ACOEM Comments on Preliminary Framework for Equitable Allocation of COVID-19 Vaccine

September 4, 2020
National Academies of Sciences, Engineering, and Medicine 
500 Fifth St., N.W.
Washington, D.C. 20001
Re: Preliminary Framework for Equitable Allocation of COVID-19 Vaccine
To Whom It May Concern:
The American College of Occupational and Environmental Medicine (ACOEM) would like to thank the National Academies for the opportunity to comment on the Preliminary Framework for Equitable Allocation of COVID-19 Vaccine. The framework represents important work at a critical time in our nation’s pandemic response. 
ACOEM is a national medical society representing 4,000 occupational medicine physicians and other health care professionals devoted to promoting optimal health and safety of workers, workplaces, and environments.  The College is dedicated to improving the care and well-being of workers through science and the sharing of knowledge.
We find the proposed plan to be thoughtful, incorporating important ethical principles. Our comments are limited to the elements of the prioritization plan that are based upon occupation.

We endorse the intention to vaccinate occupational groups in phases based upon their role in maintaining health care and other essential services while also considering their risk of occupationally acquired infection.
We support the inclusion of health care personnel and emergency responders in Phases 1a and 1b as outlined in the proposed plan, with those at greater risk of infection due to direct patient contact comprising Phase 1a.
We note the number of workers in Phase 2 is large and the group represents a spectrum of occupational risk. If vaccine supply is inadequate to implement vaccination to all groups in Phase 2, we advocate for consideration of occupational groups who are not only critical workers but are at increased occupational risk due to the nature of the work or working conditions which require that they be in close proximity to others. This would be similar to the distinction between Phases 1a and 1b. Given ACOEM's knowledge of workers and working conditions, we would be willing to assist in prioritizing those non-HCW workers included in Phase 2 if that were necessary.
Clear, concise educational outreach will be needed both to the general public and to targeted occupational groups so that workers can recognize their eligibility for vaccination during the appropriate phase and self-identify by occupational criteria at vaccination sites.

While health care employers and some large non-healthcare sector employers will be able to administer vaccine to designated occupational groups among their own employees, we anticipate challenges for non-employer-based vaccination sites to identify and verify occupation. Currently, occupation is not uniformly captured in medical records. Vaccine sites will need guidance for responding to individuals who self-identify as part of an occupational priority group. Many at-risk workers in this group lack “proof” of occupation, and we would advocate for vaccinating those who self-identify as an occupational priority group.

At this time, we are unprepared to comment on allocation priorities among other groups of workers not outlined in the current plan.

Thank you for your consideration of these comments.