Dr. David Williams
Chief Medical Officer of Health, Public Health
Ministry of Health
393 University Avenue, 21st Floor
Toronto, ON M5G 2M2
Dear Dr. Williams:
As you know, the number of COVID-19 cases in the City of Toronto continues to increase. Specifically, the 7 day moving average on Sept 1 was 40, on Sept 17 was 84, and on Sept 29 was 236 – an almost six-fold increase. Based on observations of case trends in other jurisdictions and several rapid changes in the COVID-19 case data, the City is at risk of experiencing exponential growth of COVID-19 infections in the immediate future.
I would like to commend you and your team for the ongoing collaborative efforts between the Province of Ontario and the City of Toronto throughout the COVID-19 pandemic. However, without quick action from the Province to implement further public health measures, there is a serious risk that the City will not be able to prevent the health and economic impact resulting from this surge, particularly with the imminent change in season. Based on the experiences of other jurisdictions, smaller scale policy changes will not be enough to stop virus transmission, and large-scale action is needed.
While testing has increased, on some days, the City has experienced higher daily case- counts than were experienced during the first wave of the pandemic (e.g. 381 cases on Sept 28 and 321 cases on Sept 29). As you know, the goal is to keep the reproductive number below 1.0. However, based on analysis by Toronto Public Health and the Province of Ontario, the reproductive number for Toronto is estimated to be between 1.2 and 1.4.
We have made the following critical observations:
We have been monitoring trends and effective public health measures in other comparable jurisdictions. The State of Victoria, Australia, which includes the Melbourne metropolitan area with a population size that is comparable to Toronto, implemented strict public health measures when daily case counts were lower than those currently occurring in Toronto:
After seven weeks of Stage 2, Victoria State had very few cases (7-day moving average of 28 cases/day, 0.6 cases per 100,000 population/day), as compared to jurisdictions where they implemented very few public health measures.
The situation in Toronto has transpired in spite of significant effort on the part of the Ministry of Health, the Province of Ontario and Toronto Public Health to enact legislation, bylaws, enforcement, case and contact management, as well as several strong recommendations to the public regarding how they can prevent virus spread. Therefore, I am writing you to indicate the need for further, immediate action.
As the Medical Officer of Health, it is my responsibility to identify health risks, such as the accelerated transmission of COVID-19; to identify actions to mitigate the risk; and, if I cannot take actions within my authority, as is the situation in this case, it is my duty to notify the appropriate parties of the risk to Toronto residents. Given the evidence I have reviewed, I am concerned if we do not act quickly to enhance public health measures, we will not adequately mitigate the immediate health risks to the public. To that end, I am recommending that you consider immediately implementing the following temporary public health measures in Toronto for a period of approximately one month:
I am requesting that you, as the Chief Medical Officer of Health for Ontario, use your legislative powers under the Health Protection and Promotion Act (HPPA) and the Provincial Emergency Order to enact these changes, or consider making the necessary legislative and/or regulatory changes to provide me as the Medical Officer of Health for the City of Toronto with the authority to take these actions. While I have some authority under Section 22 of the HPPA, I have received legal counsel that it would be unprecedented for a Medical Officer of Health to enact such broad changes, and such action may exceed my authority and therefore render me personally liable. I am therefore urging you to act in collaboration with the City of Toronto to implement these measures in as timely a fashion as possible.
As a part of my responsibility as the Medical Officer of Health for the City of Toronto, I have provided these recommendations to the Mayor of Toronto and the Chair of the Board of Health, in order for them to understand my concerns with the current trends in COVID-19 transmission in the City. For your consideration, I have attached to this letter some visual images of epidemiological analysis conducted by my team that reflect my concerns. I recognize that this is a challenging situation and I am available at your convenience to further discuss this request.
Dr. Eileen de Villa
Medical Officer of Health
City Manager, Chris Murray
Mayor John Tory
Chair of the Board of Health, Joe Cressy
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