National Academies release early draft framework for equitable COVID-19 vaccine allocation

The National Academies of Sciences, Engineering, and Medicine have released in draft form a report providing recommendations on how to prioritize access to a COVID-19 vaccine, once one is available. The National Academies are preparing the report, called a “consensus study,” at the request of the National Institutes of Health (NIH) and Centers for Disease Control and Prevention (CDC). The draft report is an initial step toward developing federal policy for vaccine distribution and is intended to inform policymakers. The draft report does not set federal policy, but does provide insight food companies may find valuable in planning their COVID-19 management strategies into 2021. The draft report is available for a brief, four-day public comment period, closing Friday, September 4.   

The draft report proposes a four-phase approach to allocating a vaccine, with food sector workers split between the second and third phases. The draft report is detailed and proposes four phases, generally including the following groups:

  • Phase 1 – High-risk healthcare workers; first responders; individuals with comorbidities and underlying conditions, and older adults in crowded housing;
  • Phase 2 – Critical infrastructure sector workers who are at substantially high risk of exposure; teachers and school staff; people with health conditions placing them at moderately high risk; older adults; individuals in shelters, group homes, and prisons;
  • Phase 3 – Young adults, children, other critical infrastructure sector workers; and
  • Phase 4 – Everyone else.

Importantly, the draft report differentiates between categories of critical infrastructure sector workers based on the perceived on-the-job exposure risk to workers. Within the food sector, the draft report differentiates between production workers in certain segments of the industry, who would be allocated vaccines in Phase 2, and production workers in other sectors and “white collar” workers, who would be included in Phase 3. Specifically, the draft report includes in Phase 2 “workers in the U.S. food supply system who plant, harvest and package crops; slaughter and process meat; deliver food to stores and stock shelves and staff checkout lines,” as well as “workers in warehouse and fulfillment centers.” However, restaurant workers and workers  “in factories or other goods producing facilities” are included in Phase 3. 

Food companies considering how the deployment of a COVID-19 vaccine may affect their operations and mitigation strategy may wish to review the report more closely and/or submit comments. 

Please don’t hesitate to contact us if we can be of assistance. 

 

Authored by Elizabeth Fawell and Brian D. Eyink. 

Contacts
Elizabeth Fawell
Partner
Washington, D.C.

Brian Eyink
Partner
Washington, D.C.

 

This website is operated by Hogan Lovells International LLP, whose registered office is at Atlantic House, Holborn Viaduct, London, EC1A 2FG. For further details of Hogan Lovells International LLP and the international legal practice that comprises Hogan Lovells International LLP, Hogan Lovells US LLP and their affiliated businesses ("Hogan Lovells"), please see our Legal Notices page. © 2022 Hogan Lovells.

Attorney advertising. Prior results do not guarantee a similar outcome.