TO: Department of Health and Human Services
Maine Emergency Medical Services
Maine Emergency Medical Services Board
Maine Fire Chiefs’ Association
Governor Janet Mills
FR: York County Chiefs’ Association (YCCA)
RE: YCCA Position Regarding Mandatory COVID Vaccinations
The York County Chiefs’ Association (YCCA) represents Fire and Emergency Medical Services in York County. YCCA has built lasting relationships with York County Emergency Management, District 1 Chiefs of Police, Dispatch Center Leadership, and other specialized teams that have been battling COVID-19 on the frontlines. YCEMA Incident Management Team collaboratively provides first responder, community, and school-based immunization programs to reduce the impact of COVID-19 in the 29 towns that make up York County. The collaborative has been praised by the Maine CDC and other organizations for the rapid, safe, and coordinated immunization plan built by this multi-jurisdictional group of professionals working for the common good.
The recently imposed State of Maine Immunization Requirements for Healthcare Workers Emergency Routine Technical Rule change date August 12, 2021 was shocking for many service chiefs, city/town managers, organizational leadership, and the workforce of EMS clinicians actively working every day in York County. YCCA Executive Board/Board of Directors emphasizes the need for all EMS Providers in the county to become vaccinated against COVID-19 to protect themselves, their service, their patients, and family; however, a requirement with a short window of compliance is putting undue stress on organizations that are already dealing with declining numbers of volunteers and the lack of qualified candidates for full and part-time fire-rescue positions countywide. For years, YCCA leadership has worked with the Community College System, namely Southern Maine Community College to positively impact our long-term workforce of firefighters and paramedics. YCCA questions the impact to those programs and our labor pool if other Northeast States do not follow Maine’s lead on vaccination mandates; instead of working in Maine they may choose to work in another state without strict mandates requiring vaccination against COVID-19, prior to an approved vaccine being available.
The YCCA would like the Department of Health and Human Services, Maine Centers for Disease Control and Prevention, Maine EMS, and the Maine EMS Board to consider the following points/requests:
- We would appreciate an extension of the deadline to determine the unvaccinated population of Fire-EMS employees, to provide guidance and encouragement for those employees to become vaccinated, and to vaccinate that population with existing processes made possible through the York County Incident Management Team and York County Emergency Management Agencies Vaccination Teams. Additional time would also allow for clarification of the applicable rules so our public safety system can move forward cooperatively and efficiently and address the unvaccinated population of Fire-EMS employees.
- As written, the rule permitting a medical exemption does not reduce the spread of COVID in the workplace. While the YCCA fully supports vaccination as the best option, when a medical professional determines receipt of the COVID primary vaccination series, or a booster, is medically inadvisable, then a safer workplace would be achieved if the medically exempt employee were required to mask and submit to regular testing.
- We request clarification of the definition of an employee in the Emergency Rule. While intended to address EMS staffing that provides patient care within our organizations, an independent contractor could include a vendor servicing a fire truck or ambulance, repairing stretchers or cardiac monitors, or maintaining our facilities. We have not, previously, been requested or required to track immunization status or medical exemptions of all who enter the building.
- Given that COVID boosters are imminent, the YCCA asks that the language in this Emergency Rule be broadened to include future requirements pertaining to boosters/proof of immunity, and the associated reporting requirements.
- We ask that the reporting requirements with respect to any of the required immunizations be clarified to include when, and if, serological proof of immunity is applicable for any of the required vaccinations, or in lieu of receiving a booster.
As written, the current Emergency Rule stands to negatively impact the public by reducing the amount of Emergency Medical Dispatchers providing lifesaving pre-arrival instructions to 911 callers, Emergency Medical Technicians/Paramedics responding in cities and rural parts of our county, and firefighters responding to fires in our communities. Although YCCA firmly supports vaccination of our employees and volunteers, we firmly oppose a mandatory rule change directed from the top of state government prior to receiving input from Chiefs of Service who are expected to provide dispatch, EMS, and fire response to a county of 200,000 residents. YCCA has been a part of the solution since the early days of the COVID-19 Pandemic and intends to remain a cooperative team player in our state.