TO: JEREMY MILES MP, Minister for Education and the Welsh Language, Jeremy.Miles@senedd.wales
CC: SALLY HOLLAND, The Children’s Commissioner for Wales, firstname.lastname@example.org, ELUNED MORGAN MS, Minister for Health and Social Services, Eluned.Morgan@senedd.wales
17 May 2021
We are a group of parents who have come together because of our concern about aspects of policy making on children and young people in Wales during the Covid-19 pandemic.
- UsforThem has profound concerns about the impact that mask-wearing for the length of the school day as well as for travel to and from schools (so up to 8-9 hours per day in many cases) has upon children and young people. We consider that the introduction of this policy is potentially very damaging to the health and welfare of children as well as being deleterious to their education.
We have seen no adequate evidence base to justify its implementation at this stage of the pandemic.
This recommendation does not seem to be based on any scientific evidence, fails to recognise the new realities of us having offered the vaccine to the most vulnerable groups, appears to have been introduced without evaluation of potential harms.
For the reasons set out below, UsforThem Cymru considers that the introduction of this policy is irrational, fails to take account of material considerations and is disproportionate. Essentially, it fails to put the best interests of children as a consideration, most certainly not a primary one.
- UsforThem Cymru recognises that the Welsh Government stated that the wearing of masks in lessons shall be kept under constant review, but the nature and extent of that review is not clear. It is particularly unclear as to whether the voices of the many people concerned about the wearing of masks over the course of a whole school day and the scientific, academic and other evidence which supports this, will be presented in a fair and balanced manner.
- To date, no evidence has been published (or referred to) to explain this fundamental change in position on face coverings. Previous statements stated that mask-wearing in classrooms was “not recommended”.
- The Minister for Education must make policy decisions (of which this is one) on the basis of taking into account all relevant considerations and weighing the risk/benefit of them carefully on the basis of all the evidence.
- When making any decision concerning children and young people, the best interests of children shall be a primary consideration.
- The decision-making, in this case, fails to consider at all the significant disadvantages to children and young people’s health and wellbeing of largely continuous mask wearing for 6-8 hours per day. There is an absence of compelling or indeed any evidence that the diminution of the rate of transmission (if any) by the wearing of such masks in a school setting outweighs the harm to children and young people of implementing this policy.
- Whilst children are susceptible to Covid, they are rarely severely unwell with it. The evidence summary suggests that the Covid 19 data shows rates of infection in children have been declining as have those of adults.
- There is no strong evidence to suggest that schools and colleges play a role in driving large scale transmission in Wales. To date, the studies identified that changes in infection rates amongst children follow changes in adults and reflect those of the local community. The role played by transmission within schools versus that in the wider community is said to be both uncertain and difficult to quantify.
- The only information provided about face coverings is based on adult populations and indicates that they may have a small impact upon population level transmission, with the benefit being difficult to quantify. Further, none of the studies it is derived from are related to the use of face coverings in children or in educational settings so any benefit of children wearing them appears to be effectively unknown. Any consideration of evidence has to be seen in the context of the lower levels of infection amongst children. Any risk mitigation by the wearing of masks by young people is likely to be negligible.
- Upon the return to school, there has been the implementation of regular lateral flow testing for staff and students. This has not, to date, demonstrated significant concern about the rates of transmissions in schools that have been articulated, published, or referred to by the Welsh Government.
- Moreover, as of today’s date (17 May 2021), more than 2 million people have had their first vaccine dose and over 900,000 have had a second. 1,489,754 million of those aged 55 and above (including clinically extremely vulnerable aged 16-69 and clinical risk groups aged 16-64) have had at least one dose of the vaccine. These are the people most at risk of serious ill health. There have been significant drops in both hospital admissions and deaths for the ages groups who have been vaccinated. The rate of transmission has not, to date, shown signs of significant increase as a result of the return of children to school from the information released by the government.
- There is nothing in the guidance that references potential harms and nor are the studies showing the harms of mask wearing referred to in this. Indeed, the potential for this intervention to cause harm is not mentioned at all.
- There are numerous examples from history where non-pharmaceutical interventions have caused significant harm. Serious questions of children’s health and welfare are involved. Proper consideration of all the available evidence and potential harms is essential.
- There is significant evidence of harms of wearing masks throughout the day. The studies referenced therein – many peer reviewed – include problems physical ill health – such as respiratory and heart problems, skin problems and eye problems – and also mental ill health – such as problems with communication, concentration and impaired learning.
Most of these papers are based on adults, but data collected as per WHO guidance on the effects of children wearing face-masks suggest children who have been asked to wear masks in lessons in other countries have experienced a range of harmful effects. A German registry of 25,000 children wearing a face mask for an average of 240 minutes per day found that two-thirds of them experienced impairments including irritability, headaches, difficulty concentrating and impaired learning. This is profoundly concerning.
- The wearing of masks also has a very negative impact on communication, connection, and engagement in conversation. This involves both those with hearing loss and other sensory impairments who cannot access effective education if masks are worn, but more generally it can impact all children. Masks significantly impair the quality of communication in the classroom and reduce the effectiveness of learning. Given how much education this cohort of children has already missed, this is heaping further unfairness on these children.
- We have received multiple reports of children with symptoms including headaches, nausea, fatigue, irritability, skin complaints. There should have been accompanying research and data collation to provide an evidence base for its continued justification. The absence of any such transparent evidence or information makes it impossible for the Welsh Government to adequately identify if such measures are necessary or proportionate.
