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  • ACOEM Comments to HHS on Draft Guidance on Allocating and Targeting Pandemic Influenza Vaccine

    December 26, 2007
    U.S. Department of Health and Human Services
    200 Independence Avenue, S.W.,
    Room 434 E
    Washington, DC 20201 

    Attention: Pandemic Influenza Vaccine Prioritization Guidance Comments

    To Whom It May Concern:

    The American College of Occupational and Environmental Medicine (ACOEM) is writing to provide comments on the draft Guidance on Allocating and Targeting Pandemic Influenza Vaccine (Guidance)

    ACOEM recommends that the term "occupational health providers" be included in the document. Specifically, we recommend that the definition of the target group Outpatient and home health care providers include reference to "occupational health providers." Attached please find a suggested revision to the Guidance. 

    In the Guidance, target groups for pandemic vaccination are defined in four categories corresponding to major objectives of the pandemic vaccination program. One of the four categories is “Health Care and Community Support Services (HC/CSS).” 

    Within each category, groups are clustered into priority levels. Within each category, groups in Level A will receive vaccine first. Within the HC/CSS category, "Outpatient and home health care providers" are placed in Level A. 

    In prior discussions with agency officials, ACOEM has been advised that occupational health providers are included within the category Outpatient and home health care providers. However, the term "occupational health providers" is neither found in the Guidance nor included in the Appendix C, Table 2 where further definition of target groups is provided. 

    At the time of pandemic influenza, state and local officials should not have to interpret what is intended by the Guidance. To avoid any potential for confusion, we feel that it is very important that the Guidance specifically include, by definition, occupational health providers in Level A. 

    In a pandemic influenza, occupational health will be frontline health care providers. Worksite medical clinics, staffed by physicians and nurses, will be where workers may first present with symptoms. Vaccination programs in critical infrastructures will be overseen and conducted by occupational health providers. Mass vaccination programs may take place at workplaces, including hospitals and clinics, and be provided by occupational health providers - occupational physicians, occupational nurses and physician assistants. And, at the time of pandemic influenza, occupational health providers will be a critical resource to provide surge capacity to governmental public health. 

    Thank you for your consideration of these comments. lf you should have any questions or need additional information, please contact Patrick O'Connor, ACOEM's Director of Government Affairs, at 202/223-6222. 

    Sincerely, 
    Robert McLellan

    Robert K. Mclellan, MD, MPH, FACOEM
    President 

    On page 23, Table 2. Target groups in Health Care and Community Support Services 

    A Outpatient and home health care provider

    Includes two thirds of personnel identified by their organization at outpatient facilities, including but not limited to physicians' offices, occupational health centers and worksite clinics, dialysis centers, urgent care centers, and blood donation facilities; and skilled home health care personnel.

    Maintaining outpatient and home health care is critical to reducing pandemic mortality and morbidity and reducing the burden on inpatient services; outpatient health care burden will be markedly increased during a pandemic; personnel have high risk of exposure, possibly including to infectious aerosols; infected health care personnel may transmit infection to vulnerable persons receiving care for non-influenza illness.