appointments should remain available for simple and routine needs, reducing risk and exposure for health care workers and patients.
Member of the public
[May 06, 2024 10:56 PM]
Good day,

While the highlighted areas are certainly important, there are several critical concepts & pieces of guidance missing from the draft, as outlined below:

The ongoing COVID-19 pandemic has demonstrated that symptom-based screening and point-of-care risk assessment are insufficient for breaking chains of transmission. Resulting in catastrophic amounts of death and disability that could be readily prevented by embracing new evidence.

We now know that respiratory pathogens like SARS-CoV-2 are transmitted easily through shared air, and that asymptomatic and presymptomatic transmission are major drivers of disease transmission. Given this new understanding, the medical establishment has a duty to respond appropriately, using the precautionary principle.

Every clinic/physician's office should have: 1) Upgraded ventilation and filtration (appropriate HEPA filtration and adequate air exchanges per hour for a given square footage/office layout). 2) Universal masking policy, with well-fitted, high quality resiprator-equivalent masks (and a policy for exemptions). 3) Paid sick days and a strong stay-home-when-sick for all providers and staff and 4) Education for all providers and staff, especially those in charge of IPAC, to reflect the most up-to-date understanding of disease transmission (i.e., paradigm shift away from discreet contact/droplet/airborne categorization).

Failure to respond appropriately to new evidence puts patients, staff and providers at risk. Such behaviour directly contradicts the Hippocratic Oath.
Physician (including retired)
[May 06, 2024 10:48 PM]
As a physician, I am quite shocked to see we have learned nothing from the pandemic (which has NOT been declared over) and the fact the ongoing airborne infections are only going to increase. In addition, the lack of organizations recognizing the need to protect our vulnerable populations and implement public health to protect all (vs this individualized rhetoric overtaking health care).

Recommendations:

1. Acknowledge necessity of ongoing airborne precautions for COVID-19 (and other airborne illnesses).
2. Recommend CO2 monitors for clinical room settings to monitor airborne transmission risk and set a standard of 800 or less. CO2 is a proxy for infectious aerosol concentration. A higher CO2 level also implies that viral particles will survive longer in the air based on a recent study (presented at recent CPHA Public Health 2024 conference this past April in Halifax).
3. Set ventilation (air changes per hour, eg ACH 6) standards and where not possible or to complement ventilation, set standards for air filtration using a portable HEPA filter with sufficient air exchange/inexpensive corsi-rosenthal MERV filter box.
4. Set mask standard to N95 respirators. Educate on proper fit (including keeping over the nose) for staff and patients. Explain that even non fit tested N95 fit and reduce circulating airborne particles better than surgical masks.
5. As per Human Rights under accommodations, patients or visitors can request all health care professionals to wear N95 masks when in the same room. This is crucial for elderly and the other “invisible” vulnerable patients (newborns, pregnant, immune compromised). They have a right to protect their health from infectious disease transmission, just as clinicians have a right to be protected from patient transmission. These requests should be respected and patients should not be fearful to request masking or be bullied/judged for their requests to protect their health and avoid deteriorating ongoing health conditions by simply seeking health care.
6. During times of higher prevalence, explicitly require masking of all visitors and staff which means including in hallways, reception and waiting areas in addition to other clinic areas such as exam rooms.
7. Remove and update outdated COVID-19 posters/pamphlets that emphasize hand-washing over airborne precautions such as masks and ventilation. Update them to reflect the science and revised WHO/CDC/PHAC guidance.

The above is applicable to various other infectious diseases for which we will unfortunately continue to see in our communities (this includes measles given the dropping vaccine rates and likely further novel viruses given the impact of climate change on planetary health). The above reflect the medical peer-reviewed literature re: COVID-19 over the past four years.
Other health care professional (including retired)
[May 06, 2024 10:48 PM]
As a health care worker in Long Term Care, I have seen first hand the impact of masking.
When universal masking was implemented, case numbers were low. When masking was dropped is always when outbreaks occur. I watch our aged and vulnerable residents susceptible to infections they can’t fight off. I watch them get quarantined to their rooms for upwards of 10 days, completely isolated because staff couldn’t be bothered to wear a mask. Staff and visitors are given the freedom to choose, to spread illness, which strips the residents of any freedom at all. I watch their mental health crumble when they’re in their rooms, sometimes over their birthdays, Christmas or New Years totally isolated because they have no autonomy over their safety. It isn’t right. I have worn a mask at work every day since COVID began because it is the right and smart thing to do. I watch other nurses come to work with a mask on, and take them off shortly after when there’s no one else in their area wearing them. No one has the confidence to do the right thing if it means being different. The patients deserve better. This isn’t right. Masks should still be mandatory in Long Term Care and all other health care settings - but especially Long Term Care. It isn’t about us. We work there, but for the residents - this is their home. It’s our job to keep their home and them safe.
Member of the public
[May 06, 2024 10:48 PM]
More than four years into a pandemic caused by an airborne virus, and the comments here from members of the public make it clear that they have learned more about aerosol science, transmission of airborne pathogens, and the best ways to stop infection than the so-called infection control professionals. I wish this were just embarrassing for you, but it’s so much more than that because people have died or had their lives changed forever because of your inability to listen to experts outside of your narrow dogma-driven field and learn something new. Put your egos aside as you read these comments and realize that you have lost the trust of the public. No one believes that you will keep us safe in health care settings. Your discipline needs a radical reboot and this policy amendment ain’t it. Covid is airborne and it is a serious infection that should be avoided. Hand hygiene does little or nothing to stop its spread. Start acting like you know that and that you actually want health care workers and patients to remain uninfected.
Other health care professional (including retired)
[May 06, 2024 10:45 PM]
Airborne transmission of pathogens (like Covid) is significant. Or should I call it puff cloud transmission now I can't keep up. Why does IPAC show no interest in preventing these type of infections? Is it incompetence? Negligence? I can't tell the difference.
Respirators need to be mandatory in healthcare settings, especially hospitals and physician offices. That would be n95 masks or better, not the baggy blue surgical ones. Did you know that surgical masks don't provide adequate protection against the puffy cloud viruses?
Address indoor air quality with the use of widespread air purifiers and proper ventilation (low C02 readings). Did you know that these purifiers can filter viruses out of the air? Good ventilation means we are re-breathing other people's exhaled air less often. Infected people can exhale large amounts of viruses in case that wasn't clear. Clean the air, please.
By not having proper mitigations for airborne transmission, you are abandoning your patients, especially the most vulnerable. People shouldn't be at such a high risk of getting infected with a brand new airborne pathogen when they go to a hospital.
Show that you care about them, please.
Member of the public
[May 06, 2024 10:42 PM]
Given what we have learned in the last four years in particular, there is an alarming lack of ventilation or masking practices included in this advice. Clinicians are in need of guidance and support that is non-political and focused on centering patient care when it comes to masking. Patients should never be in a position where they have to ask a healthcare provider to consider infection control with Covid-19 and other airborne viruses still widely circulating in our communities. Clinicians are also in great need of both education and support in addressing air quality issues; indeed the highest co2 number I have seen was in my doctor's office.
Member of the public
[May 06, 2024 10:41 PM]
Clinicians and clinic staff should be required to wear fit-tested NIOSH N95 or CAN/CSA Z94.4-18 respirators (or equivalent, or better). Source control is an important factor in mitigating the transmission of infectious diseases. We know about asymptomatic and pre-symptomatic transmission, so staff should not limit respirator use to when they are symptomatic (which may also be dismissed as "allergies").

There was a recent study suggesting that 75% of people will hide their symptoms to avoid missing work and social events. This further underscores the need for source control. If one does not want to wear a respirator, I suggest they find a different line of work as I believe it is an obligation to protect patients.

Bear in mind the power imbalance between the patient and the clinician as well as the clinic staff. The patient requires care and is vulnerable. It is inappropriate and insufficient to leave it to the patient to request staff or the clinician to wear a respirator, because they will rightfully be concerned that it may affect their care or even their ability to receive care. We are human and subject to biases and reactance, which may result in clinic staff acting as gatekeepers and barriers to access to care, and clinicians who may simply refuse to wear a respirator unless mandated to do so. This is not just theoretical as many people have experienced these situations in medical settings.

"Mirroring" the behaviour of the patient (i.e. donning a respirator if they observe a patient coming in wearing a respirator) is insufficient due to the source control issue previously described. More infectious aerosols will already be present in the air prior to the patient's arrival if respirators were not already being worn, increasing the transmission risk.

Further to this, ASHRAE Standard 241 Control of Infectious Aerosols should be applied to clinical settings. Medical offices frequently have inadequate ventilation and no MERV-13 or HEPA H11 (or higher) filtration for air purification. Indoor air quality is important not just for infection control, but also for limiting harmful substances such as ozone, mould spores, radon, fine particulate matter, dust, pollens, and other allergens, as well as improving cognitive performance (decision-making by clinicians) by maintaining low CO2 concentrations.
Member of the public
[May 06, 2024 10:33 PM]
Thank you for this opportunity for the public to voice their opinion on this important issue.

Hospitals are an absolutely critical part of our communities, and sadly, they are no longer safe spaces to be in. There are reports after reports of people catching COVID from a hospital visit, of people putting off much needed surgeries in fear of their already immune compromised body catching COVID, and of people avoiding a necessary emergency room visit in fear of catching something worse than they may already have. This is not only unacceptable, it is easily preventable.

While much of the world moves on in blissful denial of the ongoing pandemic which is still killing and disabling people every day, there are many of us who are following the science. That is, we are part of the population still maintaining a lifestyle that is COVID aware as we choose to avoid a virus which has the capability of disabling our otherwise healthy bodies.

Further to that, there are people who don’t have a choice but to be safe because their immune system could not tolerate a COVID infection. All of us deserve to feel safe in a place that is literally designed to keep us safe and healthy.

In addition to the patients that require these hospital services, there are staff who work there who deserve protection. Their families deserve protection. This is not only not provided, it is completely neglected.

Sadly, COVID 19 has become a grossly political issue which has cost lives, endangered lives, and created completely toxic work environments. The onus of protection should never have been placed on individuals but should be a requirement across the board like many other parts of a work environment (ie. uniforms).

The Precautionary Principle, an absolute staple in health care has been completely abandoned. It’s time to bring it back. With that, I am proposing 2 basic but necessary additions to a draft regarding Infection Control.

1) Masks. 100% masking needs to be part of health care. Not seasonal masking (because people’s damaged immune systems & cancer diagnoses don’t take holidays) and not “masking upon request” (because the majority of people will not have the courage or assertiveness to ask their health care worker to mask) but just masking. Plain and simple. A mask as part of the uniform just like scrubs, and a mask to enter the hospital because you’re either sick, visiting someone who is sick, or entering a building where there are sick and vulnerable people. No, not everyone will like it but that isn’t a reason to not do it (ie. teenagers don’t like curfews but they’re still necessary). A mask is the absolute basics of infection control.

An additional note on masking - the type of masking matters. Of course, N95s worn properly is the most effective but even 2 way surgical masking is better than no masking at all. Masks belong in health care.

2) Air quality control. COVID (just like influenza and the potentially upcoming H5N1) is airborne. Air quality needs to be included as an important part of infection control.

That looks like 1) At least 5 air exchanges per hour for each area of the hospital (including waiting rooms where sick people congregate), 2) High quality Hepa Filters and 3) air quality monitoring with visible CO2 readings for full transparency and empowering patients to be educated about the air they breath.

To be frank, these are the very basic of infection control. Implementing these basic policies will not only help patients in the long run, but they will preserve the health of hospital employees and improve the quality of life for the communities at large.

Covid 19 has taught us to be grateful for every moment and the importance of working together as a community. It’s time for health care to catch up.

Thank you for the opportunity to share my thoughts and for taking the time to read this. I hope something comes from it.
Member of the public
[May 06, 2024 10:32 PM]
As both a patient myself and an affiliated professional who works with patients who have cause to regularly interact with physicians in Ontario, I am deeply disturbed by the growing chasm between the practice of medicine and the science that would appropriately inform infectious disease transmission mitigation. There is no scientific question as to whether SARS-CoV-2 continues to circulate in our communities and within the walls of healthcare institutions. There is no (real) scientific question as to how it is transmitted; it is airborne, meaning that it is transmitted “through the air” according to the newest WHO terminology, and also that aerosolized virus can remain in the air like smoke, infecting others who are exposed up to hours later. There is no scientific question that measures like HEPA filtration, adequate ventilation and respirator style masks can all greatly reduce the risk of transmitting not only SARS2, but also other infectious pathogens that have re-emerged, and now pose a greater threat to the health of Ontarians. What is the medical community waiting for? It certainly isn’t the science. The science overwhelmingly favours adopting these mitigations, particularly by professionals who work daily with vulnerable patients. The current disconnect has gone on too long. Please revise this draft to include evidence-based recommendations and requirements that implement the tools we have available to us. This is essential to not only providing safe care during the current pandemic but also to protect against multiple other hazards that are transmitted through the air.
Other health care professional (including retired)
[May 06, 2024 9:56 PM]
I am very lucky to have a family doctor who understands that covid is an airborne virus and takes steps in their clinic- namely by masking with a respirator and employing multiple HEPA units- to prevent the spread of illness.

But it shouldn’t be luck that allows a patient to safely access medical care in Ontario. Everyone in Ontario should be able to go see their physician without worrying that they will leave sicker than when they arrived.

To that end, CPSO has a moral duty to support their members, and members of the public, in both providing and receiving care safely.