The decision to recommend face mask wearing was irrational and has not been explained in the light of the Welsh Government’s previous policy positions.
The Department for Education in England recently stated that: “Given the negative impact that face coverings have on teaching, learning and wellbeing and current epidemiological information, their use in classrooms or by pupils and students in communal areas is not recommended at the current time.”
THE DETAILS OF THE ACTION THAT THE MINISTER FOR EDUCATION AND THE WELSH LANGUAGE IS EXPECTED TO TAKE:
The action we ask the Minister for Education to take:
- To withdraw the guidance re face coverings.
- In the alternative, to issue fresh guidance which confirms that pupils do not have to wear masks in the classroom.
- If the guidance is not to be withdrawn, to undertake adequate data collection and scientific analysis of the impact of mask wearing on young people’s learning, physical and mental wellbeing and to publish such as soon as possible. This should then be used to evaluate the policy as soon as is possible. Given the serious nature of the issues in question, and that the health and welfare of children are at stake, it is imperative we are satisfied such data collection and analysis is independent.
The details of any information sought:
We ask for the following information to be provided. The Minister for Education has a duty of candour, which involves the full and fair disclosure of relevant material.
- All scientific advice before the Minister and/or the First Minister of Wales when they took the decision to recommend mask wearing in the classrooms.
- Any risk assessment and/or assessment of the risk to the health of children and young people of the implementation of this policy.
- Any impact assessment made or drafted as to the implementation of this policy.
- Confirmation of who will be reviewing this policy, the basis upon which it will be reviewed and the nature of that review – and when it will be published?
Proposed reply date:
In the light of the continuing lack of clarity as to the long-term future of this policy, we require a response as soon as possible and by the 28 May 2021 at the latest. There must be further clarity as to the policy prior to the start of the Summer Term in June 2021.
We very much hope that this matter can be resolved without needing to issue any further proceedings. We would welcome the chance to discuss these issues with the Minister for Education, and/or Officials and discuss a practical way forward.
Thank you for your email to the Minister for Education and the Welsh Language, Jeremy Miles MS, about the guidance on face coverings in schools. I have been asked to reply.
I note that my colleague Mark Price wrote to you on 27 May 2021 in response to your Freedom of Information request and provided information on the scientific evidence upon which we have issued our guidance in respect of face coverings. We continue to be cautious about relaxing advice on non-pharmaceutical interventions as we continue to relax wider restrictions and given the recent emergence of the Delta variant.
I can confirm that we are keeping the matter under constant review, including the balance of harms, with a wide range of stakeholders comprising representatives of the education profession, local authorities, teaching unions and children and young people. We are aware that some learners are not comfortable wearing face coverings for lengthy periods and their use is recommended only for situations in which they are unable to maintain social distancing. We regularly review our guidance and please let me assure you that the requirement for face coverings in the classroom or anywhere else for that matter will not be in place for any longer than is necessary.
Dear Jill Hancock,
Thank you for your reply on behalf the Minister for Education and Welsh Language, Jeremy Miles to our letter with regards to the requirement of face coverings in secondary schools.
While you colleague Mark Price wrote to me on 27 May 2021, his response was rather generic:
“Although we do not hold a dedicated evaluation of the potentially harmful effects of requiring children to wear face masks in classrooms for prolonged times, we do hold information which considers the impact of face coverings more broadly.”
The burden of proof in recommending a public health intervention is that evidence on harms (and benefits) are graded according to certainty “low – high” as is presented in Sage minutes. However, the evidence for imposing a measure across healthy school children appears to have not been subject to the same scrutiny and so parents need to understand that the best interests of their children have been at the heart of this decision.
No adequate consideration of the harms was given by Public Health of Wales. And no adequate advice how to wear a face covering. Those face coverings are only effective so long as they stay dry. As per past years’ infection control recommendations, it could take 15 or 20 minutes, after which the mask would need to be changed. But those warnings were never communicated to the public.
In addition, international comparisons have not been considered, e.g. Weiner case (please see excerpts in Annex).
Neither the impacts of wearing face covering in heat and humidity which, for example:
- Can make children more susceptible to heat stroke.
- Can make it more difficult to breathe which can potentially lead to respiratory complications.
While you continue to be cautious about relaxing any non-pharmaceutical interventions, the use of face coverings as one of the system of controls needs to show that there is an incremental benefit of using face coverings in addition to the other measures that schools have adopted (e.g., bubbles, social distancing, increased handwashing, regular twice weekly testing of all pupils) and whether such additional benefit is justified given the potential for harm. The issue around the “more transmissible variants” has been shown to be incorrect.
There has been no systematic monitoring of the harms to make such evaluation. While a comprehensive assessment may not have been possible, the Department of Education alongside PHW could have collected data as advised by WHO guidance and has failed to do so. With so much uncertainty about any benefit it is unreasonable to continue with this policy and directly contravenes recommendations in previous versions of the guidance.
Any public health measure is usually reviewed according to strict criteria especially when imposing a potential harmful measure on a healthy child which has uncertain benefits.
The Welsh Government clearly consulted with the Unions about the guidance who’s members have expressed concerns in their open letter, but haven’t considered the viewpoints of children (nor child and educational psychologists).
Several studies have been published on the harms of wearing face masks for lengthy periods and yet apparently have not been taken into consideration. The WHO guidance states: “Do no harm: the best interest, health and well-being of the child should be prioritized.”
We are asking for the Government to apply the same principles of assessment of any intervention imposed on healthy children and to weigh the evidence on both sides of the equation to demonstrate that we are following the science and the data.