How to Comment On the OHA rules change – Deadline Tuesday 12/24/21 5pm

TO: Involved Citizen of Oregon

FROM: Bill Meyer

RE: getting an OHA comment in by Tuesday

 

“Mr. X” and I discussed today, Friday, how to properly comment on the OHA’s desired permanent mask mandate rule. Deadline is Tuesday, 5pm. Here is the notice originally sent out by OHA so you can see what they’ve said, and then there is our example of one way to respond. First, the original OHA notice.

 ________________________________________________________

Date: November 24, 2021

To: Interested Parties

From: Zintars Beldavs, Section Manager

Acute & Communicable Disease Prevention Section

Subject: Extension of Comment Period for OAR 333-019-0010 and 333-019-1005 –

“School and childcare exclusion, public health, safety requirements for childcare providers, youth programs “

 

The Oregon Health Authority, Public Health Division is extending the public comment period for the proposed rules noted below. The public comment period will close at 5:00 p.m. on December 14, 2021 in order to allow additional time for input from the public.

The Oregon Health Authority (OHA), Public Health Division, is proposing to permanently amend and adopt Oregon Administrative Rules in chapter 333, division 19 pertaining to school and childcare exclusion, and public health and safety requirements for childcare providers and youth programs related to COVID-19.

The two rules proposed for adoption and amendment concern:

  • Exclusion of susceptible staff, children and students from schools and children’s facilities, if they are exposed through close contact to an individual with COVID-19.

 

  • Public health and safety requirements for childcare providers and youth programs.

Temporary rules were adopted effective June 29, 2021 (Temporary Administrative Order PH 27-2021) and this proposed rulemaking seeks to make those changes permanent.

You are being invited to review and comment on the proposed rules.

The comment period for this rulemaking has been extended until 5:00 p.m. on December 14, 2021.

You may file written comments by sending them to the Public Health Division Rules Coordinator at the following address:

OHA, Public Health Division

Administrative Rules Coordinator

800 NE Oregon Street, Suite 930

E-mail comments to: publichealth.rules@dhsoha.state.or.us or you may also send comments by fax to: (971) 673-1299.  Final rules will be filed after consideration of all comments. 

PLEASE NOTE that we are not taking comments on school vaccine or mask requirements at this time. The hearing and comment period for those rules will be announced at a later date.

For more details, please see the Notice of Proposed Rulemaking, including the Statement of Need and Fiscal Impact and the full text of the proposed rules at the following website: www.healthoregon.org/diseasereporting .

If you have any questions or would prefer to be sent a hard copy of the Notice of Proposed Rulemaking, please send an email to publichealth.rules@dhsoha.state.or.us

___________________________________________

 Okay, that’s what OHA sent out. Here’s some suggested verbiage:

RE: extension of comment period for proposed rules-OAR 333-019-0010 and 333-019-1005 to December 14, 2021

OHA – Is there Justification for a permanent rule, based on data analysis of hospitalizations, deaths, and recovery rate of school aged children 0-19 from Jan. 21, 2020- November 28, 2021?

The statistical record doesn’t constitute conditions that would require making a permanent statewide rule, and that local control over adequate health responses would be best suited. Here’s the OHA and CDC stats:

According to OHA from Jan 21, 2020 to November 28, 2021

Total Cases Oregon Age 0 to 19 – 70,461 Cases (18.9% of Cases in Oregon)

Total Hospitalizations Age 0 to 19 – 606 Hospitalizations (0.86% of School Age Cases have needed hospitalization)

Total Deaths Age 0 to 19 Age – 5 Deaths (0.007% of School Age Cases have resulted in death)

Total Recoveries Age 0 to 19 Age – 99.993% of Cases have Recovered

https://www.oregon.gov/oha/covid19/Documents/DataReports/Weekly-Data-COVID-19-Report-2021-12-01-FINAL.pdf

According to CDC from Jan 21, 2020 to November 28, 2021

Total (Oregon) MIS-C Age 0 to 19 – 25 to 49 (Max 0.07% of Cases have been MIS-C) Multisystem inflammatory syndrome in children…” condition that appears to be linked to covid 19

https://covid.cdc.gov/covid-data-tracker/#mis-national-surveillance

For Reference Statistical Significance typically doesn’t come into effect until a percentage reaches 3 to 5%

https://www.indeed.com/career-advice/career-development/how-to-calculate-statistical-significance

 

FOR RECOMMENDATION FOR THE RULE TO BE PUT IN PLACE:

  1. Bullet point recommendations: The two rules proposed for adoption and amendment concern:

Page 2 of the proposed rule should read: (italicized wording replaced with bold print)

  • Potential exclusion of infected staff, children and students from schools and children facilities, if they are exposed through close contact to an individual with (COVID-19) with provable SARS-COV-2 infection.
  • Public health and safety requirements guidance for childcare providers and youth programs.

Additionally, there is potential misuse of the intended rule that would prevent equity and inclusion and would be potentially discriminatory. An equitable solution and mechanism should be in place for children who are NOT vaccinated and are at no risk, to return to school ASAP.

_____________________________________________

See what those two changes in italics accomplish? OHA wants to exclude staff, children and students if they are exposed to an individual “with Covid-19”. Given the high false positive characteristic of the PCR test, many people would be tossed out based on questionable testing. That’s why the replacement with “provable SARS-COV-2 infection” is needed.

Replacing “requirements” with GUIDANCE is another positive move.

Get busy, put as much of your comment in your words, and get them in by 5pm Tuesday 12/14/21.

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