This can be done through education for MDs around the airborne nature of covid-19, asymptomatic transmission, and what constitutes high-quality PPE. Members should be informed that they must mask when a patient requests it, and, even better, mask as best practice when they see that a patient is masking at their appointment.
Member of the public
[May 06, 2024 9:54 PM]
It is becoming increasingly difficult to access healthcare in a safe manner. COVID-19 brought to light the importance of cleaning the air and universal masking. Despite these lessons, many hospitals have dropped their masking requirements which makes vulnerable patients more at risk of complications and even death, and also puts the public at risk of becoming vulnerable. Please bring back universal masking in healthcare settings and invest in cleaning the air with improved ventilation.
Medical student
[May 06, 2024 9:45 PM]
Mandatory masking in healthcare settings is a key infection prevention measure that needs to stay and be implemented. Respiratory illnesses such as covid are often transmitted asymptomatically and through the air. Given the close proximity of healthcare providers and patients, two-way masking is important to protect vulnerable patient populations, providers and their family members. This is especially pertinent given nationwide hcp shortages. It makes no sense to avoid implementation of such a simple, effective measure for infection control. Masking was not previously mainstay in surgical suites. Handwashing was not mainstay at one point between patients. These were important points of progress in infection control. As our understanding of respiratory illnesses evolve, so too must our practices. We know now that airborne transmission is central to such pathogen spread. Thus masking, and importantly proper masking (ex n95) should be recommended.
Other health care professional (including retired)
[May 06, 2024 9:38 PM]
As a health care worker, working with immunocompromised patients, I would like to see direction on proper ventilation and masking recommendations in all health care settings. The covid-19 pandemic has demonstrated the role of airborne transmission and we have a moral obligation to prevent this transmission as much as we can. Our patients and health care system depend on proper prevention strategies.
Member of the public
[May 06, 2024 9:23 PM]
At the very least, have air filtration in the waiting rooms and clinic rooms. If your patient is masking please mask as well. They could be vulnerable or have a family member who they are protecting.
Member of the public
[May 06, 2024 9:20 PM]
We need staff (medical and support) wearing respirator masks to stop airborne transmission of diseases like COVID, flu and RSV.
We need staff EDUCATED on the reality of airborne transmission so they stop minimizing the concerns of patients who are better informed.
We need better air filtration and ventilation to help clean and scrub the air, and staff educated on actually using this equipment properly.
Member of the public
[May 06, 2024 9:18 PM]
As a person disabled by long covid, there are a few things missing from this policy document. All staff should be required to wear n95 masks, not surgical masks. This will prevent transmission of COVID and other airborne diseases. Ventilation is also another key thing missing from the policy. Ventilation standards should be required to be aligned with what the WHO has recommended.
Member of the public
[May 06, 2024 9:04 PM]
I’m very disappointed there’s no mention of ventilation or at least air filtration. As well, I’d like to see doctors required to wear masks when seeing patients (ideally N95 but surgical is better than nothing). I’d really like to see universal masking in all healthcare settings for both visitors and staff, but that’s probably unrealistic in the current climate.
Member of the public
[May 06, 2024 9:01 PM]
Please require masking and clean air to protect everyone.
Physician (including retired)
[May 06, 2024 9:00 PM]
Having read the new draft and advice documents, including the PIDAC document on IPC for clinical practice, and the following suggestions :

1. That the PIDAC document above be updated and used as the reference document. The draft document and accompanying advisory document from CPSO would also be better served when used in conjunction with the PIDAC document.
2. More emphasis to be made on hierarchy of controls, including administrative (e.g vaccination of staff for other conditions, not just Covid vaccinations), and engineering controls such as ventilation and to recommend Hepa filters as required
3. Emphasis on use of audits, with responsibility on supervisors and owners.
4. Environmental cleaning to be highlighted, and with use of products with shorter contact times for disinfection. Cleaning of blood pressure cuffs between patients and at the end of the day is advocated. This is sometimes forgotten by clinic staff
5. n95 fit testing to be done for staff, so as to prepare for use when required, including in respiratory outbreaks.
Physician (including retired)
[May 06, 2024 8:59 PM]
As currently written, these documents are a huge lost opportunity to meaningfully improve office safety for healthcare workers and for patients. The advice relating to office safety to prevent the transmission of airborne viruses is totally inadequate. I find it very hard to understand the reluctance of the medical profession to improve patient care by applying all that has been learned over the last 4 years about airborne transmission of Covid and other respiratory viruses. The facts of airborne transmission are hard to deal with, and the temptation to revert to 'pre-2020' state of knowledge is there, but it is our responsibility (and in our own interest) to adapt our practice to new knowledge. There should be an entire section in both documents on the engineering/system changes required to improve air quality in every medical setting. This would include advice on improving ventilation systems, the use of C02 monitoring for easy assessment, how to calculate ventilation and HEPA units needs for your office. It should become routine practice for patients to see HEPA units in examination rooms. The WHO has recently (albeit belatedly) acknowledged airborne transmission of Covid and other respiratory viruses. Canadian IPAC is stuck in pre2020 approaches and the CPSO must move beyond this. Physicians are not engineers, and many will find this subject daunting. Fortunately, resources are now now available - such as the recently published recommendations and advice from OSPE, the Ontario Society of Professional Engineers, under the leadership of Joey Fox. Collaboration between CPSO and OSPE would be a very positive step towards patient safety. A task force with medical, engineering and patient representatives to demystify and promote air quality in medical settings should be set up.
The debate around masks is a huge subject with many layers. Undoubtedly, at the moment, N95 masking is the most reliable way to protect the wearer or a patient from airborne infection. At a minimum, this should be acknowledged in a document such as this.
There is an argument for universal masking in healthcare settings to be routine practice, just as washing one's hands is. At the minimum, this should be the case in all settings caring for the immunosuppressed, elderly and other vulnerable. Another minimum requirements should be 'see a mask, wear a mask' - in other words, if a patient arrives with a mask on, it should be automatic courtesy and good medical medical practice for clinic staff (nurses and doctors) to don a mask too. In 2024, when we know that such an action protects our patients, it is unethical not to do so. The hope is that with time, widespread ventilation and air purification improvements along with new vaccines and therapeutics will be enough to largely control Covid, and it may then be possible to reduce medical mask use but we are not in that position yet. The increasing incidence of autoimmune diseases, diabetes, myocardial infarction, strokes and other neurological complications occurring post Covid is a reality that most of us cannot face thinking about currently, but it is our job to do so. And to do everything we can to protect our patients, our families and our own health.
Tackling airborne viruses is daunting. It means systemic changes, at an engineering level.
Just as the discovery of the waterborne spread of cholera and typhoid in the 19th century required clean water engineering, we need clean air engineering. This needs to be acknowledged and the words 'ventilation, CO2 monitoring, air purification, HEPA filtration' used in both these documents to start educating physicians and making a real difference. thank you.
[Name redacted] Retired MD.
Member of the public
[May 06, 2024 7:44 PM]
I am quite frankly appalled that four years after the start of the worst pandemic of the century, you have zero guidance and requirements on proper air filtration and ventilation. The lesson of the COVID pandemic has been that transmission of some respiratory viruses is airborne. You need to state, in clear language, minimum standards for air filtration/ventilation that all medical offices must have. This is as important for infection control as cleaning equipment and washing hands.

I also find your policy on masks and PPE to be insufficient. I would prefer that high-quality N95 masks be routinely required for all medical staff and patients in medical facilities, but at a bare minimum, doctors should respond to patient concerns by masking to the same degree of safety as the patient does, i.e., if the patient is vulnerable and wears a high-quality mask, medical staff should as well. Given that COVID infections can be transmissible before symptoms are apparent, it's not enough to mask only when someone in the room has symptoms.

As a patient with a disability for whom getting infected with COVID could have very serious implications on my health and functioning, policies like this make me feel unsafe while getting the medical care that I need. This is an issue of accessibility: vulnerable patients should have a right to get medical care in a setting that is safe. That means taking reasonable precautions to ensure proper air filtration/ventilation, and using high-quality masks, at the very least, around patients who are vulnerable or who express concern about safety (for example, if they live with someone who is immunocompromised).

COVID isn't just a cold. It isn't minor. It can cause serious disability even after a mild acute infection, and even in vaccinated patients. It also dramatically increases the risk of cardiovascular issues like clots / strokes / heart attacks for at least a year after infection, again, even in mild cases in people who appear to recover.

It's completely irresponsible for medical facilities to be vectors of transmission of an extremely contagious virus with such serious consequences. It's quite simple for doctors to institute basic mitigation practices to protect patients, and it's absolutely necessary to ensure that vulnerable patients can access medical care when they need it. We can choose to avoid going into a restaurant to mitigate our risk, but we can't choose to avoid necessary medical care.

Please draft a policy that actually takes seriously the lessons of the COVID pandemic — both to address the ongoing risk from COVID, and to prevent future pandemics. We can't just pretend the last four years never happened. We need to learn from them.
Member of the public
[May 06, 2024 7:22 PM]
WHO states Covid19 is airborne and we know this is not the only infectious airborne disease. Thus wearing N95 respirator masks, adequate ventilation and HEPA filters along with air quality monitoring with CO2 monitors would have a big role in protecting patients, medical practitioners, and staff. All of us should be able to feel that we are being treated in a safe and healthier space.
Member of the public
[May 06, 2024 7:21 PM]
My father died of an MRSA outbreak 19 years ago at Sunnybrook Hospital in Toronto, one of a number of people who died during that outbreak. He was put in critical care in an isolation room with negative pressure and we were required to mask and gown to enter the room. Staphylococcus aureus is a Biosafety Level 2 (BSL-2) pathogen. SARS-CoV-2 is a Biosafety Level 3 pathogen. Why, 19 years ago, was there an adherence to safety protocols for a lower level pathogen and why are those not being rigorously implemented for a higher risk pathogen?

To ensure safe and equitable access to medical care, it's essential for all medical facilities to implement airborne precautions. This involves installing high-quality air filtration systems, including HVAC and HEPA filters, and monitoring CO2 levels in real-time, with this data readily available to both caregivers and patients.

Staff must consistently wear properly fitted respirator masks whenever patients are present, extending this requirement to administrative personnel as well. Patients shouldn't be put in the position of having to request caregivers to wear masks, recognizing the inherent power dynamics involved. Care providers should lead by example and prioritize the safety of their patients. Two-way masking should be required at all times.

Any protocols requiring less than the above are ethical malfeasance given what we know about airborne transmission and asymptomatic transmission of SARS-CoV-2.
Member of the public
[May 06, 2024 7:21 PM]
Airborne transmission of infectious diseases is a key area of IPAC. Airborne transmission is scientifically demonstrated, and recent reviews and policy, including e.g., the WHO (https://iris.who.int/bitstream/handle/10665/376496/9789240089181-eng.pdf), and Cochrane Canada's CAN-PCC recommendations are beginning to reflect this. It *must* be addressed in the context of unmitigated spread of COVID-19, along with influenza, RSV, and now cases of measles and rising rates of TB and other infectious diseases. Many clinicians and office staff are not aware of the prevalence of airborne transmission, and the steps needed to mitigate transmission risk, including respirators, ventilation & filtration; UV & air-cleaning, etc.. Guidance should be given that healthcare providers and office staff maintain minimum clean air standards and use mitigations such as wearing n95 respirators (see, e.g., the OSPE's guidance: https://ospe.on.ca/indoor-air-quality/).
Member of the public
[May 06, 2024 7:09 PM]
You need to address the airbone transmission of several diseases and, in order to protect the patients, the use of respirators, air filters with HEPA or MERV 13 should be mandatory to all staff and patients.
Organization
[May 06, 2024 7:00 PM]
College of Physicians and Surgeons of Alberta (CPSA)
 
Thank you for allowing us the opportunity to provide feedback on the draft IPAC policy.

Overall, the tone of the policy and advice document set the tone for safety amongst CPSO members. CPSO may wish to consider the following:
  • Policy 1 sets out that physicians must follow PIDAC’s Clinical Office Practice document; however, the lengthy document combines recommendations, notes, “pearls of wisdom,” and legislated requirement. It might be considering and/or testing the enforceability of requiring compliance with this document (e.g., it may be challenging to enforce a recommendation). It may also be unclear on how to approach some recommendations (e.g., are PIDAC’s recommendations for staff immunizations mandatory?).
  • Policies could be broadened to include clinical staff who assist the physician (e.g., “the physician must ensure that he/she, and those in the clinical office setting, undertake…”). In all likelihood, physicians will rarely do any of the tasks listed in these policies (e.g., environmental cleaning, reprocessing, terminal disposal of sharps) but should be ultimately responsible for IPAC in the clinic.
  • Is it possible Policy 9 could create a conflict between what the clinic deems to be appropriate for improving quality of care and what is required in the PIDAC document (e.g., a clinic decides to vary from PIDAC because it can see more patients doing things another way and the risk of infection is low)? Perhaps removing “to improve safety and quality of care” would reduce potential conflict.
  • In our Infection Prevention and Control standard, we added the requirement that regulated members fully cooperate with any IPAC-related practice visit (see clause 6) in accordance with the Health Professions Act: perhaps there is similar legislation in Ontario to ensure cooperation.
Member of the public
[May 06, 2024 6:54 PM]
During the COVID-19 pandemic, we have learned much about the role of airborne transmission as the primary infection vector for respiratory viruses. Additionally, the role of asymptomatic and pre-symptomatic patients in the spread of COVID-19, and likely other pathogens as well.

Every clinic/physician's office should have: 1) Upgraded ventilation and filtration (appropriate HEPA filtration and adequate air exchanges per hour for a given square footage/office layout). 2) Universal masking policy, with well-fitted, high quality resiprator-equivalent masks (and a policy for exemptions). 3) Paid sick days and a strong stay-home-when-sick for all providers and staff and 4) Education for all providers and staff, especially those in charge of IPAC, to reflect the most up-to-date understanding of disease transmission (i.e., paradigm shift away from discreet contact/droplet/airborne categorization).

Failure to respond appropriately to new evidence puts patients, staff and providers at risk.
Member of the public
[May 06, 2024 6:00 PM]
It is very important that all healthcare settings implement the risk mitigation measures proven to protect patients and healthcare staff from COVID and other airborne viruses, namely cleaning the air via improved ventilation and air purification (as well as regularly monitoring air quality), universal masking using high-quality N95 respirator masks (this will also help protect people from the high percentage of infections that are asymptomatic), testing of patients and staff (and ideally visitors) and putting processes in place to support isolating when symptomatic or if testing positive. The modeling of these science-based measures by hospitals and healthcare professionals would go a long way towards breaking through the substantial amount of misinformation surrounding this subject. It is time that we acknowledge that it is not just the elderly or immunocompromised who are at risk but, in fact, every one of us is potentially vulnerable to the short and long-term health consequences of COVID and other viruses. We need to do everything possible to protect our struggling healthcare system, those who work in it, and everyone who needs it to be a safe place when they are at their most vulnerable.
Member of the public
[May 06, 2024 4:46 PM]
“Member of the Public” but also a retired professional in a closely-related but non-medical field.

