NYS Health Commissioner Dr. Howard Zucker Responds to Mayor Bill de Blasio's Request to Use Second Vaccine Doses as First Doses

New York State Health Commissioner Dr. Howard A. Zucker today responded to Mayor Bill de Blasio's request to use second COVID vaccine doses as first doses.

The full text of Dr. Zucker's letter to the Mayor is available below:

February 4, 2021

To Mayor de Blasio,

I am in receipt of your letter of February 3rd asking for State Department of Health approval to use second doses of COVID-19 vaccine as first doses.

As you may know, and as I am sure your Health Commissioner has advised you, the use of second COVID-19 vaccine doses for first doses is a topic being discussed by top national and international health experts.

There are some health officials who advocate for use of second doses as first doses.

These experts will point out that their recommendation is premised upon a federally secured increase in vaccine production which would be required to meet the additional dosage demands in the coming weeks. There are also health experts that adamantly oppose the use of second doses as first doses because they believe there is inadequate production to manage the surge it would create. There is even a school of thought that suggests the delay between first doses and second doses has given rise to the viral variant strains that have surfaced. Clearly the medical community is of mixed opinion on the matter.

Most importantly, and definitively, the CDC, which is now headed by President Biden's team, does not recommend using second doses for first doses. I am in regular contact with the CDC, including as recently as this morning, on this topic when they affirmed their opposition to using second doses as first doses now. The CDC has information that we do not have. The CDC has intimate knowledge of the future vaccine production schedule as it is federally controlled and their opinion is informed by national and international medical professionals researching the virus.

Governor Cuomo has already said that if the CDC does recommend using second doses for first doses he is ready, willing and able to administer a state-wide program that will do just that. If the CDC does reach a point where they recommend the use of second doses it is fair to assume the CDC will also recommend protections that would need to be put in place to make sure second doses are available on a timely basis. Your suggestion that a "brief delay" of people receiving second doses would be acceptable however it does raise a caution flag. People have worked very hard to get a vaccination appointment and there is much public anxiety that second doses will not be available on their appointment date. While the science on whether a "brief delay" would impact full immunity is open and disputed, I do believe it would create undue anxiety to tell people who have scheduled appointments that those appointments are being shifted even for a "brief delay." As you know the vaccination process and supply has not instilled a high level of public confidence. Even postponing appointments due to the recent snow storm caused concern, I believe it is important that all scheduled appointments be honored.

I would ask New York City and all other local jurisdictions to continue their focus on vaccinating their 1B essential workforce and priority hospital workers and addressing the low performing hospitals. The differential in the hospital staff vaccination rate can be as high as 50 percent. We must do better. We have been working with private hospitals which have increased their performance and would ask for your attention to the public hospitals under your control on this matter. We know that if there is a variant that causes an increased infection rate, hospital capacity will once again become a pressing issue and those hospitals with a lower percentage of vaccinated staff will most probably be the first to fail.

Governor Cuomo, as you know, has been very aggressive in procuring increased vaccine supply and vaccination implementation. If the CDC does in fact recommend usage of the second dose as a first dose, I can assure you New York will set the national model.

Sincerely,

Dr. Howard A. Zucker, M.D., J.D.

Commission of Health