Dear Minister Kang:

We, the undersigned, are writing to raise significant concerns about the proposed plans for fall return-to-campus based on the most recent provincial guidance provided. Preventing Covid-19 infection among students, instructors, teaching assistants, research assistants, faculty, and administrative and operational staff should be paramount.

At present, the BC COVID-19 Return-to-Campus guidelines published on July 5, 2021 are not consistent with the best available evidence, do not follow the precautionary principle, and disregard key aspects of the Hierarchy of Controls that could prevent COVID-19 exposure and subsequent transmission in post-secondary environments. We are writing to request that BC publish new guidelines for post-secondary institutions that correct these deficiencies.

We specifically request that the Ministry immediately adopt the following guidelines:

1) Improve ventilation and establish provincial ventilation and HVAC standards;
2) Maintain enhanced cleaning protocols in all indoor settings and on high touch surfaces;
3) Mandate masks for classrooms and indoor settings;
4) Set occupancy limits for shared spaces and classrooms;
5) Maintain classroom configurations that enable minimum of two-metre physical distancing, which will likely require reducing class sizes in many cases; and,
6) Provide access to routine community and on-campus symptomatic and asymptomatic testing.

The Covid-19 Return-to-Campus Primer was issued by BC post-secondary institutions with the support of the Ministry of Advanced Education and Skills Training on April 30, 2021. The Covid-19 Return-to-Campus Guidelines were released on July 5, 2021. Both the April 30th and July 5th guidance issued by the Ministry of Advanced Education and post-secondary institutions, upon the advice of the Provincial Health Officer, make assumptions that are inaccurate. Our concerns are outlined as follows:

– COVID-19 is not like other seasonal ailments such as influenza: The July 5th guidelines state that “while elimination of the Covid-19 virus will not occur in the near future, we can certainly adapt to living with Covid-19 as we do with other manageable seasonal ailments such as influenza” (5).

While approved vaccines provide a high-degree of protection and prevention of severe illness and hospitalization, Covid-19 remains an unpredictable virus that can cause severe illness, hospitalization, death, and long-term illness and disability. The UK Office of National Statistics recently released data indicating that an estimated 962,000 people are experiencing “long COVID” (symptoms persisting for more than four weeks after acute infection), representing 1.5% of the UK population.[1] While comparable Canadian and BC data are not available as they are not collected, we remain concerned that allowing COVID-19 to spread within post-secondary populations could introduce a substantial long-term health burden on the province of BC. The April 30th guidance assumes that COVID-19 transmission will be low and that the virus can be managed in “the same manner as other common respiratory infections” (3). But the fact is, the consequences of COVID-19 infection (even with high rates of vaccination) far exceed other respiratory infections, in terms of direct mortality as well as unpredictable long-term effects.

– Failure to acknowledge aerosol transmission and implement measures to prevent aerosol transmission in indoor settings: The April 30th guidance states that “controlled environments such as post-secondary educational settings are lower-risk sites for COVID-19 transmission” (3). We ask: how are post-secondary educational settings “controlled environments?” High occupancy classrooms, hallways and other common spaces are uncontrolled environments with thousands of students each day using these spaces. We ask: lower-risk compared to what? There is now scientific consensus that aerosol transmission is the primary mode of COVID-19 transmission.[2] However, both the April 30th and July 5th guidance fails to acknowledge aerosol transmission and mandate measures across post-secondary institutions that can help prevent aerosol transmission within indoor settings, including the many classrooms that do not have windows and have poor ventilation. Since we now know that COVID-19 is airborne, transmission risks are reduced in well ventilated areas, in a physically distanced environment with occupancy limits, and with the use of face masks. There are no concrete commitments or plans for HVAC upgrades nor have we been made aware of provincial standards to improving ventilation – critical to preventing transmission of COVID-19.[3] In the absence of provincial ventilation and HVAC standards (as we’ve seen across Canada[4] and internationally), we are particularly alarmed that masks will be not be required in the classroom and that students will not be required to be vaccinated to enrol in in-person classes.

– Masks will not be required in the classroom or any indoor settings: Masks are an effective layer of protection against COVID-19.[5] Based on the July 5th guidance, there will be no infection prevention and control measures in the classroom beyond self-administered health checks and encouraging hand-washing and surface cleaning which does not address the dominant mode of COVID-19 transmission (aerosols). In the absence of a ventilation standard, and since many post-secondary institutions have older buildings without windows and poor ventilation, masks should continue to be required.

– Proof of full vaccination not required for enrolment in in-person courses: If proof of vaccination were mandated for return to campus, it would provide much greater certainty and reduce infection risk on campus. Many US post-secondary institutions are requiring proof of full vaccination for return to campus and Seneca College in Ontario has implemented a similar policy. Recent guidance from the BC Human Rights Commissioner indicates that: "that duty bearers can in some circumstances implement a vaccination status policy such as a proof-of-vaccination requirement—but only if other less intrusive means of preventing COVID-19 transmission are inadequate for the setting and if due consideration is given to the human rights of everyone involved." We have been told that requesting such proof is contrary to BC privacy laws and cannot be required, and this discrepancy in guidance is alarming. The lack of public health measures (e.g., masking, ventilation improvements, physical distancing, reduced class sizes) without any measurement of vaccination rates on campus is concerning and invites preventable risk.