I have made a separate comment, but I wish to include an objection to one aspect of the method for taking comments, which also applies for the input to the survey.

The options available when submitting a comment for this document regarding the type of respondent (or “Are you...” in the survey) include several medical-related options (physician, medical student, other healthcare professional) with the only other type of identification for individuals being “member of the public”.

This means that individual professional who is outside the medical field is just considered a “member of the public”. A university professor contributing forty years of research in infection control, but who is not practising medicine is just a “member of the public” as far as their input goes. An expert in health and safety providing consulting expertise that has saved lives and improved employee health in workplaces across the continent is still a “member of the public”. Likewise so is a researcher in respiratory protection with a career designing and testing the very personal protective equipment that clinics should be using.

This becomes significant when the comments or survey responses are later analysed with their importance assessed and actions decided. At best, logging each medical-related responder but disregarding the background of any non-medical expert could be considered to introduce an inherent bias. At worst, doubtless unintentional, it could be interpreted as telling the world that the College doesn’t put value on input from professional experts outside its own community.

Given the volume of comments, this review exercise does not appear to be finishing soon. Please resolve this issue in the commenting process in the future for this and other programmes, and allow respondents to identify their professional expertise in their replies.

Thank you.

(Also please also stop merging all paragraphs into one when comments are posted).
Member of the public
[May 06, 2024 4:42 PM]
I was disappointed to not see any mention of masking as a prevention method. Hospitals and medical clinics serve Canadians at their most vulnerable. We understand the science of transmission and the tools we have to prevent it. Please consider reinstating recommending masking in healthcare - for everyone’s health.
Organization
[May 06, 2024 4:36 PM]
Canadian Aerosol Transmission Coalition
 
Please see attached file. Kindly retain paragraph distinctions when published, thank you.
Ont College Infection Prevention Practices Comments - CATC.pdf
Other health care professional (including retired)
[May 06, 2024 4:23 PM]
Infection prevention and control needs to address ventilation, filtration, and respirator masks.

Covid, measles, influenza, and other diseases spread through the air. Just like surface transmission, spread through the air needs to be prevented in medical settings.

Please see ASHRAE standard 241 for ventilation and filtration designed to prevent disease transmission through the air.

Respirator masks need to be worn in healthcare to prevent transmission of disease. Like hand washing, the evidence is clear. Medical culture needs to implement the evidence to protect patients and practitioners.
Organization
[May 06, 2024 4:00 PM]
Ontario Federation of Labour
 
Response in PDF format:
 
IPAC for Clinical Office Practice_OFL Organizational Response_20240506.pdf
Member of the public
[May 06, 2024 3:53 PM]
Both documents have overlooked the critical aspect of airborne transmission of pathogens, notably SARS-CoV-2. It's imperative to incorporate discussions on ventilation and the promotion of clean air within healthcare settings. Countless studies have highlighted the efficacy of clean air in reducing the spread of pathogens, emphasizing the need for robust ventilation systems and air quality management strategies

Secondly, universal masking must in place place all year round in healthcare spaces:
1. Protection Against Airborne Pathogens:
Pathogens, including SARS-CoV-2, pose a persistent threat year-round, irrespective of seasonal variations. Universal mask mandates for physicians are essential to mitigate the risk of airborne transmission within healthcare facilities. Masks serve as a critical barrier, reducing the spread of infectious respiratory aerosols and protecting both healthcare providers and vulnerable patients from exposure.

2. Mitigating Asymptomatic Transmission:
The prevalence of asymptomatic carriers underscores the importance of universal masking among healthcare workers. Asymptomatic transmission can occur at any time, emphasizing the necessity for year-round mask mandates to prevent unwitting spread of infections. Universal mask requirements alleviate the burden of personal risk assessments and ensure consistent protection for all individuals in healthcare settings, reducing the risk of transmission and fostering a safer environment for patients and staff alike.

3. Upholding Professional Responsibility and preserving continuity of care.
Physicians have a professional and ethical obligation to prioritize patient safety by adhering to year-round mask mandates. Consistent mask-wearing demonstrates a commitment to fulfilling this responsibility, reducing the likelihood of transmitting infectious diseases to patients and colleagues. Moreover, maintaining a healthy workforce is paramount for preserving continuity of care. Enforcing year-round mask mandates minimizes the risk of healthcare workers falling ill, thereby mitigating disruptions in patient care and upholding the integrity of healthcare delivery.

In the current climate, where the burden of personal protection often falls solely on patients, implementing universal masking policies in healthcare settings is crucial for fostering a compassionate and inclusive environment. Patients should not fear repercussions or be pathologized for advocating for their own safety. Universal masking policies, enforced by physicians in leadership positions, offer a compassionate approach that prioritizes the well-being of all individuals involved in healthcare interactions.
Member of the public
[May 06, 2024 3:37 PM]
Masking is vital when it comes to effective infection control. Respirators should be mandated for all health care workers and, at the bare minimum, surgical masks should be a requirement for anyone entering a space where vulnerable patient populations exist. To require anything less is negligence.
Member of the public
[May 06, 2024 3:13 PM]
Clear guidance on masking and using HEPA filters to clean the air are missing from these documents. My loved ones need weekly medical appointments to address ongoing medical needs and this policy doesn't address key points that would make their appointments much safer. I would like to see mandatory, universal masking with N95 respirators in healthcare settings. Air purifiers with HEPA filters should be running in every room. Doctors should offer virtual appointments as appropriate. And all health care workers should at a minimum respect patient wishes and mask properly with N95 or elastomeric mask when asked.
Member of the public
[May 06, 2024 3:13 PM]
Infection control needs clean air (proper ventilation and filtering) and use of respiratory masks.

We are still in a pandemic killing and disabling people. COVID, flu, RSV, TB, etc are airborne.

You’re ignoring the most basic science if you ignore masks and the concept to Do No Harm.
Member of the public
[May 06, 2024 3:13 PM]
This is shocking. Medical masks? They do not over adequate protection for airborne virus. Huge items missed:

1. N95 masking should be required for everyone.
2. Use of HEPA filters with proper ventilation
3. CO2 detectors displaying air quality levels
Member of the public
[May 06, 2024 3:01 PM]
I’m am a medically vulnerable person. With Covid,flu,rsv, and even emerging H5N1 all being airborne, not having masks and a set standard practice is nothing less then a eugenics practice. It will prevent me and all medically vulnerable people for accessing health care until it too late. Please allow me to see healthcare in a safe environment.
Organization
[May 06, 2024 3:00 PM]
Ontario Society of Professional Engineers
Note: Some content has been edited in accordance with our posting guidelines.
Response in PDF format:
IPAC for Clinical Office Practice_Organizational Response_20240506.pdf
Member of the public
[May 06, 2024 2:30 PM]
Response in PDF format:
IPAC for Clinical Office Practice_Member of Public Response_20240506.pdf
Member of the public
[May 06, 2024 2:23 PM]
The draft Infection Prevention and Control for Clinical Office Practice policy and advice document are missing two crucial elements: Standards for clean and safe air, and standards for respirator use to reduce the risks associated with the spread of infectious aerosol particles. Aerosol particles that can be inhaled (at both near-field and far-field ranges) have now been recognized as the predominant means through which COVID-19 spreads, and are also likely a significant contributor to the spread of many other infectious diseases with respiratory tract involvement. In the context of the continuing COVID-19 pandemic and recurring waves and outbreaks of other respiratory illnesses including RSV, influenza, and measles, physicans' offices in Ontario should be required to meet ASHRAE Standard 241, Control of Infectious Aerosols, to safeguard the health and safety of all patients.

As an academic researcher in the field of Critical Disability Studies and as a disability rights and justice advocate, I strongly urge the CPSO to prioritize clean and safe air that meets the ASHRAE 241 standard and the appropriate use of respirators to ensure the safety of patients. Many patients with disabilities and chronic illnesses remain particularly vulnerable to negative outcomes following infection with COVID-19 and other viruses that spread through the airborne route, and continue to face significant barriers to accessing health care including as a result of unsafe conditions in physicians' offices. Requiring safe air and respirator use will facilitate better access for all patients while further creating safer working conditions for staff and physicians themselves.
Member of the public
[May 06, 2024 2:17 PM]
Note: Some content has been edited in accordance with our posting guidelines. 
Hello,
As a mature member of the public, my review first was of comments contributed with select reading of the comments.
April 12, from Occupational Health & Safety Branch, significant content to consider.
May 2, Medical Student
May 2, Retired Statistician
Many comments from members of the public.

Ventilation, masking, acknowledging airborne transmission, asymptomatic, pre-symptomatic or symptomatic but without precautions are factors to continue to consider.

In a solo practice office or shared clinic setting, the physical building, owned or rental, budget for ventilation, other considerations must be considered.

Trust and education among members of staff, in patients who visit for appointment, in cleaning products, routines is the ideal model.

The second document I reviewed was the advice document.  I noted much detail including not using spray or trigger bottles due to respiratory irritation.  That limits options.

In an established office practice with professional staff, the reference to environmental cleaning and reprocessing reusable medical equipment stand out as critical items to ensure safety.

The draft policy was reviewed last.  As we consider the COVID pandemic in its 5th year, it should be referenced.  With lack of clear, continuing federal and provincial health messaging that does reach the patient population with respect to both vaccines and the current COVID variants, it is important to try to reach the public at a local or practice level re: COVID but also infectious disease prevention.

In Guelph, the local public health has excelled at sharing and preparedness.  They have the fall 2024 COVID vaccine news on the website since April if not earlier. 

Because local public health staff were organized at the early vaccine clinics, I was offered the option of sharing my email first for research for the CANVAS study of vaccine side effects, then for the COVID Immunity Task Force (CITF) StopCov study [redacted], studying 1,000 participants for vaccine antibodies, side effects, COVID infections, starting in spring, early summer 2021 when much less was known about the infection and the vaccines.  The study will end later this year and has learned much about the COVID vaccine experience but also about immunity and more. 

Has an infectious disease medical group been consulted by the CPSO as part of the draft policy process?
Member of the public
[May 06, 2024 1:41 PM]
Masking (N95 at a minimum) should be required in all healthcare settings - by staff and patients. Hepa filters should also be mandatory with guidelines on filter replacement and maintenance. Health care settings are not the place where people (especially immunocompromised) should have to worry about picking up a preventable infectious illness!
Other health care professional (including retired)
[May 06, 2024 1:33 PM]
The guidance is not up to date to control respiratory pathogens that involve infectious aerosols in asymptomatic spreaders. Ventilation, filtration and masking and other controls need to be addressed. Placing vulnerable patients into a position of a point of care assessment only involves those patients required to have their health risks decided by another and removes self advocacy. An Urgency of Normal practitioner or one who is anti mask cultured may use that point of care assessment to their own benefit towards not masking and not for the protection of the patient. It also leaves vulnerable patients in a lower position of having to request someone with power over them to mask, leaving it up to that person to determine if they would comply. This is ethically wrong. How does a patient, especially a child, have agency in this situation?
Other health care professional (including retired)
[May 06, 2024 1:00 PM]
Hello,

I'm writing to provide feedback, as requested, on the draft IPAC for Clinical Office Practice document. I'm writing to you as both a health professional and patient. Please see my comments below:

While the highlighted areas are certainly important, there are several critical concepts & pieces of guidance missing from the draft, as outlined below:

The COVID-19 pandemic has demonstrated that symptom-based screening and point-of-care risk assessment are insufficient for breaking chains of transmission. Resulting in catastrophic amounts of death and disability that could be readily prevented by embracing new evidence. 

We now know that respiratory pathogens like SARS-CoV-2 are transmitted easily through shared air, and that asymptomatic and presymptomatic transmission are major drivers of disease transmission. Given this new understanding, the medical establishment has a duty to respond appropriately. 

Every clinic/physician's office should have: 1) Upgraded ventilation and filtration (appropriate HEPA filtration and adequate air exchanges per hour for a given square footage/office layout). 2) Universal masking policy, with well-fitted, high quality resiprator-equivalent masks (and a policy for exemptions). 3) Paid sick days and a strong stay-home-when-sick for all providers and staff and 4) Education for all providers and staff, especially those in charge of IPAC, to reflect the most up-to-date understanding of disease transmission (i.e., paradigm shift away from discreet contact/droplet/airborne categorization). 

Failure to respond appropriately to new evidence puts patients, staff and providers at risk. Such behaviour directly contradicts the Hippocratic Oath.

Thank you for your time & consideration.
 
Member of the public
[May 06, 2024 12:57 PM]
Despite my best individual efforts to avoid it, I currently have covid for the second time. It is not possible, practical, or appropriate in a society that claims to care for the collective to put avoiding illness, especially airborne illness, on individuals. There is no downside to cleaner indoor air, and masking policies are critical in places where people are definitely sick or where people at high risk or children unable to mask need to go for their own health. Common sense needs to apply here, not politics.
Member of the public
[May 06, 2024 12:00 PM]
Masks and HEPA filters should be required in all medical environments as many people are going to receive care only to be exposed to a covid infection.

Requiring these would also stop the discrimination folks who are wearing masks for their own safety are receiving. There have been far too many stories of people not being accommodated for their ask of the physicians to wear a mask (Even when it is being offered to them by the patient).
Member of the public
[May 06, 2024 11:42 AM]
Evidence shows incontrovertibly that masking, filtration, and ventilation are critical to controlling the spread of infectious diseases, including COVID-19. COVID-19 is airborne and continues to maim and kill largely unabated. Long COVID is a serious and growing burden on society and the healthcare system. Please require A) mandatory air quality controls including MERV 13 and HEPA filtration and adequate ventilation (follow ANSI/ASHRAE Standards 62.1 and 62.2, the recognized standards for ventilation system design and acceptable indoor air quality, or IAQ), and B) mandatory masking for all healthcare personnel and patients, specifically KN95 or N95 or better respirators (as opposed to baggy blue surgical or "medical" masks, which are leaky and unsuitable for controlling the spread of airborne viruses). We're effectively in the dark ages at this point. Please do your duty to protect patients and the larger community.
Member of the public
[May 06, 2024 11:41 AM]
The ‘death stats’ are in nationally, and Covid is now (as of the most recent data) the third highest leading cause of death in Canada.

