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An Open Letter to OSHA Regarding the Pending Vaccinate-or-Test ETS

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Below is the open letter Wello’s CEO sent to OSHA regarding the pending vaccinate-or-test Emergency Temporary Standard (ETS) set to go into effect Monday, January 10. The ETS is being challenged in the U.S. Supreme Court, but no matter what the court decides, we think there is a better way to keep employees healthy and safe.

To access more details on a population health management program that is more effective and 96% less expensive than the current standard testing programs, download a copy of our guide here.

 

Attn: U.S. Department of Labor

Occupational Safety & Health Administration

200 Constitution Avenue, NW

Room Number N3626

Washington, D.C. 20210

 

Dear Assistant Secretary Parker, 

I write to you today as the President and CEO of Wello®. Our company has had just one mission for 10 years,  “to end the spread of contagious illness and set a new standard in employee health and safety.”

We screen an estimated 100,000 people per day—people who work in the fields of manufacturing, logistics, and healthcare. If you could summarize the people we serve in one phrase, they are “essential workers”.

In light of the issues posed with the OSHA “vaccinate-or-test” ETS, I would like OSHA to consider an alternate population health management program, which could be more effective in protecting worker health and safety, and at a lower cost and controversy. 

Issues with Vaccinate-or-Test

Dr. Michael Mina of Brigham Women’s Hospital and more recently eMed, has suggested that while rapid testing will make great strides in the workplace, rapid test companies cannot manufacture inventory fast enough, as evidenced by the difficulties many Americans have faced recently in trying to purchase at-home antigen tests. The uncertainty around the proposed ETS itself has made the demand for tests difficult to predict. Additionally, the cost of these tests effectively amounts to a $2,000 – $3,500 tax per unvaccinated employee per year, not including the time spent by employee and employer. Lastly, the measure does not address that vaccinated individuals, even if less so, also spread illness. 

In short, the program may do more to incentivize employers to mandate Covid-19 vaccines, but its efficacy in stopping spread in the workplace is questionable. This creates risky scenarios, where a specific workplace could have both low vaccination rates and high spread.

Another Way

Our population health management program could isolate more infectious individuals at a lower cost. It includes tracking vaccination and testing in a secure and private manner,  high-volume and fast health screening for onsite work, and selective testing only of potentially infectious individuals.

While Wello is aligned with your mission at OSHA and NIOSH, we focus strictly on stopping the spread of disease, and it is well-known how often Covid-19 outbreaks have been tied to the workplace. Even in the past two weeks, using the most rudimentary alert criteria, our product identified 227 out of 280,000 screens as likely contagious people and who are possible super-spreaders – evidence points to 2% of individuals being responsible for 90% of cases. We estimate the additional selective screening step will net possible Covid-19 super-spreaders by 5x. 

Our model shows that this selective testing program is even more effective at isolating infectious individuals at 10% of the cost of a standard weekly PCR testing program. Attached [click here to download] is more details about this program as well as an interactive model to show the cost and efficacy of commonly-used testing programs. We move quickly in general, so it is at your convenience that we would love to present. 

All of our products are manufactured in our facility here in Addison, Texas. Our welloStationX is the only self-service FDA Class II clinical thermometer device of its kind. Our work is the culmination of ten years, 14M+ scans, and millions in R&D. I hope OSHA can consider a more simple, flexible, and highly economic solution for businesses entrusted with the safety and health of their team.

Regards, 

 

Alan “Rik” Heller

President and CEO

Wello

https://welloinc.com

 

To learn more about our proposed population health management program with selective testing, click here. 


Additional Resources

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