April 27, 2021
CAPT Sara B. Newman, DrPH, MCP, USPHS
Director, Office of Public Health
National Park Service
1849 C Street, N.W.
Washington, DC 20240
Subject: NPS Covid-19 Response Program and Data
Dear Captain Newman:
Thank you again for speaking with us last week regarding the National Park Service (NPS) Covid-19 response program and data regarding the number of positive Covid-19 tests among NPS employees. As we discussed during the call, the Coalition has submitted nine FOIA requests since the beginning of the pandemic in March 2020 seeking to learn the month-by-month total of NPS employees who have tested positive for Covid-19 and a list of parks where those cases have occurred. As context for our ongoing interest in this information, we know that approximately 20,000 NPS employees hosted 237 million visitors to the National Park System in 2020 (NPS data). On average, these numbers reflect a high potential for employee exposure.
I appreciate the time you spent discussing the logistical difficulties of setting up a program that could collect and report National Park Service-wide Covid-19 infection numbers. And we acknowledge the additional difficulties of gathering information related to how many employees have received a Covid-19 vaccination due to privacy concerns.
As a result of our call, we better understand that NPS has been reluctant to release information about the specific numbers of Covid-19 cases at individual parks due to privacy reasons. It was suggested that at small parks with small staffs such information may enable others (e.g., other employees) to deduce the name(s) of individuals who have tested positive. While that may make sense for the infected individuals, we reiterate that the lack of transparency and candor, in general, regarding the NPS Covid-19 response program could erode employee and public confidence in the credibility of the program; just as it did with the national Covid-19 response program under the previous administration.
We would expect the Park Service to be able to find an appropriate balance between protecting individual privacy vs. informing NPS employees, as well as the general public, of the extent of Covid-19 infections among Service personnel. In essence, the number of cases and the Covid positivity rate are basic indicators not only of employee exposure to the virus, but also how effectively parks are implementing basic public health precautions recommended by the Center for Disease Control (CDC).
We are glad to hear that the NPS Public Affairs Office is planning to share service-wide Covid-19 numbers on www.nps.gov. We strongly recommend that such information include the following: 1) the total number of NPS cases per month since March 2020; 2) a general statement about how many parks have had employees test positive (or the % of parks that have had cases) during that period; 3) a graph that compares the positivity rate among NPS employees vs. the nation as a whole; and 4) if possible, a tally of how many NPS employees have been partially and fully vaccinated against Covid-19. In the interest of maintaining transparency, we ask that this information be periodically updated (e.g., monthly) and posted on the NPS website. If this information is posted on the NPS website more or less as described, we will consider withdrawing our previous FOIA requests.
Also, during the call, we were interested to learn that individual parks are heavily dependent upon local and state public health programs for employee testing and vaccinations, and in coordinating response(s), when needed, for positive test results. This raises concerns about the capabilities of smaller parks, which often have limited resources for PPE, to effectively implement the necessary prevention activities or to handle a Covid outbreak among park staff. We would hope that each park has fully integrated Covid-19 procedures into its occupational safety and health program, consistent with Director’s Order 50B1https://www.whitehouse.gov/briefing-room/presidential-actions/2021/01/20/executive-order-protecting-the-federal-workforce-and-requiring-mask-wearing/ (DO-50B). As such, each park should have a designated Covid-19 coordinator whose responsibilities include serving as the park’s liaison with local and state public health officials. Without assignment of this responsibility, there can be no accountability.
As we mentioned during the call, we have heard anecdotal reports from NPS employees that on-duty co-workers do not routinely wear masks as recommended by CDC guidelines. Granted, these reports occurred before President Biden issued the Executive Order (EO) on Protecting the Federal Workforce and Requiring Mask-Wearing2https://www.nps.gov/subjects/policy/upload/DO_50B_9-3-2008.pdf on January 20, 2021. However, in order to maximize protection of park employees, we believe it essential that NPS leadership at all levels clearly communicates and emphasizes to all employees that the service-wide provisions for reporting unsafe and unhealthful conditions and work practices in the workplace also apply to reporting employee noncompliance with Covid-19 safety guidelines. For details, see RM-50B, Chapter 23https://www.nps.gov/subjects/policy/upload/RM-50B_Chp2_Reports_Unsafe_Work_Practices_Whistleblower_Protection-508.pdf, which includes provisions for anonymous reporting and protection from reprisal as a whistleblower.
In closing, we appreciate the significant challenges that NPS has faced in keeping its employees safe while keeping parks open during the pandemic. To the extent that NPS can periodically share general information about employee cases of Covid-19, it would be reassuring to the workforce, as well as to the visiting public, that NPS has been succeeding in accomplishing that important objective.
Philip A. Francis, Jr., Chair
Coalition to Protect America’s National Parks
2 Massachusetts Avenue NE, Unit 77436, Washington, DC 20013
Shawn Benge, Acting Director, National Park Service
Louis Rowe, Deputy Associate Director, Vis. and Res. Protection, National Park Service