If smoking was the third highest cause of death, we would ensure that patients have the option of accessing medical services in a smoke-free environment. A smoke-free section, at the very least! Let’s do the same thing here.

It’s the right thing to do.
Member of the public
[May 06, 2024 11:22 AM]
It is imperative for all healthcare professionals and facilities to implement mandatory masking in every patient care area across all healthcare facilities in Ontario. As we navigate through the fifth year of an airborne pandemic, it is crucial to take proactive measures to mitigate the transmission of diseases within medical settings. This pandemic has resulted in widespread disability and immune system damage among both patients and medical professionals, exacerbating the burden of illness caused by various other airborne diseases. Consequently, individuals are faced with the daunting decision of either delaying necessary medical visits or risking their compromised health by accessing medical facilities that lack proper measures in place. The absence of requirements for adequate air filtration, provision and use of respirators, and transparent data tracking for SARS-CoV-2 and other airborne diseases is not only irresponsible but also appears to be deliberately malicious and eugenicist in nature.
Member of the public
[May 06, 2024 11:21 AM]
1. We need mandatory, universal masking with N95 (or better) respirators in healthcare settings to prevent nosocomial infections. In the draft document, Policy 2 v refers to the wearing of medical masks “when required.” Unfortunately medical masks do not provide adequate protection, and this policy is very vague.

It is absolutely essential for healthcare workers to follow airborne precautions, by wearing respirators (e.g. N95, N99, FFP3 or elastomeric respirators). The policy must mention respirators, rather than obsolete medical masks. With mandatory, universal masking with respirators, healthcare workers and patients can avoid contracting COVID-19, influenza, measles, tuberculosis, and other diseases.

2. Thanks to laissez-faire policies, there is a very high prevalence of SARS-CoV-2, and this is an issue year round, not just during the so-called “respiratory season.” Nosocomial COVID infections can lead to COVID-induced health issues such as long COVID, cognitive issues, strokes, heart attacks and heart failure.

3. All clinics should use HEPA filters to clean the air. HEPA filters are common in the offices of dentists. They should be used in clinics to clean the air, and reduce the risks of contracting COVID-19.

4. Virtual appointments should be readily available. For many appointments, it is really not necessary to go to a clinic. For example: a routine renewal of a prescription.

5. Doctors should take into account the preferences of patients. If a patient asks you to wear a mask, please wear an N95, N99, FFP3 or elastomeric respirator. Do not downplay the risks associated with COVID-19 infections — it is not “just a cold.” Many patients are vulnerable, and they want healthcare workers to take precautions to prevent transmission. Also keep in mind that many infections are asymptomatic. In any case, healthcare workers should always be wearing respirators when they’re in a clinic or hospital.
Member of the public
[May 06, 2024 11:07 AM]
Given that we are currently in an ongoing airborne disease pandemic, with other diseases that are transmitted by airborne particles circulating in our community (e.g., measles) and with the risk to be circulating soon (e.g., H5N1, HPAI), as well as the risk of more frequent pandemics in the near future due to climate change and other factors, this policy is disappointingly lacking in having incorporated any learnings from the SARS and COVID-19 pandemics nor any future-readiness.

We already know that we can incorporate simple measures to improve indoor air quality, and this policy lacks them: N95 respirators, and cleaning the air via filtration, ventilation, and UVC cleaning.
Physician (including retired)
[May 06, 2024 11:03 AM]
I believe that given the continuing risk of COVID-19 and other airborne infections now and in the future, that medical offices should be held to ASHRE 241 standards, and until then, and perhaps afterwards , we should be requiring universal masking in all medical settings both inpatient and out patient.
We are told we are entering the “age of pandemics “ and in spirit of doing no harm we need to be prepared.
I would also like to see mandatory air filters as another layer of protection in all medical settings and perhaps UV when approved especially in setting where a mask cannot be worn by the patient.
Everyone has the right to safe medical care and I find it particularly distressing when I find someone has acquired Covid in a medical setting.
It may be said that this is too expensive, but when I improved my office ventilation in 2020 it was quite inexpensive, less than my monthly fees for my EMR.
Organization
[May 06, 2024 10:54 AM]
Canadian Covid Society
 
As the Co-Chair of the Canadian Covid Society, a non-profit organisation formed to fight the acute and long-term sequelae of Covid-19, I am writing to express our concerns regarding the College's recent draft policy on "Infection Prevention and Control for the Clinical Office Practice."

The COVID-19 pandemic has highlighted the importance of robust infection prevention and control measures in healthcare settings. With over 3.5 million Canadians who have or are now suffering from long-term symptoms following COVID-19, it is crucial that we prioritise the safety of both patients and healthcare workers.

Recent research has demonstrated that respiratory viruses, including SARS-CoV-2, spread predominantly through aerosols emitted by infected individuals while breathing, talking, and coughing. These aerosols can remain viable in the air for extended periods and travel significant distances. Infections, confirmed by whole genome sequencing, have been documented in hospitals almost five hours after the infected person left the room.

Presymptomatic and asymptomatic transmission further complicate efforts to control the spread of these viruses.

In light of this evidence, we strongly urge the College to reconsider its current draft policy and implement the following changes:

1. Recognize the responsibility of employers and healthcare facilities in planning and implementing effective infection prevention programs, rather than placing the burden solely on individual healthcare workers.

2. Acknowledge the importance of a multi-faceted approach to infection prevention, including engineering controls (e.g., ventilation, HEPA and MERV13 and above filtration, and isolation rooms), work practice controls, and personal protective equipment (PPE) in accordance with the hierarchy of controls.

3. Emphasise the use of properly selected and fitted respirators, such as N95s or higher, for healthcare workers in close contact with potentially infectious patients. Medical masks, as suggested in point 2.v of the draft policy, are significantly less effective in preventing aerosol transmission.

4. Establish explicit, science-based criteria for determining the appropriate protective measures for specific pathogens, considering factors such as exposure assessment, individual vulnerabilities, and the full range of potential health impacts, including long-term sequelae.

5. Strengthen recommendations for source control measures, including enhanced ventilation in patient care and non-patient care areas, expanded use of airborne infection isolation rooms (AIIRs), and proactive use of masks as a preventive measure.

Furthermore, we would like to highlight the legal obligations of physicians under the Westray law, which establishes a duty for all persons directing the work of others to take reasonable steps to ensure the safety of workers and the public. The College's guidance must ensure compliance with this law, protecting both healthcare workers and patients in the clinic setting.

Engaging the expertise of aerosol scientists, industrial hygienists, ventilation engineers, respiratory protection experts, patients, and frontline healthcare workers is essential in developing effective infection prevention policies. We strongly recommend that the College consult with these stakeholders and incorporate their insights into the final policy.

The health burden of COVID-19 infections and reinfections in healthcare settings is antithetical to the principle of "First, do no harm." Vulnerable populations, such as cancer patients, immunocompromised individuals, and those with long COVID, are at particularly high risk of severe outcomes from hospital-acquired infections. It is our collective responsibility to protect these individuals and ensure that healthcare facilities are safe for all.

We urge the College to revise its draft policy to reflect the current scientific understanding of respiratory virus transmission and to prioritise the health and safety of both patients and healthcare workers. By implementing robust infection prevention measures, including the use of respirators and improved ventilation standards, we can work towards creating a healthcare system that truly embodies the principle of "First, do no harm."

Thank you for your consideration of our concerns. We look forward to engaging in further dialogue with the College to develop evidence-based infection prevention policies that protect the health and well-being of all Ontarians.

Sincerely,
Dr. Joe Vipond, Co-Chair
Emergency physician

Canadian Covid Society
9580 Yonge Street
Suite 9255
Toronto ON L4C 1V6
Member of the public
[May 06, 2024 10:34 AM]
Respirators and HEPA filters are a must.
Member of the public
[May 06, 2024 10:20 AM]
Require N95 masking and appropriate indoor air quality measures be taken to mitigate the spread of deadly airborne viruses in healthcare spaces and to make them accessible to persons who are vulnerable and disabled. These people deserve protection from airborne illness as a RIGHT without questions asked. Require mandatory education for physicians on the importance of masking. Sanction physicians who diagnose patients who insist on N95 masking with "mask anxiety". Start making patients healthier, not sicker. Healthcare spaces should never be the source of infection. Nosocomial infections are a stain on the provision of healthcare. Ill, immunocompromised and disabled patients who contract Covid-19 in healthcare spaces are at greatly increased risk of death. This is absolutely unacceptable when visiting healthcare spaces are contributing to early death.
Member of the public
[May 06, 2024 10:17 AM]
Airborne illnesses require airborne protections. The most vulnerable are served on-site seeking care to be made well. They are not there to acquire additional preventable airborne illnesses on top of the care they are already seeking. People are not seeking needed medical care due to the risks of infection not being addressed and managed properly.

ASHRAE 241 standards exist now to prevent the airborne transmission of infectious diseases. A combination of ventilation, filtration, and far UV can help achieve such standards. At the same time, if someone infectious breathes in another person’s face, whether they know it or not, be they symptomatic, asymptomatic, or presymptomatic, and that person isn’t wearing protection, they will likely fall ill. Comfortable N95 or better respirators and elastomerics exist to prevent airborne transmission. Source control matters. There is no excuse. Some of the most vulnerable can’t mask, which includes children under 2.

Medical settings are not social clubs. They are places to help people heal, not get worse. If you are not addressing and managing airborne transmission Year 5 of an ongoing airborne pandemic as per the WHO, you are not doing your jobs.
Member of the public
[May 06, 2024 9:42 AM]
I have previously answered the survey, looked at the draft document & advice document. Add me to the list of people disappointed and concerned about the lack of guidance for airborne transmission.
1) With all the minimizing and disinformation about the risks of both acute & long covid, there is NO informed consent in the public about a lack of masking.
2) Not addressing airborne transmission & mitigation (N95/ respirators), air cleaning & filtration 4+ years into an airborne pandemic is negligence. I blame the IPAC droplet orthodoxy on this, but if they cannot accept what engineers & hygienists are telling them, they need to step out of the way. This is contrary to goals of being able to learn and adapt to circumstances, and PREVENT.
3) Because people cannot consent to negligence, these current draft guidelines are counselling Drs into legal vulnerability from harming patients unable to consent to harmful environmental circumstances, that are known to easily be prevented with high effectiveness (respirators).
I have looked at past IPAC guidance documents, that do not seem to have ever been followed such as this from 2020 https://www.publichealthontario.ca/-/media/Documents/B/2020/bp-novel-respiratory-infections.pdf which talks abut airborne precautions, N95s & evaluating PPE, and continuing education and review of effectiveness of programs (the great failure of IPAC).
4)Because of the disinformation, lack of masking, lack of people to access testing or doing it, this guidance puts doctors at risk of health complications that may end their ability to practice. That puts a further strain on a negligently underfunded healthcare system.
5) There is a human rights requirement to create safe accessible spaces, and failing to address airborne transmission infringes human rights, and makes care unsafe. I have not seen this addressed. The current guidance is discriminatory
Due to the recent Toronto Hospital Operations Table guidance (April 2024) I have had to change care plans to one only accessible by car (which will require time off work or expensive transport) because the hospital within walking distance will be overrun with unmasked staff & patients, and there is significant evidence that one-way masking is ineffective.
6)Virtual options should be reinstated, and if the government is unwilling to properly (or at all) compensate these visits, then public education & support of Dr's (AND Government's) human rights obligations is needed. Perhaps even challenging the situation legally. This is also a disability accommodation
7) Because labs are often done at for-profilt 3rd party sites, and these are not covered by CPSO regulations, Dr's should be checking that test locations they are referring patients can protect them. It may mean bringing testing back in-house, like when I was younger. Especially since some procedures require un-masking. It may also mean getting local public health on board to ensure air quality/ masking at local testing sites.
8) some procedures and specialties may be especially risky (ENT, some imaging - MRI or requiring intubation to deliver liquids in GI,etc) and need proper ventilation throughout a building and sufficient time spacing.
9)I'm excited about the possibilties of engineered infeciton prevention from high touch surfaces, and far UV or ceiling UV for disinfection purposes.
10) I have seen instances of people saying Drs removed or lowered or otherwise touched people's masks. Clearly this is unacceptable and needs to be explicitly addressed. If an appointment requires putting a patient at risk, it should also be disclosed in advance, as well as discussing options the patient might have to further protect themselves.
Member of the public
[May 06, 2024 8:57 AM]
The two vital safety practices that are missing from the recommendations are masking and proper air ventilation. Even mirror masking would be a bare minimum for effective patient-provider safety and care (healthcare providers mirroring the masking behaviors of patients as a practice of safety and empathy, for everyone including the disabled, chronically ill and/or immunocompromised patients). Since covid is airborne, the WHO has been clear that ventilation, air filtration are vital for stopping the spread of covid. Covid is not seasonal and it's not gone. Long covid, post covid symptoms, and long lasting or permanent effects are still a significant risk for the public. If medical professionals won't model science-backed, evidence-based precautions like masking and proper air ventilation, then the public certainly won't. Medical professionals have immense responsibility and power in the community. It's not an easy burden to say the least. And, people tend to listen to those in authority. Please lead by example.
Member of the public
[May 06, 2024 8:20 AM]
I am bewildered by the lack of importance given to air quality and adequate ventilation. We have the technology readily available to ensure medical settings are safer for patients and hospital staff. Monitoring air quality, use of hepa filters, and universal masking at least during periods of high transmission are proven to be effective. It is time to accept that better practices are needed and that patients have the right to a safe space for care.
Member of the public
[May 06, 2024 4:37 AM]
It is an absolute duty of all medical professionals and facilities to take reasonable precautions to measure and reduce transmission of diseases in medical settings. We are in the 5th year of an airborne pandemic which is causing mass disabling and immune system damage to patients and medical professionals creating additional illness burdens from an array of other airborne illnesses.

