COVID-19 Public Health Policy for Orange County's Homeless Shelters

March 16, 2020

Chairwoman Michelle Steel
Vice Chairman Andrew Do
Supervisor Donald Wagner
Supervisor Doug Chaffee
Supervisor Lisa Bartlett
Public Health Services Deputy Agency Director David M. Souleles, MPH
Office of Care Coordination

RE: COVID-19 Public Health Policy for Orange County’s Homeless Shelters

Dear Orange County Supervisors, Public Health Services Deputy Agency Director David M. Souleles, and Office of Care Coordination,

We urge you to immediately develop and implement plans for the prevention and management of COVID-19 in all homeless shelters in Orange County.

The thousands of people living in Orange County’s shelters on any given night are extraordinarily vulnerable to outbreaks of contagious illnesses such as COVID-19. Homeless shelters, by their very nature, make it impossible for residents to comply with precautionary measures recommended by the Centers for Disease Control (CDC). In fact, shelters are highly potent environmental modes of transmission. For example, the CDC recommends that people reduce their risk of contagion by avoiding mass gatherings and maintaining a 6-foot distance from others. But shelters congregate scores, and sometimes hundreds, of people in crowded, warehouse like conditions. Sleeping mats, cots, or beds are often separated by only a few feet. Moreover, as recent reporting and the American Civil Liberties Union of Southern California’s (ACLU SoCal) investigation show, California's shelters are sometimes dangerously unsanitary, elevating the risk of transmission. For example, while the CDC recommends aggressive handwashing to prevent the spread of COVID-19, as recently as this week we have received information from shelter residents who report shortages or lack of toilet paper and tissues, no handwashing soap, and lack of warm water for washing hands. We have also received reports of filthy bathrooms and showers. The risks posed by Orange County’s shelters are doubly alarming because many shelter residents, including people who are ill and older adults, are at higher risk of getting very sick from this illness.

We urge the Orange County Board of Supervisors, Orange County Public Health officials, and the Office of Care Coordination to take immediate, coordinated action to protect the health and safety of people who live and work in homeless shelters.

We would like to meet with you within the next two weeks to share our information on current conditions and practices in homeless shelters that are putting those who live and work in them at risk of infection and discuss how you plan to prevent and respond to COVID-19 outbreaks in all homeless shelters in Orange County and implement a system to ensure compliance.

Among the recommendations we wish to discuss with you are:

• Establishment of health and sanitation standards that apply to every homeless shelter in Orange County and a system to ensure compliance: As recent reporting and an ACLU SoCal investigation note, homeless shelters are subject to a patchwork system of oversight, with no single public entity in charge of making sure they are safe and sanitary. This weak regulatory environment can result in toxic and unsafe conditions, including too few toilets for the number of residents and broken toilets; raw sewage flowing from porta potties; showers with no temperature control if they work at all; infestations of rodents, maggots, and other insects; an acute shortage of soap and cleaning products; a lack of heat on cold winter nights; and flooding during rainstorms. To protect residents from infection, the County should develop and enforce high and uniform health and sanitation standards for homeless shelters. The ACLU SoCal's report on homeless shelters provides model guidelines. Our recommendations for the prevention and management of COVID-19 in Orange County homeless shelters include, but are not be limited to, the following standards:
  • Hygiene supplies: Health and safety standards must include the most basic aspect of infection control: hygiene. There must be ready access to warm water and adequate hygiene supplies, such as soap, both for handwashing and for cleaning. Shelter residents must also be informed about the virus and the measures they can take to minimize their risk of contracting or spreading the virus.
  • Social distancing: Health and safety standards should also include protocols that help shelters align with CDC recommendations on social distancing. For example, sleeping spots should be placed at least six feet apart, ideally with barriers between residents. To prevent and mitigate outbreaks, the County should also provide shelter residents with opportunities for self-isolation, including provision of motel or housing vouchers.
  • Testing and treatment: Because of the extraordinarily high risk of contagion, shelter residents should be prioritized for COVID-19 testing and treatment. Staff must also be screened to ensure that they are not bringing COVID-19 into the shelters. Courses of treatment must be evidence-based, available immediately, and in compliance with scientifically based public health protocols. Safe, accessible transportation to health care facilities should be available to shelter residents.
  • Vulnerable populations: The plan must provide for additional precautions for those who are at high risk of serious illness if they are infected, such as older adults and people with chronic illnesses, compromised immune systems, or disabilities.
• Establish due process protocols for evictions: Shelter residents are often evicted at the discretion of shelter staff and with no due process protections. Unintended consequences could include the spread of COVID-19 as people experiencing homelessness cycle between multiple shelters and the streets. To help mitigate the spread of the virus, the County should immediately establish due process protocols to protect shelter residents from arbitrary and unaccountable evictions.
• Data collection: The collection of data regarding COVID-19 should be part of the public health response. As with any contagious disease, data collection is critical to understanding and fighting the virus. The same information that is tracked in the community must be tracked in homeless shelters.

Moving forward, the COVID-19 pandemic provides a stark reminder that homelessness is best addressed by providing people with homes—not shelters—as an immediate response to their housing needs. Affordable, permanent housing is a public health intervention and a form of health care. We call on you to support the development of long term, consistent County funding that is large enough to ensure that everyone in Orange County has a safe, accessible, healthy, and truly affordable home. When all our residents thrive, communities thrive.

Please let us know when you will be available to discuss your plans with us. You can reach me at egarrow@aclusocal.org or 714-450-3967.

Sincerely,

Eve Garrow, Policy Analyst and Advocate, ACLU of Southern California

Clarissa Woo Hermosillo, Director of Economic Justice, ACLU of Southern California