– Transition from WorkSafeBC COVID-19 safety plans to communicable disease plans minimizes need for stringent occupational health and safety measures when highly transmissible variants continue to spread in BC: We are concerned that the shift to communicable disease plans, which do not require WorkSafeBC approval, minimizes the importance of occupational health and safety measures at a time when there remains significant risks of COVID-19 transmission and infection. The Delta variant, the most transmissible variant to date, continues to spread in BC. We are currently observing steep exponential growth in case numbers in other jurisdictions and countries with high vaccination rates (e.g., the Netherlands and the United Kingdom). There is no reason to expect the virus will behave differently in BC.

This represents a particular concern in the absence of proof of vaccination and robust public health measures. A return to “regular pre-COVID-19 cleaning protocols,” as Stage 4 of the Post-Secondary BC Restart Plans outlines, will result in increased risk of exposure to COVID-19 and other communicable diseases. Until COVID-19 is no longer prevalent in communities, control measures must be implemented to minimize the risk. When considering how to reduce the risk, the hierarchy of controls must be followed in the correct order, from the most effective to the least effective. The most effective being elimination to substitution, engineering controls, administrative controls, and PPE. Without adequate protective measures in place, even if a large percentage of the community is fully vaccinated, there remains a high risk of infection and the likelihood of large outbreaks at post-secondary institutions that will spread into the wider community.

While it is our expectation that all post-secondary students, staff, and faculty in BC will have had the opportunity to be fully vaccinated by September return, we know from the experience in BC with breakthrough infections and internationally that the best approach includes high levels of vaccine protection along with continued non-pharmaceutical interventions (NPIs) such as indoor masking, physical distancing, and unrestricted easy access to testing – including testing for individuals without symptoms.

Adopting the precautionary principle also means ensuring that equity is at the core of our return to campus. For students, staff, and faculty who live with chronic conditions and may be immune-compromised (or live with family members who are), we must do the best to mitigate risks associated with the return to campus and implement measures that prevent infection.

In particular, we draw your attention to US CDC guidance for post-secondary institutions which recommends the continuation of prevention strategies including consistent mask use, physical distancing, contact tracing, testing, and increased ventilation in settings with mixed populations of both people who are fully vaccinated and who are not fully vaccinated.[6] In settings where everyone is fully vaccinated (and proof of vaccination is required), there is much more room for NPIs to be safely discontinued.

In conclusion, we ask that the Ministry reconsider and strengthen its July 5th guidance, and ensure that guidance is consistent with the best-available evidence and adopts the precautionary principle and the Hierarchy of Controls when it comes to COVID-19 infection prevention and control.

We, the undersigned, call on the Ministry and post-secondary institutions to develop standardized, province-wide standards for ventilation/HVAC; maintain enhanced cleaning protocols in all indoor settings and on high touch surfaces; mandatory indoor masking; and physical distancing through reduced class sizes; and, provide access to routine community and on-campus symptomatic and asymptomatic testing. There are numerous jurisdictions to draw upon for best practices in these areas.

We would request a meeting as well as a written response to this letter.

Sincerely,

[Your signature]

Teaching Support Staff Union (SFU)
CUPE 3338 Executive Committee (SFU)
Simon Fraser Student Society Executive Committee (SFU)
University of Victoria Faculty Association Executive Committee (UVic)
CUPE 4163 Executive Committee (UVic)
CUPE 2278 Executive Committee (UBC/UNBC)
Graduate Student Society Executive Committee (SFU)
BCGEU Executive Committee
BC Union Workers’ Union Executive Committee

cc:
Shannon Baskerville, Deputy Minister, Ministry of Advanced Education
Bonnie Henry, Provincial Health Officer, Ministry of Health
Hon. Adrian Dix, Minister of Health
Stephen Brown, Deputy Minister, Ministry of Health
Reka Gustafson, Deputy Provincial Health Officer and PHSA Vice-President
Joy Johnson, SFU President
Santa J. Ono, UBC President
Geoff Payne, UNBC President
Kevin Hall, UVic President

[1] Office of National Statistics, Prevalence of ongoing symptoms following coronavirus (COVID-19) infection in the UK: 1 July 2021.
[2] Greenhalgh T, Jimenez JL, Prather KA, et al. Ten scientific reasons in support of airborne transmission of SARS-CoV-2. The Lancet 2021;397(10285):1603-05; Morawska L, Milton DK. It is time to address airborne transmission of coronavirus disease 2019 (COVID-19). Clinical Infectious Diseases 2020;71(9):2311-13; Tang JW, Bahnfleth WP, Bluyssen PM, et al. Dismantling myths on the airborne transmission of severe acute respiratory syndrome coronavirus (SARS-CoV-2). Journal of Hospital Infection 2021;110:89-96; Bourouiba L. The fluid dynamics of disease transmission. Annual Review of Fluid Mechanics 2021;53:473-508; Stadnytskyi V, Anfinrud P, Bax A. Breathing, speaking, coughing or sneezing: What drives transmission of SARS-CoV-2? J Intern Med 2021 doi: 10.1111/joim.13326 [published Online First: 2021/06/10].
[3] Morawska L, Allen J, Bahnfleth W, et al. A paradigm shift to combat indoor respiratory infection. Science2021;372(6543):689-91. doi: 10.1126/science.abg2025.
[4] For example, the University of Toronto and Western University are making HVAC upgrades. To our understanding, no comprehensive assessment of ventilation systems and improvements in BC PSIs have been shared with stakeholders or made public.
[5] Czypionka T, Greenhalgh T, Bassler D, et al. Masks and face coverings for preventing the spread of Covid-19: a narrative review. Annals of Internal Medicine 2020:doi.org/10.7326/M20-6625.
[6] US CDC, Guidance for Institutions of Higher Education, updated June 4, 2021.