This is further increasing the medical and disability burden for the whole population as people must make an impossible choice between delaying and avoid necessary medical visits and avoiding further unnecessary risk to their already compromised health by going to deliberately inaccessible medical facilities.

In this context, the lack of requirements for proper air filtration, respirators provision and use, and transparent data tracking and tracing for sars-cov-2 and other airborne diseases is beyond irresponsible and is hard to see as anything except deliberately maliciously eugenicist.
Member of the public
[May 05, 2024 9:23 PM]
Many things were learned as the public navigated through Covid. The following practices should continue:
1. Adequate ventilation in public spaces (schools, offices, stores, etc)
2. Air quality monitoring
3. The use of HEPA filters
4. Universal masking using N95 masks during periods of high transmission (flu season, etc)
Thank you.
Member of the public
[May 05, 2024 9:09 PM]
I have nothing more to respond to the above questions.
Member of the public
[May 05, 2024 9:06 PM]
Doctors should not under any circumstances be infecting patients.

We now know that the majority of viruses (SARS-COV-2, H5N1, RSV, Flu, ect...) are airborne.

Appropriate precautions must be installed permanently to address this.

That means that physicians and all medical staff should be mandated to wear N95 respirators or better (P100) while at work. And especially while seeing patients.

Patients should not fear having to ask their medical provider to wear a respirator and then receive poorer care because they dared to ask. That is the current dynamic and it is unacceptable.

The virus aerosols can remain in poorly ventilated rooms (e.g. medical exam rooms) for hours.

After one unmasked, infected person breathes out in a room, the aerosols in the room can infect patients, nurses, and doctors for hours, long after the infected person has left the building. That is why all exam rooms must also have HEPA air purifiers installed to clean the air and prevent medical professionals and other patients from being infected by a patient that was there hours earlier.

Patients are often infectious while asymptomatic - that is why everyone in all medical facilities should also be mandated to wear at least a KN95/N95 or better as a way of source control. These should be provided for free for those who need one.

Anything less than this is the acceptance and encouragement of nosocomial preventable infections, disability, and even death. Doctors should be prioritizing patient care and that means wearing a N95 or better and having all staff do the same in a clinical environment with HEPA air purifiers and the best ventilation possible.

https://whn.global/doctors-should-not-infect-patients/
Member of the public
[May 05, 2024 8:36 PM]
Patients and public expected to be wearing masks (and staff wearing respirators) in all health care settings on a regular basis in all areas would prevent transmission of infection to a huge extent. Many illnesses are transmitted through the air through talking and breathing and so universal or near universal masking would increase safety for vulnerable people and everyone greatly.

Covid-19 also has high risk of long-term harm, which stresses our care systems even further than they already are. Masking in health care settings alleviates pressure by lessening the burden of respiratory disease transmission in the short-term, as well as mitigates long term risk.

Further, widespread HEPA filtration and ventilation should be invested in to further increase air safety and reduce transmission of infection.
Member of the public
[May 05, 2024 8:25 PM]
Masking in clinics and hospitals wonderful . Keeps the healthy well . HEPA filter systems running making the air safer .
Member of the public
[May 05, 2024 8:20 PM]
In order to make accessing medical care safe and accessible to all, airborne precautions need to be taking in all medical facilities. This includes high quality air filtration via HVAC and additional HEPA filters, CO2 monitoring (that information should be posted in real time for both care providers and patients to monitor), and high quality and well-fitted respirator masks.

All staff should be wearing high quality and well-fitted respirators at all times when patients are around (including admin staff). Ideally the same high quality and well-fitted respirators should be provided and required to all patients seeking care as well. If that is not possible, then there should be a safe waiting area provided for maskers who want to stay safe.

If patients are not required to mask as well, then there should be rooms that only masked patients use, as airborne illness can linger in the air for hours. And especially for young children who cannot safely and reliably mask and for folks who legitimately cannot mask, they should not have to risk their safety to access care.

At a minimum, patients should never have to request their car provider wear a mask. There is a huge power imbalance in requiring that. Care providers should mirror patients.
Member of the public
[May 05, 2024 7:33 PM]
I am the mother of a medically complex child who requires frequent specialist appointments for screenings and to manage chronic health issues.  I am also high risk with my own medical conditions, and the only adult available to take my child to their appointments. Accessing safe healthcare is getting increasingly difficult. Doctors do not seem to understand or care that infecting us with Covid-19 could cause serious problems for my family.

My requests for our healthcare providers to wear a mask are frequently disputed. Recently, my cancer screening was cancelled the night before it was scheduled because the technician assigned to do my testing decided that they did not want to honour my accessibility accommodation request under the Ontario Human Rights Act where I asked them to wear an N95. As medical professionals are no longer required to even wear a surgical mask, the decision has been left to their own personal preference on whether to mask. The fact that our family needs to protect ourselves from infection because we could suffer severe health impacts if infected is not part of the decision-making process.

It has been proven in multiple studies that asymptomatic transmission occurs in 50% of cases. The World Health Organization acknowledges that Covid transmits through the air at both short and long distances. It is exhaled in the breath, floats in the air as a "puff cloud" and infects people through inhalation of the virus which lingers in the air. The risk of formite infection is extremely low. Yet, people are being asked to sanitize their hands instead of wearing a mask.
When I request that my healthcare team wear an N95 to prevent airborne transmission, I'm labelled as anxious or difficult. Sometimes I'm lectured by the doctor in front of my child. I am extremely concerned about the impact that the lack of masking, and the failure to follow the scientific evidence in healthcare facilities, is having.

A survey by the British Medical Association in 2023 showed that a significant proportion of doctors with Long Covid were experiencing debilitating long-term effects. These findings included: 

"Doctors reported a wide range of symptoms, including fatigue, headaches, muscular pain, nerve damage, joint pain, ongoing respiratory problems and many more.

Around 60% of doctors told the BMA that post-acute Covid ill health has impacted on their ability to carry out day-to-day activities on a regular basis;

Almost one in five respondents (18%) reported that they were now unable to work due to their post-acute Covid ill-health;"

A safe work environment is a human right. 

Furthermore, the medical profession swears an oath to "do no harm" to patients.

Yet patients and medical professionals alike are being put at constant risk due to the lack of airborne precautions for a vascular disease which is now in constant, high circulation.

Please provide guidance that medical professionals should wear N95s at all times and in all patient-facing areas in order to protect themselves and their patients from viruses that transmit through the air. We wash and sanitize our hands to prevent infections and we need to start wearing N95s to prevent airborne infections.  

Please update ventilation systems in line with ASHRAE standard 241 for the prevention of airborne viruses. 

Please advise that HEPAs should be used in any areas where ASHRAE standard 241 is not in place.

Please recommend that CO2 monitors be present in all patient rooms, waiting rooms, surgeries, and technical rooms (such as xrays, MRIs, ultrasounds etc) so that the amount of CO2 in a room can be monitored and appropriate steps can be taken if it gets too high.  

Please properly educate physicians and surgeons about how it's now known that these viruses are transmitted through the air, how wearing an N95 is an important piece of personal protective equipment, and the reasons why it's important to take preventative measures.
Member of the public
[May 05, 2024 5:40 PM]
I am disappointed that comprehensive guidance on clean air management and the mandatory use of high-quality respirators in all patient-facing areas were not included, particularly in light of the COVID-19 pandemic.

These measures are necessary for creating a safe and resilient healthcare environment. By proactively addressing these critical components, healthcare facilities can bolster their defenses against airborne pathogens, safeguarding both patients and healthcare workers alike. Moving forward, it's imperative that we prioritize the integration of such crucial protocols to ensure robust infection prevention and control practices.
Member of the public
[May 05, 2024 4:23 PM]
In health care settings today, where we understand that asymptomatic spread of airborne viruses such as COVID are not only possible but frequent, two-way masking should be required at all times. Physicians in particular should be required to wear N95 respirators when interacting with patients, without being asked to do so. Those of us who are high risk or who are medically fragile - or those who are simply informed about the impacts of viruses like COVID and who want to protect their good health - are increasingly being put in a position where we have to convince health care professionals to take important precautions such as masking or having adequate clean air (via HEPA air purifiers or upgrades to mechanical ventilation) in clinical settings. Pleading with them, having to justify through references to scientific articles or other reputable sources why we are asking for these precautions to continue... it's extraordinarily punishing. There is a true lack of appreciation of how much of a burden this places on patients who continue to ask for masking and clean air. Sadly, there are also are many patients who would like physicians to take these precautions but are too timid to ask, for fear of being seen as a burden or as a trouble maker, or being seen as someone who is anxious or overly fearful. Simply having a policy in place where N95 masking by physicians was expected - or at least mirror masking (see someone in a mask, put on a N95) and ensuring that there is clean air in areas where patients may be present, would go a long way.
Member of the public
[May 05, 2024 3:57 PM]
I would like to see the following implemented:

- Masking of all patients, Physicians and staff (at all times)
- Hepa filtration in rooms
- Updated information regarding Covid displayed in the Physician's office/rooms. I see signs saying to wash your hands, but no mention of masking for an airborne disease.

We need to protect all patients. No patient should have to worry that they are going to be infected with a disease when they are looking for healthcare in healthcare settings.

These are simple things that can be implemented for everyone's health and safety.
Member of the public
[May 05, 2024 3:40 PM]
The use of HEPA filtration, air quality monitoring and, above all, high-quality masks (with N95 respirators) would make me infinitely more comfortable accessing health care.
Member of the public
[May 05, 2024 3:27 PM]
Please make respirators mandatory at all times in all physicians offices. The air must be cleaned in addition to surfaces. Thank you.
Member of the public
[May 05, 2024 2:50 PM]
The draft policy does not contain the words "mask", or better yet, "respirator", also nothing on "ventilation" nor "filtration". Five years into an airborne pandemic that has killed at least tens of thousands of Canadians, many of whom caught their illness in medical facilities such as doctors' offices, how is this responsible?

Requiring filtration and masking, not only in patient-facing areas, but everywhere is a minimum ask if physicians truly believe in "do no harm". Ventilation and UV-C disinfection are longer term goals.

If H5N1 evolves to transmit reliably between humans, which it may very well soon, a CPSO policy requiring masking, ventilation and filtration will presciently protect Ontarians from current and future airborne diseases.
Prefer not to say
[May 05, 2024 1:06 PM]
As the airborne COVID-19 pandemic continues, these proposed IPAC guidelines ignore the urgent necessity for universal respirator use and basic air filtration in healthcare settings. This is despite the overwhelming evidence of the efficacy of these interventions in preventing nosocomial SARS-CoV-2 infections. This ongoing failure of IPAC has led to an abandonment of the precautionary principle, has made it impossible for many vulnerable people to access healthcare, and continues to cause needless illness and death among those who do.
Member of the public
[May 05, 2024 10:33 AM]
Needs are;
Adequate ventilation.
• Air quality monitoring (CO2 monitors)
• HEPA filters
• universal masking (preferably respirator style N95 masks) or at minimum masking during periods of high transmission.
Member of the public
[May 05, 2024 9:08 AM]
Please consider making health care safe and accessible for everyone. The lack of airborne virus protections that is currently the norm is unsustainable and causing pressure on the healthcare system.

Airborne virus protections required in our currect era
- Measuring the air quality via hourly C02 measurement, installing HEPA filters, obligatory quality respirators for all HCW & ancillary staff within any hospital or HC setting. All visitors should also be obliged to wear quality a respirator. All hospital patients should be tested on entry & daily for infectious diseases & quarantined if positive.

Air quality & keeping C02 well below 800 at all times should be a priority. Covid19 is the third leading cause of preventable death in Canada. It can also cause injury and long term disability in anyone.

Protect your staff, but most importantly protect your all your patients from preventable illnesses.
Other health care professional (including retired)
[May 05, 2024 7:52 AM]
I wrote earlier about wearing a mask in providing care; this is a critically important equity issue, since many people who are most vulnerable to hospitalization and death from infectious diseases are older, disabled, BIPOC, or members of the LGBTQ2S+ community.

It is also critically important that primary care providers understand the risk of long COVID, particularly for women. Research is lagging in this condition, but the data are clear that women are more at risk. Please ensure members are informed about this risk so that they can communicate it to their patients, who can then make informed decisions about their actions.

It is also very important that primary care providers clean the air in the spaces where they offer care. This can be done by opening windows and doors, or with a HEPA filter, with MERV-13 filters on ventilation systems, with Corsi-Rosenthal boxes, or with equivalent kits made from PC fans (quiet and inexpensive) - https://aidankepo.wixsite.com/northboxsystems?fbclid=IwZXh0bgNhZW0CMTEAAR3v7RiORHA-889j8M2eHv7e9I_vwpKIR-nT6RQz7rZKnHUTP9VGOOosc9E_aem_AQQtLHjImma0GLoj7lrQj3f26-8aLFqo9t9dXDH6A0hIHaVy81itDGW1QycU_6TsryE60_pgGiwTw5B6oZX1XQyV.

Communicating the importance of clean air is an important aspect of physicians’ responsibility to advocate for public health in their communities. As such, measuring the CO2 in spaces where care is provided and sharing that information with patients is important. Many communities provide access to CO2 monitors through local public libraries; monitoring could be done using these free services in high patient load times to ensure that mitigation is sufficient. Alternatively, Aranet monitors are available from Canadian Tire for about $240, and could easily be shared among physicians or with other professionals, such as dentists.

Please encourage members to take these actions and to share their successes with their local and provincial public health authority.

Sincerely,

[Name redacted]
Member of the public
[May 05, 2024 6:24 AM]
4 years into the pandemic and it’s clear that the best tool we still have is masking. A proper N95 mask protects both the patients and medical staff. High quality air filtration is also needed.
Member of the public
[May 05, 2024 6:13 AM]
When sources like Public Health Agency of Canada urge us to ensure good ventilation and/or filtration to prevent "through the air" (WHO language), actually airborne disease, it is disappointing that you do not address providing a good indoor air quality in clinic through ventilation and filtration. A poorly ventilated clinic will spread infections no matter how well you wash hands and clean surfaces. Masking, especially with respirators, is also important for protection from infectious aerosols from talking, beathing, and coughing.
Member of the public
[May 04, 2024 9:50 PM]
Story time…

Once upon a time, a hundred and five years ago, a medical clinic and a lead smelter started operations near each other. Back in those days, workers at both sites accepted that their work might make them sick – either from disease due to inhaling airborne infectious aerosols in the then-current pandemic, or by poisoning in part from inhalation of aerosolized lead particles.

