# 2054
Since I was away at the ACHA convention for much of last week, I haven't have an opportunity to read and comment on the newly released proposed guidance on the use of Antivirals by the HHS until today. I covered the new facemask and respirator recommendations on Wednesday.
The two new guidance documents are called:
Proposed Guidance on Antiviral Drug Use during an Influenza Pandemic
and
Both of these documents were released last week, and the HHS is seeking public comment on these new recommendations through the first week of July.
While there is much to ponder in these new documents (and it will require more than one blog to cover), the most striking change is the recommendation that private sector employers consider stockpiling prophylactic antiviral medications, particularly if their employees will be at high risk of exposure.
That means Hospitals, EMS units, Fire Departments, and Law Enforcement Agencies, among others.
These new guidelines divide antiviral use into four categories.
- Overseas Containment
- Treatment
- Outbreak Prophylaxis
- PEP (Post Exposure Prophylaxis)
Outbreak Prophylaxis, as defined by these documents, would require up to 8 courses (80 pills) of Tamiflu per employee to cover a pandemic wave.
PEP (Post Exposure Prophylaxis) would require 1 course (10 pills).
The federal and state stockpiles, which currently fall short of the 81 million courses originally planned, are generally reserved for overseas containment (6 million courses), and treatment of infected patients (75 million courses).
Little or none of the state and federal stockpile is expected to be available for outbreak prophylaxis or PEP. Employers are put on notice that they cannot expect any of the federal stockpile to be allocated to them for protecting their employees.
"Despite expanding recommendations for antiviral drug use, there are no current plans for a commensurate expansion of public sector stockpiles, and employers will have to take the lead role for protection of their workforce if these recommendations are to be implemented."
While this guidance is quick to say "This guidance does not establish a requirement or expectation that all employers stockpile antiviral drugs.", it makes it pretty clear that certain classes of employers should stockpile prophylactic antivirals.
Quoting from the guidance again:
Antiviral strategies may be most useful for employers that have employees who will have frequent exposure to persons with pandemic illness, in critical infrastructure sectors, and those that have overseas locations and operations.
Outbreak prophylaxis of front-line healthcare and emergency services workers (fire, law enforcement, and emergency medical services [EMS]) is recommended because of their important role in providing critical healthcare services, preserving health and safety in communities, the lack of surge capacity in these sectors and the importance of reducing absenteeism when demands for services are likely to be increased.
There you have it in black (well, blue) and white.
- A strong recommendation that hospitals and emergency services provide 12 weeks of prophylactic antivirals to all employees who will have direct exposure to infected patients.
- Employees who are not routinely exposed to infected patients should be offered PEP (Post Exposure Prophylaxis) if they happen to come in contact with an infected patient.
And of course, all of this is on top of the requirements for PPE's, or personal protective equipment (masks, gowns, gloves) for HCW's (Health Care Workers).
The burden of protecting their employees has now been squarely laid on the shoulders of employers, particularly those in healthcare and critical infrastructure sectors.
There will be resistance to this idea, I'm sure.
Antivirals are expensive. They have a limited shelf life. Safe and secure storage of antivirals may be problematic. And there is always the possibility that antivirals could lose their effectiveness if a pandemic virus acquires resistance.
All true.
But none of these arguments are going to carry much weight if a pandemic breaks out, and employees discover that their health and safety have been secondary considerations.
If hospitals want nurses, doctors, and technicians to work, they'd better have adequate PPE's and prophylactic antivirals.
If EMS, fire, and police departments expect their first responders to respond, they'd better do the same.
The time for waffling, or making excuses, or simply saying that there is no guidance suggesting that employers stockpile antivirals - is over. Health Care Workers, and first responders, along with other critical infrastructure employees need to make it very clear to their employers that they expect to be protected.
And now, for the first time, they have some federally issued ammunition to use in their argument.
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