Sunday 7 June 2020

Ontario needs legislation requiring an annual report to the legislature on PPE held in Ontario’s stockpile

These are the important facts.

In 2007   Ontario’s Ministry of Health and Long-Term Care (MOHLTC) developed a comprehensive, detailed Ontario Health Plan for an Influenza Pandemic (OHPIP).   This required that all  health care settings and providers  maintain a four-week stockpile of personal protective equipment and other critical supplies.  The province undertook to develop and maintain a four-week a stockpile of personal protective equipment for the entire health system; and a system for purchasing, storing and distributing supplies.  This would ensure business continuity for the first wave of the pandemic which was estimated to be approximately 8 weeks.

That plan was put into effect and communicated to hospitals and other stakeholders, including Toronto Public Health.  Further, in 2007 Ontario bought supplies for the stockpile.   A number of hospitals and Toronto public health also stockpiled supplies.  When H1N1 struck in 2009 supplies from Ontario’s stockpile were distributed. 

In 2013 Ontario Health Plan for an Influenza Pandemic was updated.  It still required that all  health care settings and providers  maintain a four-week stockpile of personal protective equipment and other critical supplies, and that the province would maintain a four-week a stockpile of personal protective equipment for the entire health system, to cover  the first 8 weeks of the pandemic.   Further, the plan is still in force and on Ontario’s web site.

In December, 2017  Ontario’s auditor general  reported  that  80 percent of Ontario's stockpile had expired, noting that  “The ministry informed us that its budget for these supplies only allowed for storage and not the management of them.”     The Auditor General recommended that the Provincial Emergency Management Office work with ministries to ensure that they plan for and enter into all relevant agreements and plans for any resources that may be needed during an emergency.

In December, 2019   the Auditor General for Ontario reported that it had conducted a follow up audit on its recommendations from 2017.   Sadly, the Ministry was aiming for March, 2021 to have plans in place to deal with goods and services that might be needed in an emergency.

Comments:
Manitoba, Newfoundland, Nova Scotia and PEI also had pandemic plans requiring stockpiles, which they also failed to keep up-to-date. 

On May 06, 2020 the Manitoba NDP introduced Bill 213, the Personal Protective Equipment Reporting Act. The bill would require the Manitoba government to table a report each year setting out the number of items of PPE purchased during the year and the number of items held in inventory at the end of the year.     See:   https://web2.gov.mb.ca/bills/42-2/pdf/b213.pdf
https://www.mbndp.ca/ppe_stockpile

I believe that it makes sense for Ontario to introduce a  bill requiring Public Health Ontario to report annually on the PPE held in Ontario’s stockpile, and to have a system in place to ensure that the stockpile does not contain expired goods.

Here is a first draft of the bill:

WHEREAS having stockpiles of personal protective equipment prevents shortages of that equipment when it is needed;

WHEREAS since 2007 Ontario has had a  detailed Ontario Health Plan for an Influenza Pandemic (OHPIP) which has required that all  health care settings and providers  maintain a four-week stockpile of personal protective equipment and other critical supplies, and the province undertook to develop and maintain a four-week a stockpile of personal protective equipment for the entire health system, to ensure continuity for the first wave of the pandemic which was estimated to be approximately 8 weeks;

WHEREAS the pandemic caused by the communicable disease known as COVID-19 has demonstrated the need for personal protective equipment to prevent and control infection and has demonstrated the failure of Public Health Ontario to maintain Ontario’s stockpile of personal protective equipment;

AND WHEREAS it is in the public interest that everyone in Ontario is aware of the inventory of personal protective equipment held by health authorities;

THEREFORE HER MAJESTY, by and with the advice and consent of the Legislative Assembly of Ontario, enacts as follows:

 1. For each calendar  year Public Health Ontario and  the minister must prepare a report that sets out, with respect to Ontario’s stockpile of personal protective equipment,
(A) the number of items of personal protective equipment that are purchased during the year;
(B) the number of items that are held in inventory at the end of the year.;
(C) the number of items distributed to the health system during that year;
(D) the number and locations of Ontario’s warehouses storing the stockpile;
(E) the number of items that were disposed of during the year because they had expired;
(F) the number of items in inventory that are within a year of their expiry date;
(G) a plan to distribute to the health system items that are within a year of their expiry date and a plan to replace those items in the stockpile;
(H)    a brief report on whether the supplies in inventory are sufficient to last four weeks in the event of a pandemic;
(I) the cost to acquire  personal protective equipment that are purchased during the year;
(J) the cost to warehouse the stockpile for the year.

2.  The report must include the number of items of the following types of personal protective equipment:
(a) surgical masks;
(b) filtration masks (N95 and higher filtration rate masks);
(c) protective gowns;
(d) face shields;
(e) eye protection;
(f) examination and sterile gloves;
(g) any other type of personal protective equipment, as prescribed by regulation under this Act.

3.  Within two months after the end of each calendar year, the minister must table a copy of the report in the Assembly and make it available to the public

3.  The Lieutenant Governor in Council may make regulations prescribing an item as a type of
personal protective equipment for the purpose of  clause 2(g).

4.  This Act comes into force on the day it receives royal assent.

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It is worth noting that many of the products in the stockpile, if properly managed, and distributed before they expire, do not cost a province that much more than the cost of storage.  This is because Ontario is going to spend the money to buy the products for the hospitals .  For example, the stockpile will contain a one month supply of surgical masks.  Hospitals in a Ontario go through a month’s supply of surgical masks each month.   Ontario will pay for the surgical masks  that the hospitals use whether they are shipped direct to the hospital, or are shipped from storage in the stockpile to the hospitals, and there is no additional cost other than storage, and cost for shipping once per year

Managing a stockpile to ensure that it does not contain expired goods is not rocket science, but does require planning and effort.  Chen et al. (2017) describe how Taiwan maintains a minimum stockpile for the surge demand of PPE in the early stage of a pandemic.  Taiwan  deals with expiration problems of the stockpiled goods by having the oldest stock in the central government stockpile regularly replaced and replenished with the same amount of new and qualified products, ensuring  availability and the maintenance of the stockpiles. Previously,  Taiwan had adopted a traditional way to stockpile PPE in central inventory, with large purchases and then storage until use.  To solve the issue of low consumption and having a mostly out-of-date PPE stockpile in the central health authority during non-epidemic periods, while maintaining the minimum stockpile,   Taiwan developed a replacement model for PPE stockpile management.

Christopher Brett
Perth and Ottawa, Ontario

Reference
Chen YJ, Chiang PJ, Cheng YH, Huang CW, Kao HY, Chang CK, Huang HM, Liu PY,
Wang JH, Chih YC, Chou SM, Yang CH, Chen CH, 2017
Stockpile Model of Personal Protective Equipment in Taiwan.
Health Security, 28 Feb 2017, 15(2):170-174. DOI: 10.1089/hs.2016.0103
https://europepmc.org/article/pmc/pmc5404251

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