Both sets of workers face the same kind of challenge – inhalable airborne microscopic particles which cannot be seen or smelled, can float in air over distances and settle out on surfaces.

Jump, forward to the present, and improvements at the smelter mean the lead workers get sick so rarely that an occurrence makes the news, while after years of attention from medical bodies and infection control advisory committees, the employees at the clinic suffer sickness from working during a pandemic at pretty much the same rate as a century earlier.

The difference? The clinic follows infection control guidance as in the draft here. The smelter employs measures in regulations and advised by a wide range of experts – good ventilation, delineation of contaminated and clean areas, air quality monitoring, health surveillance, strict cleaning and decontamination protocols and range of personal protective equipment recognising the airborne hazard. For respirators, this means following national standard guidance using properly selected, fitted and maintained certified respirators. By the way, the same types of particle filtering respirators are effective against both hazards – it happens that the laws of physics which control filtration don’t care whether a particle is infectious or not.

Furthermore, repeating that the airborne nature of the hazards is very similar in both workplaces, we see that in the lead smelter, there is no “debate” about the need for effective respiratory protection against the hazardous aerosol. There is no vague instruction like “wear facial protection” for aerosol protection. There is no guidance proposing that workers assess for themselves the hazard through the workday like a “point of care” risk assessment. And there aren’t researchers undertaking randomized control trials like they did in this pandemic – the “gold standard” according to medical experts – where some workers wear effective respirators, some do not, to “prove” or disprove the need for respirators, with the decider being how many workers get poisoned.

So… how can the embarrassing difference health and safety measures and outcomes illustrated in this story be addressed?

Fortunately, we live in enlightened times, where there is no shame in admitting that you need help. The College of Physicians and Surgeons, PIDAC and other medical bodies shouldn’t be afraid to consult with the same types of professionals whose applied expertise has made such an improvement in health outcomes in smelters and many other workplaces. You may not need to apply every measure applied in a smelter, but I am sure the experts in ventilation, occupational hygiene, respirator technology and other relevant disciplines will be very understanding and more than willing to help out if you actually ask them.

Who knows, with the right will, the College can lead the way – and one day, the healthcare sector will have raised its standards to achieve the health and safety benefits already found in nearly every other workplace across the province.
Member of the public
[May 04, 2024 8:04 PM]
As someone who is immunocompromised, it is not safe for me to seek care, be it routine or urgent, when there are no masking policies in place. Universal masking is the bare minimum to prevent the spread of all respiratory diseases in medical settings. To ask an able-bodied person to mask for the sake of the health of the vulnerable is not a big deal. But to subject those same vulnerable people to the pathogens of other people will possibly kill or further disable them. The balance of power in having a disabled person have to ask a medical provider to mask places too much of a burden on the patient. Therefore, wearing masks should be a standard for healthcare going forward.
Physician (including retired)
[May 04, 2024 4:36 PM]
Please add guidance for airborne virus precautions.
Adequate ventilation
Air quality monitoring (CO2 monitors)
HEPA filters.
Universal masking with N95 style respirators at all times or at minimum during times of moderate to high transmission.
Prefer not to say
[May 04, 2024 3:00 PM]
I have read both documents and find them disappointing.  Ie the draft Infection Prevention and Control for Clinical Office Practice policy and draft Advice document

At a time when our biggest community health challenges and risks  are related to aerosol transmitted viruses (covid, rsv, flu, measles et )  — these guidelines are woefully inadequate to keep patients safe when they go to their doctor’s office.  

The reference to mask wearing in particular is inadequate.  Suggesting medical masks “when  required”— with no definition around what would indicate  this being required.  Regardless— Medical masks primarily  provide droplet rather than aerosol protection.  There is no reference to the use of N95 respirators.  Nor air quality and the use of hepa filter machines — regularly maintained with new filters as needed.  . 

Doctors and staff in doctors office should be aware of their need to be compliant with the Ontario Human Rights Code and wear masks (or respirators)  as an accommodation when needed for providing care to high risk patients.  Guidance for “mask mirroring” is important.  When a patient arrives wearing a mask or respirator — the doctor should be expected to do the same. 

Especially for high risk patients — CPSO needs to provide guidance on the necessity of continuing to provide the option for virtual video or phone appointments .    Because these office practice guidelines are so inadequate to prevent transmission of respiratory disease. Especially for high risk patients.  

Doctors should also be encouraged to organize their schedules so as to minimize disease transmission  risk.  For example— spacing appointment times to minimize the number of patients in the waiting room at any given time; isolating known infectious patients asap upon arrival at the doctor’s office; encouraging scheduling of patients to minimize disease transmission- eg patients with acute illness at the end of the day— separated from  annual checkup patients seen earlier in the day, for example. 

All Patients in Ontario need to be able to access medical care in a safe environment. There is a lot of work to be done on these guidelines to ensure that there is safe, accessible care for all Ontarions.  Including those of us who are high risk for communicable diseases. 

Although hand hygiene is important—I think it’s important to consider why in 2024 this remains such a big focus of the guidelines - rather than the prevention of serious aerosol transmitted diseases. These can be mitigated through guidelines that outline best practices for aerosol transmitted disease prevention. However, these draft guidelines don’t even begin to adequately address these issues of preventing aerosol  transmitted disease at doctors’ offices in any meaningful way.  

[Name redacted]
Toronto resident. 
Member of the public
[May 04, 2024 9:02 AM]
As many have commented, it seems important to move in the direction of air quality standards in any medical facility, and the required use of respirator masks in those settings. I'm sure that clean water standards seemed overwhelming and impossible at first and now we would settle for nothing less for disease prevention. Premium air quality and awareness of airborne transmission of disease in medical settings should be a universal.
Other health care professional (including retired)
[May 04, 2024 12:03 AM]
Hepa filters in all rooms/areas. Air quality monitoring. Masking in all areas by all staff and patients.
Member of the public
[May 03, 2024 9:42 PM]
Please provide safe healthcare by ensuring that patients have the right to request that their practitioners wear N95s, and ensure there is sufficient air changes per hour to reduce the transmission of airborne disease.
Member of the public
[May 03, 2024 7:14 PM]
Every single person deserves the best medical care whether in a doctor’s office, hospital, or other facility. We have the scientific evidence that COVID is airborne. We also have scientific evidence that N95s, HEPA filters, CO2 monitoring and ventilation can all be used against COVID (along with other things such as measles). In my family doctor’s practice (office tower setting) I have on each visit measured CO2 levels above 1800 which has been deemed an unacceptable level. There are no HEPAS and only 1 doctor in a N95. There are elderly people in the waiting room along with tiny infants, we MUST do better for them. The days of ‘sneeze into your sleeve’ are over. We need to immediately implement the tools we know work to keep both our most vulnerable and our medical workers healthy. One day you may be vulnerable too. If Japan can implement C02 readings into movie theatres and entertainment venues, the very least we can do is use these instruments in healthcare, schools, and work settings. A healthier society that masks and scrubs the air from pathogens is where our future lies.
Member of the public
[May 03, 2024 7:13 PM]
We need universal masking with N95 respirators. All clinics should use HEPA filters to clean the air. Virtual appointments should be available. If a patient asks you to wear a mask, please wear an N95
Member of the public
[May 03, 2024 5:47 PM]
I urge you to consider methods of improving air quality in hospital and HC settings. As a disabled person, I have to visit health care providers frequently, and the removal of masks in these settings exposes me to both COVID and other viruses. Encouraging not just mask, but respirator use, protects vulnerable patients and staff members. We now know that droplets are not the main transmission source for things like COVID, so we need to update precautions accordingly.
Member of the public
[May 03, 2024 5:10 PM]
Thank you for the opportunity to comment. I am a patient, I a parent to young children who I support through medical appointments when they are patients and I support my senior parents when they are patients attending appointments Doctor/health care offices. I am concerned that air quality and infection transmission through air is not adequately address interms of recommendations for best practices as an expectation and including appropriate education/training for all staff (doctors, nurses, support staff, maintenance/cleaning staff, patients etc) such as Air filtration (hepa filters) in waiting areas and exam rooms, ventillation standards, and masking (surgical masks are not appropriate for airborne infections; n95/respirator/kn95 information). Currently air quality in dr offices I have attended are not addressing air quality - this is a concern for all people accessing medical care and infection should be reduced using all the available tools so health care settings are not places where people catch additional infections. Please add this to the guidelines so patients are appropriately supported and health care settings better protect both the staff and the patients. People do not need to get sick more frequently and we do not want to deter people from going to Healthcare settings. Thank you.
Member of the public
[May 03, 2024 2:38 PM]
Please upgrade mask requirements to N95 at a minimum. Surgical masks are not as effective for preventing airborne viral transmission such as flu and Covid. N95 should be required of everyone in a medical setting of any kind, including patients and doctors but also nurses, admin, cleaning and other staff. There should be 100% universal masking in all spaces. Protect your patients and make healthcare safe for all to access. Also this will protect doctors, nurses and staff as well, cutting down on sick days and inter-office spread of illnesses. We aren’t on a post Covid world but even if we were this nonsense of questioning whether masks should be required in hospitals should be seen as ridiculous. Learn from the pandemic! Prepare for the next one. And make healthcare safer and more effective as a result. ALSO clean the air in waiting areas and offices and lunch areas where staff will need to unmask in order to eat. Use the technology we have! Put it to use. This should be obvious! Show us how smart you are by actually improving rather than degrading IPAC policies.
Member of the public
[May 03, 2024 1:20 PM]
Given that covid is an airborne disease that spreads asymptomatically or presymptomatically, relying on a physician's judgment call on whether the patient represents an airborne threat that necessitates the use of a respirator is simply not adequate. There need to be policies in place that reduce the risk of physicians' offices being a nexus of infection spread, as we adapt to the realities of an uncontrolled pandemic.

The default stance should be universal respirator use, with exceptions made for people who make major objections to it, rather than vice versa. If the consistent and universal use of respirators is too politicized to be implemented, then efforts need to be made to depoliticize it, at least in doctors' offices. In the meantime, there is a duty to offer harm reduction for patients who are put in the impossible position of needing to choose between seeking medical care and risk an(other) infection they cannot afford (whether physically or financially), or to delay medical treatment—perhaps indefinitely, if conditions do not improve. This means measures to improve air quality, like ventilation audits in every treatment room, carbon dioxide monitoring to ensure ventilation standards are met consistently, and air filtration and/or far-UVC devices appropriately calibrated to room size, to remove pathogens from the air between patients, so that patients can access spaces without contamination of persistent airborne pathogens from the previous patient.
Member of the public
[May 03, 2024 12:18 PM]
I am a resident of Ontario. I urge you to require medical spaces to have mandatory masking, hepa filtration and good ventilation. I ask that you require N95 or equivalent masking (medical/surgical masks are insufficient) for staff in order to facilitate safe patient care and a safe working environment.

At minimum around masking, please require 'mask mirroring' where if the health care provider sees a patient is wearing a mask, they too put on a mask (N95 or equivalent) without being asked.

I urge you to educate your profession on the current science: we know that COVID along with some other pathogens are airborne; the medical and science community have finally reached consensus on this point based on evidence; we know that COVID and other diseases can be asymptomatic; and we know from wastewater readings in Ontario that COVID and other pathogens are continuing to circulate.

I urge your organisation to be a leader in health. Thank you.
Physician (including retired)
[May 03, 2024 12:00 PM]
Note: Some content has been edited in accordance with our posting guidelines.
Response in PDF format:
IPAC for Clinical Office Practice_Physician Response_20240503.pdf
Member of the public
[May 03, 2024 10:07 AM]
Access to medical care should not be a risky endeavor. Indoor air quality needs to be monitored in facilities and CO2 levels should be monitored (ex. A doctor's office should never reach 3300, but I have been in my doctor's office and my CO2 reader showed numbers above 3000 the entire time). HEPA filters should be in each patient room as well as waiting rooms. Masking policies should be universal with all staff wearing well fitting respirators, and patients should be required to mask as well. Patients should feel as though seeking medical care will help them get better, not potentially make them worse because they have caught a cold/bug/flu (or covid even!) by going to the doctor.
Member of the public
[May 03, 2024 9:43 AM]
No one should have to risk getting sick or disabled while seeking medical care. Please bring back universal masking in all health settings. Covid-19 is airborne, as are many other viruses and can hang in the air for hours so simply having doctors/staff mask on request does very little to reduce the risk if the previous occupants of the room were unmasked and infectious. Improve filtration using HEPA filters and opening windows. Use technology to help - allow/encourage people to wait outside the facility in personal cars or in the open air if weather permits and use instant messages/online check ins to reduce the amount of time patients wait in unsafe crowded waiting rooms. Allow for more virtual appointments.
Member of the public
[May 03, 2024 7:35 AM]
Please consider making health care safer for everyone by measuring the air quality via hourly C02 measurement, HEPA filters, & as this is health care, obligatory quality respirators for all HCW & ancillary staff with any hospital or HC setting. All visitors should be equally obliged to wear quality a respirator. All hospital patients should be tested on entry & daily for infectious disease & quarantined if positive. Patients who are able to mask must. Others must be placed in protected areas. Air quality & keeping C02 well below 800 at all times should be a first priority. Covid19 & other virus can kill the vulnerable & can & do cause injury & ruin lives. Protect your staff (sometimes against their own ignorance) & most importantly protect your vulnerable patients.
Member of the public
[May 03, 2024 7:04 AM]
Give the scientific research, I strongly encourage the following:
*HEPA filtration
*adequate ventilation
*universal respirator masks
People who are at risk (ie: comorbidities
and repeat infections--a large section of the population) should be able to attend medical appts and have medical procedures in an medical environment where the risk of getting seriously sick from an airborne pathogen is better mitigated by implementing the above.
Member of the public
[May 03, 2024 7:00 AM]
It is past time to upgrade AQ in hospitals, clinics, offices, schools, etc. Covid is airborne.
Member of the public
[May 03, 2024 6:03 AM]
Covid is airborne. Medical spaces need to have mandatory masking, hepa filtration and good ventilation. Please promote.
Member of the public
[May 03, 2024 5:53 AM]
As a disabled person, I strongly encourage cpso to set standards around ensuring a clean and safe environment for patients by requiring doctors to wear respirators and have hepa or other forms of air filtration in each patient area. I further suggest implementing mitigations such as upper room uv or far uv. Visiting the doctors office should not be a potentially disabling event.
Physician (including retired)
[May 03, 2024 4:43 AM]
Please include the following precautions for protection against airborne viruses:
Masking (ideally respirator style masks).
Air quality monitoring in waiting rooms and exam rooms.
HEPA filtration.
Member of the public
[May 03, 2024 3:43 AM]
HEPA air filtration and proper ventilation Mandatory use of high quality respirators (not just surgical masks)
Other health care professional (including retired)
[May 02, 2024 10:57 PM]
Clean air / ventilation / CO2 monitor visible and KN95 comfortable options exist rather than surgical for airborne protection
Member of the public
[May 02, 2024 9:09 PM]
Physicians who wear respirators when treating patients are showing those patients that they value their health and life. As a patient in a high risk group it is difficult to ask a physician to mask to protect me due to the power imbalance, especially when I know that they already know my diagnoses and are choosing not to wear a mask around vulnerable patients. It is disheartening to feel so disposable to those who care for me and does not positively contribute to my well-being. I recognize that folks are still working through their own pandemic trauma and trying to put all mask use behind us is part of a larger societal trauma response. A simple policy to adopt at this point would be: if you see a mask, wear a mask. If your patient is wearing a mask, please also wear one to show them that you care about their health and well-being. It’s a small gesture that can mean the world to someone who feels otherwise abandoned and disposable.
Member of the public
[May 02, 2024 8:38 PM]
Things needed:
HEPA filtration
adequate ventilation
universal respirator masks

Unsafe healthcare isn't really healthcare at all
Member of the public
[May 02, 2024 8:16 PM]
Yes to make physicians, all healthcare workers, and patients wearing N95 respirators and running HEPA, and posting CO2 levels in congregate areas.
Member of the public
[May 02, 2024 8:11 PM]
Indoor air quality is crucial for patients and medical professionals. Masking should be more prevalent especially to protect those who cannot mask and those who are not in a position of power in healthcare settings.
Member of the public
[May 02, 2024 7:50 PM]
For patient safety, it should be mandatory for clinicians to wear respirators which offer superior protection from airborne pathogens. Medical masks are insufficient. Air filtration and monitoring should also be paramount using Hepa filters, outdoor air exchange and UV technology where available.
Member of the public
[May 02, 2024 7:42 PM]
N95s or at the very least a surgical mask would make sense in doctors' offices, since people are often ill and in close proximity to each other in the waiting room. HEPA filters should also be mandatory. It's May and I know of two people with COVID; one in his mid 40s and serious enough to need an ambulance. It hasn't disappeared, no matter how much we might wish it away or pretend it's gone.
Member of the public
[May 02, 2024 6:34 PM]
It is imperative that all healthcare providers be masked in all healthcare settings. And that the masking standard be N95s, not procedural masks. Anything less than this actively endangers clients and colleagues. The ‘gold standard’ for infection-safe healthcare remains online consultation. It is essential that online and phone-based appointments become the default format for most medical appointments.
Member of the public
[May 02, 2024 6:21 PM]
Everyone---staff and patients alike---should be required wear N-95 or KN-95 masks in all healthcare settings and they should be given out free. Due to non-masking at my doctor's office, I am now putting off going there because I am self-employed and cannot afford to get sick, and I certainly won't go to a hospital emergency dept. now that masks are not worn. Allowing healthcare facilities to make masking optional ignores the vast level of asymptomatic and pre-symptomatic spread of diseases like SARS-2. Making masks optional means that those who cannot afford to get sick face a different degree of access to medical care. Similarly, healthcare facilities should be required to have HEPA-standard filters and adequate ventilation. There are standards for refrigeration of medicines and all sorts of other practices; there should be standards for masking, air quality, and infection control.
Member of the public
[May 02, 2024 6:11 PM]
I am writing to ask that you include masking within the policy in order to facilitate safe and inclusive care. I would like to see mandatory masking for all health care providers. At a minimum, I would like to see the introduction of 'mask mirroring' where if the health care provider sees a patient is wearing a mask, they too put on a mask. As a parent to a medically vulnerable child, and caregiver for medically vulnerable parents, I understand how marginalized individuals are most impacted by COVID-19. Before Covid mitigations were eliminated, outbreaks were contained to a few people only. After mitigation were dropped, each outbreak infected nearly every patient. Consideration for the most vulnerable should be written into policy to make health care most accessible.
Member of the public
[May 02, 2024 4:53 PM]
Please include HEPA filtration, adequate ventilation, and universal use of respirator (N95 or equivalent) masks in the expectations for infection prevention and control practices in physicians’ offices.
Member of the public
[May 02, 2024 4:30 PM]
I urge the College to make standard the requirement for clean air—HEPA filters and appropriate ventilation. 

I urge the College to make standard the requirement for the use of respirators by all those who work in or visit physicians. 

This is essential to reduce the spread of airborne diseases—the ones we have circulating now, and the ones that are coming in future. 

Thank you,

[Name redacted]
Member of the public
[May 02, 2024 4:04 PM]
I am a retired statistician and have been reporting on covid scientific evidence and data since March 2020. Without going into the litany of peer-reviewed research and various supporting acknowledgements by WHO, the CDC, and PHAC, I wish to point out some important gaps that I see in the draft.

Observations:

1. Symptom screening is useful as a general practice but has limits to its effectiveness in the case of SARS-COV-2. (Yale Public Health cites 49% of covid transmission is asymptomatic.)
2. Hand hygiene is useful but again, in the case of SARS-COV-2 there is limited or no evidence that fomite transmission is a main vector. Instead, a large and compelling body of scientific evidence has identified airborne transmission as a main vector, something WHO has recently acknowledged. Aerosol particles can linger for hours in a high traffic, less ventilated, or less filtrated room. The airborne particles are not subject to arbitrary standards such as six feet proximity (which is not evidence based for SARS-COV-2).
3. Airborne risk is a particular issue for SARS-COV-2 in smaller volume rooms where there is some combination of higher risk from multiple patient encounters either sequentially or together, limited air exchange (ventilation), or no MERV/HEPA filtration. There is plenty of scientific evidence to support this as well as world class expertise in the engineering and aerosol sciences. I say sequential because infectious particles will last for hours even after previous visitors have left an unventilated/unfiltered room. If there is enough saturation, the next visitor can be infected.
4. Masking is logically a two-way mitigation since masks operate both for inbound and outbound air filtration (and any poor face fit leakage). If the infector (eg clinician) is unmasked in a clinical and intimate setting with a patient, then the risk level is elevated for the patient even if the patient is wearing a mask, since significantly more aerosols are generated in what WHO labels as "puff clouds" but the imperfect analogy I would use is cigarette smoke.
5. Certified respirator masks (eg N95) are designed to fit the face and prevent more leakage than a medical mask which has gaps on the side and is not designed to limit leakage. This has been demonstrated in experimental settings. Fit is improved further with head straps as opposed to ear loops. Certified N95 respirators provide superior fit than KN95's that typically use ear loops. A simple fit test can gauge fit and leakage but of course that is impossible with a medical mask. Cloth masks are not a serious masking option.
6. The prevalence of SARS-COV-2 is variable and is not fixed as "seasonal" at this stage. It can grow given waning immunity levels over time or new more evasive or infectious variants. Even today, I am looking at a return to growth in Ontario with JN.1* FLiRT variant developments. Any recommendations based on risk should acknowledge this variable environment.
7. Patient risk is not uniform across age or other demographics. The medical establishment's infection control baseline needs to recognize this. For example, the SARS-COV-2 test positivity is highest among older adults right now, partly because they are more likely to have been vaccinated but may not have been previously infected - ie, the cumulative immunity profile may be lesser than those with several past infections. I am sure you also have seen the data that the hospitalization and death risk of infected older adults and those who are immunocompromised is much higher as well. First time infections would therefore be an even higher risk. I believe you can find a recent BC study on this point.
8. The current vaccine Spring booster formulation (XBB.1.5) is expected to be less effective against current growing variants such as KP.2 based on recent laboratory analysis. This will further expose those most at risk of severe outcomes until vaccines "catch up".
9. The draft says "wearing a medical mask when required to prevent transmission of
infectious agents in droplets and airborne particles". The operative word here is "required". I do not sense that the draft makes clear when it is required and by whom. It does not clearly recognize a patient's or visitor's right to seek reasonable protection by requiring that the healthcare professional also wear a suitable mask. I suggest that it expand to make this clear and give patients, especially the most vulnerable, that right.

Recommendations:

1. Clearly acknowledge the preeminent importance of airborne precautions for SARS-COV-2.
2. Recommend CO2 monitors for clinical room settings to monitor airborne transmission risk and set a standard of 800 or less. CO2 is a very good proxy for infectious aerosol concentration. In fact a higher CO2 level also implies that viral particles will survive longer in the air based on a recent study.
3. Set standards for ventilation (air changes per hour, eg 6) and where not feasible in a room or to complement ventilation, set standards for air filtration using a portable HEPA filter with sufficient air exchange or an inexpensive corsi-rosenthal MERV filter box.
4. Set the preferred mask standard to N95 respirators or better and provide education on proper fit, as needed. (Failing to do so encourages aerosol transmission.)
5. Provide patients or visitors with the authority to require all health care professionals to wear masks when in the same room. This is imperative for older or more vulnerable patients. They have a stakeholder right to protect their health from infectious disease transmission, just as clinicians have a right to be protected from patient transmission.
6. If you are unwilling to fully consider or implement these recommendations at this time, I would suggest serious thought be put to adapting the policy with updates when SARS-COV-2 is higher (eg, tied to wastewater and outbreak data) and to complement that with a recognition that more vulnerable or older patients have the right to require proper masking in an encounter.
7. During times of higher prevalence, explicitly require masks of all visitors and staff eg reception and waiting areas.
8. Consider the removal of any outdated covid-19 posters, pamphlets, etc that wrongly emphasize hand-washing over airborne precautions such as masks and ventilation. Consider updating them with something more in tune with the latest science and revised WHO/CDC/PHAC guidance.

Much of what I have written will be applicable to various other infectious diseases. For this reply I have relied on my knowledge of hundreds of peer-reviewed SARS-COV-2 scientific articles over the past four years and my personal data analyses and tracking of covid-related data in Ontario and Canada.

Thank you for reaching out and seeking public input.

Regards,
[Name Redacted]
Medical student
[May 02, 2024 4:03 PM]
This draft guidance reads as if the Covid-19 pandemic never happened! Possibly this is due to its reliance on old PHO materials rather than development of new resources or reference to recent work by ASHRAE or the Ontario Society of Professional Engineers on the control of infectious airborne disease. We are now much more aware of the risks of aerosol transmission of viruses, sometimes asymptomaticly (and Covid is still around and causing damage), and IPAC guidance needs to reflect this awareness.

First, recognize that airborne transmission can happen between doctor/staff and patient and between patients; even patients who mask in the waiting room may infect each other when they unmask in an examination room if needed (and most surgical masks will not fit well enough to prevent airborne transmission anyway!). While not every disease is as infectious as measles, there is still plenty of evidence to show indirect airborne transmission for many other viruses. Unfortunately many medical offices are in old commercial or private buildings with inadequate ventilation and many are quite high risk venues for the presence and transmission of disease.

To address these risks the key is to avoid outdated all-or-nothing thinking like the requirement for respirator fit testing and specialized ventilation equipment, and avoid creating special categories for diseases like measles or TB. Instead, give advice on practical measures that can be implemented widely and reduce risk for a broader ranger of pathogens. For example, encourage use of respirators (which tend to fit better, even if not fit-tested) by patients and staff and the installation of portable HEPA filters in every waiting and examination room unless ventilation is known to be high (eg new built hospitals with high flow rates). Ditch outdated advice about elbow sneezing, back to back seating, and 2m spacing - better to have people wear good masks! Portable HEPA units are relatively inexpensive measures any practice can implement but given sticker shock like everyone doctors need a push in the right direction. Most of the dentists have done it, the doctors should too.

The consequence of doing nothing is that people will continue to be wary of seeing doctors (if they even have access to them) and unnecessary infections will continue.

Finally, clearly there are power imbalances at work that make patients reluctant to ask doctors to enforce better practices related to airborne illness, which is all the more reason for the college's advice to counteract these imbalances. On a personal note, I can't tell you how tired I am of bringing my own HEPA to a doctor's appointment and being treating like a crazy person for doing so, when measured CO2 levels clearly show poor ventilation and there is no changeover time between patients! The irony is that my doctor has token HEPA units in their waiting room - underpowered and often off - but staff wear loose surgical masks or nothing behind plexiglass (despite open tops) and there are no filters in the examination rooms. Doors to exam rooms and the office hallway were open to encourage airflow but there were no HEPA units! Irrational or inappropriate half measures should be avoided and clear advice from the college like "put a HEPA unit with appropriate clean air delivery rate in waiting rooms and in each examination room" with a simple table to calculate the target CADR (clean air delivery rate) would go a LONG way.
Member of the public
[May 02, 2024 3:22 PM]
I would like to request that health care facilities have a universal mask requirement, preferably with respirators (e.g., KN95 or N95 masks). Many infected persons are asymptomatic or are infectious before the appearance of symptoms. I would also like there to be an emphasis on air cleaning in health care facilities, such as through the use of HEPA filtration. The Ontario Society of Professional Engineers has a working group on indoor air quality and provided many helpful suggestions: https://ospe.on.ca/indoor-air-quality/.
Member of the public
[May 02, 2024 3:00 PM]
Hi. Thanks for taking public feedback. As an Ontarian who never fully recovered from a Covid infection, I think it is necessary for you add increased measures to prevent airborne spread of diseases. Air exchange, filtration, and other mitigations such as masking with proper respirators can help to make medical settings safer for everyone. The evidence is clear how airborne mitigations can prevent a number of diseases from spreading, not just Covid. Thank you for considering.
Member of the public
[May 02, 2024 2:30 PM]
Honestly, I think we need to see the inclusion of hepa filters, good ventilation and the use of N95's.

Those measures are proven to be effective mitigation measures. 

Please help us get out of this mess and set the example for others to follow.

[Name redacted]
Member of the public
[May 02, 2024 2:02 PM]
As a resident of Ontario, I’m writing to provide feedback on the draft policy, “Infection Prevention and Control for Clinical Office Practice.”  We know that tuberculosis, chicken pox, and measles are airborne—we know now, too, that COVID-19 is airborne. That the draft policy makes no mention of respirators or HEPA filtration is wildly disappointing. From the perspective of a parent with a young child who cannot reliably wear a respirator, accessing basic medical care presents a risk: we sit in a waiting room with coughing patients, we sit in an examination room with stagnant air, and we see a medical doctor in a poorly fitted surgical mask. A “clean and safe healthcare environment” means cleaning the air with HEPA filtration (each office should have HEPAs that provide a sufficient clean air delivery rate relative to the total office space). It means requiring that patients mask, and requiring that physicians mask in N95s. More succinctly, the policy must include specific airborne precautions to mitigate the spread of COVID-19. Thank you for the opportunity to provide feedback.
Member of the public
[May 02, 2024 1:52 PM]
We need to see measures to clean the air included in this document to help prevent the harms from the spread of airborne diseases and infections and pollutants, now and the future. This should include, but is not limited to - HEPA or equivalent air filtration - proper ventilation - required respirators masking at all times in all health care settings Other options such as UV light etc should also be further investigated.
Member of the public
[May 02, 2024 1:15 PM]
Patients need protection against the spread of airborne viruses. Musts: HEPA filtration, adequate ventilation and universal respirator masks Unsafe healthcare isn't really healthcare at all.
Member of the public
[May 02, 2024 1:00 PM]
Dear Doctors,

Keeping patients from contracting
disease in their Doc's office, with SARS-CoV-2 being most likely and deadliest, requires:
1. HEPA filtration
2. Adequate ventilation
3. Universal respirator masks

Please recall your microbiology undergrad courses and the more advanced learnings on epidemiology.

Airborne infection requires control at its vector of infection level.

Sincerely,
 
[Name redacted]
Medical student
[May 02, 2024 11:46 AM]
It was disappointing to see that there was no mention of airborne transmission or the ongoing COVID-19 pandemic.
We should be advocating for use of respirators, N95’s, and N99’s to reduce the transmission of airborne illnesses. The vulnerable people in our care deserve safety as much as others do; they are not disposable (and acting otherwise violates anti-discrimination. Laws in both Canada and ontario).

Both ignoring that airborne illnesses exist, and subjecting vulnerable individuals to airborne infections violates our oath to “do no harm”.

Wearing an N95 or N99 mask or respirator prevents transmission and therefore reduces the chances of a virus mutating into viruses we are not prepared to treat. Having masking be a routine practice would help to prevent or minimize the impacts of future pandemics- which we ought to consider as medical
Professionals.

We must do our due diligence and advocate for the prevention of COVID and other airborne viruses; please update the documentary immediately to ensure we are in alignment with our sworn oath.
Member of the public
[May 02, 2024 11:29 AM]
There should be standards for air cleaning to prevent transmission of airborne viruses. Similarly there should be heightened mask standards to have universal masking. At the very least, mask mirroring should be the norm.
Member of the public
[May 02, 2024 10:52 AM]
I understand that the College of Physicians and Surgeons is engaging in public consultation on their draft policy for the Infection Prevention and Control for Clinical Office Practice. I am writing to ask that you include masking within the policy in order to facilitate safe and inclusive care. I would like to see mandatory masking for all health care providers. At a minimum, I would like to see the introduction of 'mask mirroring' where if the health care provider sees a patient is wearing a mask, they too put on a mask. Consideration for the most vulnerable should be written into policy to make health care most accessible.
Other health care professional (including retired)
[May 02, 2024 10:19 AM]
Prevention is worth a pound of cure. Keep masks in healthcare, clean indoor air with HEPA filters & UV, and make infection prevention protocols a priority. Help reduce the burden on an already overwhelmed healthcare system by preventing the spread of respiratory illnesses such as RSV, SARS2, flu, etc.
Member of the public
[May 02, 2024 10:06 AM]
I notice it is mentioned "...wearing a medical mask when required to prevent transmission of infectious agents in droplets and airborne particles, and during aseptic and invasive procedures...". Can there be clarification that respirator (i.e. N95) should be used for airborne transmissions? This could help the reader better understand the tight fit nature of a mask required and to not use a surgical mask. Additionally, COVID-19 circulates throughout the year. Since are most vulnerable populations often need healthcare, it seems prudent follow the precautionary principle and consistently mitigate disease transmission; likewise, COVID-19 can be asymptomatic, so mask-wearing should be constant during healthcare operations.
Member of the public
[May 02, 2024 10:04 AM]
I appreciate that the policy includes "wearing a medical mask when required to prevent transmission of infectious agents in droplets and airborne particles, and during aseptic and invasive procedures". However, given that we are still in the midst of a global pandemic, it would seem that this should be a routine, daily practice, not a case-by-case decision. Routine masking provides a safer healthcare experience for both the clinicians and the patients. With regards to the policy on maintaining a clean and safe health care environment, cleaning the air with use of HEPA filters would provide a safer environment or both the clinicians and the patients.
Other health care professional (including retired)
[May 02, 2024 9:58 AM]
I have to echo the numerous comments here related to mandatory respirator use in healthcare settings. The ongoing Covid pandemic necessitates use of the precautionary principle. Given that this virus spreads primarily through airborne transmission, mitigation measures such as universal respirator use and improved ventilation are essential. Many physicians are not keeping up to date on the literature and would benefit from the CPSO instituting mandatory educational sessions with respect to the mechanisms of spread, the serious consequences of infection/re-infection, and effective mitigation practices.
Member of the public
[May 02, 2024 8:37 AM]
Everyone - staff and patients - should be required to be masked in all health care settings. Airborne transmission of infectious diseases that constantly mutate puts everyone at risk. Trying to identify some people as vulnerable, and declaring others not, is bad practice informed by a poor understanding of an ethical (and legal) obligation to "do no harm."
Member of the public
[May 02, 2024 6:42 AM]
My name is [redacted], I am a resident of Ontario. I understand that the College of Physicians and Surgeons is engaging in public consultation on their draft policy for the Infection Prevention and Control for Clinical Office Practice. I am writing to ask that you include masking within the policy in order to facilitate safe and inclusive care.

I would like to see mandatory masking for all health care providers. At a minimum, I would like to see the introduction of 'mask mirroring' where if the health care provider sees a patient is wearing a mask, they too put on a mask.

As a partner to a health care worker I understand how marginalized individuals are most impacted by COVID-19. I’ve witnessed outbreak after outbreak in their unit. Before Covid mitigations were eliminated, outbreaks were contained to a few people only. After mitigation were dropped, each outbreak infected nearly every patient. Consideration for the most vulnerable should be written into policy to make health care most accessible.
Member of the public
[May 02, 2024 6:15 AM]
Please add guidance to address airborne viral transmission (masking, hepa filtration, etc.). The Ontario College of Engineers has excellent guidance already avaable, based upon the expertise of hvac engineers, industrial hygienists, etc.
Member of the public
[May 02, 2024 6:12 AM]
Please add guidance for the mitigation of airborne diseases (covid, flu, etc).
Member of the public
[May 01, 2024 10:04 PM]
Where is any mention at all of COVID-19? Sweeping a pandemic under the rug is not a good look when your role is literally infection and disease prevention and control. Surgical masks are not good enough in any medical environment anymore. COVID-19 is not going anywhere and is not seasonal. It has been proven that N95s and elastomerics are the best protection for airborne viruses like COVID-19, TB, RSV and Influenza. Why is there no mention of cleaning and monitoring the air quality under cleaning/environment? Clean air with low CO2 will immediately bring airborne infections way down, thus decreasing the chance of serious HAIs. We have seen in Ontario so many hospital COVID-19 outbreaks it's ridiculous. Universal N95s would cut down infections by far. I don't get how an infectious disease prevention organization wants to continue doubling down on allowing COVID-19 to spread freely anywhere, never mind in medical environments.
Member of the public
[May 01, 2024 7:44 PM]
I am writing to ask that you include masking within the policy in order to facilitate safe and inclusive care. The burden of prevention of airborne diseases should not rest solely on the shoulders of patients seeking medical care. At minimum, I would like to see the introduction of 'mask mirroring' where if the health care provider sees a patient is wearing a mask. they too put on a mask without being asked. I hope that with the knowledge we have gained in the last 4 years, we can update policy that reflects what we know about airborne transmission.
Member of the public
[May 01, 2024 7:41 PM]
Please include high quality air filtration (HEPA) and masking - preferably respirators ie N95, KN95
Member of the public
[May 01, 2024 7:12 PM]
High quality respirators like N95s or better must be mandatory for all medical and dental professionals and support staff. Please bring them back and make it permanent.
Member of the public
[May 01, 2024 6:55 PM]
Mirror masking would help me feel more comfortable with the idea of bringing my child to the doctor's office for routine checkups. (Small children are not good at wearing tight-fitting masks themselves.) Air purifiers with regularly replaced filters would be very helpful too.
Other health care professional (including retired)
[May 01, 2024 5:07 PM]
I would appreciate if healthcare providers and their staff working in primary care would wear masks. Given that it is so hard to find a primary care provider and that many people who are higher risk for infectious diseases, protecting patients from infectious disease is a matter of equity. Additionally, these offices should have ventilation that meets the criteria of the new ASHRAE standard 241, prevention of infectious aerosols. Finally, primary care providers need to be properly informed about the risk of long COVID.
Member of the public
[May 01, 2024 4:48 PM]
Please please please return masking with high quality respirators (KN95 or better) to medical settings. Vulnerable and sick people deserve to access care safely.
Other health care professional (including retired)
[April 23, 2024 10:30 AM]
I am a retired Medical Laboratory Technologist (Clinical Genetics). I am providing my input to your draft policy for Infection Prevention and Control for Clinical Office Practice. I would very much like to see masking required by all Clinicians and patient-facing Staff. At the very least, ‘mirror-masking’ (where a health care provider dons a mask when a patient is wearing one) as a matter of policy would go a long way to provide inclusive and accessible health care to all who may be vulnerable to potentially serious infectious diseases such as COVID-19, RSV and influenza.
Member of the public
[April 23, 2024 9:46 AM]
My name is [redacted], I am a resident of Ontario. I understand that the College of Physicians and Surgeons is engaging in public consultation on their draft policy for the Infection Prevention and Control for Clinical Office Practice. I am writing to ask that you include masking within the policy in order to facilitate safe and inclusive care. At minimum, I would like to see the introduction of 'mask mirroring' where if the health care provider sees a patient is wearing a mask. they too put on a mask without being asked.

As a social worker I understand how marginalized individuals are most impacted by COVID-19. Consideration for the most vulnerable should be written into policy to make health care most accessible.
Physician (including retired)
[April 12, 2024 5:37 PM]
?Would it be beneficial to include a section to explicitly address the use of medically-approved equipment that is appropriately maintained and operated by appropriately trained personnel knowledgeable in proper use(for example, this may address equipment for sterilization equipment such as autoclave sterilizers).
Organization
[April 12, 2024 1:00 PM]
Occupational Health and Safety Branch, Ministry of Labour, Immigration, Training and Skills Development
 
Good afternoon,

I wish to provide some comments on the Infection prevention and Control for Clinical Office Practice Policy that is out for consultation.  For context, I work with the Fair, Safety and Healthy Workplaces Division within our Ministry focusing on the prevention of illness and injury of workers.

The draft policy on Infection Prevention and Control for Clinical Office Practice is a welcome addition, and it looks like it will serve to protect both patients and those working in clinical offices.  I do wish to highlight one particular element of this policy, which is in paragraph 8 regarding the duties of physicians in positions of leadership.
 
Footnote 8 clarifies that this term refers to those in an ownership, managerial or supervisory role in a clinic or practice, and footnote 9 refers to the Occupational Health and Safety Act (OHSA).  For greater clarity, I would like to highlight that the roles referenced in this Act are employer, supervisor, worker and owner among others with responsibilities for workplace health and safety (with employers having the largest set of responsibilities as they are in control of the workplace overall).  The Public Services Health and Safety Association published some guidance on the roles and responsibilities of physicians as mapped to these OHSA roles which you might find helpful in understanding OHS regulatory expectations: Public Services Health and Safety Association | Physicians' Occupational Health & Safety Roles and Responsibilities (pshsa.ca)
 
The Occupational Health and Safety Act sets out a number of general duties that employers, supervisors, workers and owners have (Part III: Duties of employers and other persons | Guide to the Occupational Health and Safety Act | ontario.ca).  In addition to this, depending on where the clinical office practice is located, other regulations such as the Health Care and Residential Facilities Regulation (O. Reg 67/93) and the X-Ray Safety Regulation (O. Reg 861) may also apply and have more specific requirements (such as written measures and procedures pertaining to worker health and safety that are reviewed on a periodic basis).  The Needle Safety Regulation (O. Reg 474/07) is broadly applicable to workplaces that require the use of a hollow-bore needle being used on a person. 
 
Both the policy and the explanatory material provided by the CPSO are helpful in providing a rationale and a set of expectations for physicians, but I just wanted to point out that while the OHSA is referenced in footnote 9, how the OHSA is applied may differ slightly from the expectations set out in paragraph 8, and it may be helpful to understand where and how they are aligned.  As is always the case, any workplace policy that meets and exceeds what the OHSA requires is always encouraged.  The MLITSD has ex-officio representation on PIDAC-IPC, and so PIDAC guidance does try to accurately include references to the OHSA where applicable.

I hope these comments are helpful.  Please feel free to contact me if you have any additional questions.