Public Comment on the WHO Strategic and Operational Plan for Coronavirus Disease Threat Management (2025–2030)

Submitted to: covid19@who.int

Subject: Public comment submission – strategic and operational plan for coronavirus disease threat management

We appreciate WHO’s continued leadership in coordinating global efforts to reduce the burden of coronavirus disease threats and welcome the opportunity to comment on the draft Strategic and Operational Plan (2025–2030). The shift from short-term emergency response to long-term, integrated threat management is both necessary and overdue. However, the current draft requires substantive revision to address core scientific and operational realities that are critical to long-term success.

Introduction: Lessons to be learned from the early pandemic response

As noted in the WHO Plan, lessons can be learned from the COVID-19 pandemic. We strongly agree — and emphasize that meaningful learning begins with clear evaluation. The wide variation in outcomes across countries early in the pandemic demonstrates that better responses were not only possible, but achieved. This variation makes it clear that success depends on early action and identifiable, effective public health measures.

In particular, countries such as New Zealand, Vietnam, and Taiwan, as well as regions like the eastern provinces of Canada, acted swiftly and recognized airborne transmission early. They were able to markedly limit transmission, save lives, and reduce the long-term burden of disease. In contrast, most countries failed to meet the appropriate standard: containment and elimination — the only strategy that prevents illness and reduces the need for disruptive measures by stopping community transmission at the source.

The role of a global public health agency should be to identify and promote successful strategies worldwide to improve outcomes everywhere. Even in places that performed relatively well, further gains can be made by learning from others. Mutual learning and adaptation must be continuous and global.

The failure to communicate and implement effective measures globally contributed to widespread transmission and to severe individual, economic, and societal harm. SARS-CoV-2 spread rapidly across the world, killing tens of millions and disabling hundreds of millions. Yet this scale of harm must not be seen as inevitable: both the early successes during the COVID-19 pandemic and the successful containment of previous outbreaks, including SARS-CoV-1, show that much better outcomes were possible.

Unlike COVID-19, SARS-CoV-1 was successfully contained. The comparative — and catastrophic — failure to contain SARS-CoV-2 must be explicitly acknowledged in the WHO Plan. Only with a clear-eyed assessment of what went wrong can we build effectively on past experience and avoid repeating the same mistakes. A critical, science-based analysis of pandemic responses is essential — both to reduce the ongoing burden of COVID-19 and to enable faster, more effective responses to future respiratory pathogens with pandemic potential.

We posit that the WHO and other government actors failed to adopt a precautionary principle to control the spread of SARS-CoV-2 by ignoring modes of transmission common for other coronaviruses which, if properly controlled, could have drastically reduced the spread of SARS-CoV-2 in 2020, if not altogether avoided the pandemic.

1. Clean Air is the 21st Century’s Clean Water

Airborne transmission is the dominant mode of spread for SARS-CoV-2. This simple fact has profound implications—but it is not adequately reflected in the draft plan. Moreover, airborne transmission of SARS-CoV-2 would have been reasonably predictable in 2020 for an international health organization based on information gathered from like-coronaviruses, such as SARS and MERS. At the very least, a reasonably diligent public health body would have anticipated that such a mode of transmission would have been feasible for this kind of virus, and adjusted its recommendations accordingly. Clearly, based on how the spread of this virus was not properly controlled, leading to a pandemic, this was woefully not the case. In fact, to this day, despite robust evidence, instructions regarding the spread of SARS-CoV-2 remain murky at best, as reflected in the current draft WHO plan. SARS-CoV-2 spreads through the air. This should be clearly articulated.

The appropriate analogy here is clean water. We do not protect against waterborne disease by treating patients with antibiotics or offering public guidance about handwashing alone—we ensure the water is clean. Similarly, we cannot protect against airborne disease without addressing the quality of the air people breathe.

Vaccines, surveillance, and clinical care are all essential. But none of them prevents exposure. Without systematic airborne precautions—including clean indoor air standards, effective ventilation and filtration, and widespread availability of high-quality respirators—COVID-19 and related threats will continue to circulate, evolve, and harm populations. These interventions are not “optional”; they are the only way to reduce transmission at its source.

The draft plan mentions ventilation in passing (C2.3) and limits respirator use to clinical settings (C3.3). This is not adequate. WHO must affirm that:

• Airborne transmission is primary.
• Clean air is the medium of protection.
• Respiratory protection must be community-wide.

2. COVID-19 Is Not a Respiratory Disease

A second core correction is needed in the framing of the document: COVID-19 is not simply a “respiratory disease.” It is a respiratory transmitted disease—a critical distinction.

COVID-19 is a vascular disease, with an affinity for the ACE2 receptor consequently affecting the brain, heart, vasculature, endocrine system, and multiple organs beyond the lungs. SARS-CoV-2 is no more a “respiratory disease” than HIV is a disease of the sexual organs. The symptoms of a Covid infection may begin in the respiratory tract, but its pathophysiology is multi-systemic. Framing it as a respiratory disease reinforces a misunderstanding of its risks and long-term consequences.

To serve its global audience, this plan must:

• Use accurate terminology: COVID-19 is a respiratory transmitted disease (RTD), not a respiratory-limited one.
• Avoid structural minimization: By lumping COVID-19 with influenza and RSV programming without addressing its broader systemic effects, the plan misrepresents the threat it poses.

3. Long COVID / Post-Acute Sequelae Must Be Central, Not Peripheral

The plan refers to Long COVID (Post-Covid Conditions/PCC) but does not treat it as a strategic priority. This is a critical oversight.

Long COVID is not rare. This chronic condition stemming from a SARS-CoV-2 infection has afflicted many millions, with profound implications for health, lifespans, health systems, economies, and workforce participation. The mechanisms of Long COVID involve viral persistence, vascular damage, immune dysregulation, organ injury, and potentially others as well—all requiring dedicated, targeted research and investment in prevention. We are deeply concerned by the long term impacts of Covid infections on the population. This is evidenced by the plethora of research which supports that many, if not most, will eventually develop some type of chronic condition from SARS-CoV-2 infection, especially when those individuals suffer from repeat infections. Therefore, at this stage, as the majority of the world’s population has had multiple Covid infections, measures should be implemented to address the following realities:

• a large portion of the population is currently suffering or is conditioned to suffer from chronic illness, which they are unaware of having been caused by their Covid infection(s). This requires proper medical infrastructure to support; and
• we can reasonably anticipate that populations will continue to be subject to further Covid infections, unless the messaging about Covid’s modes of transmission and long term consequences is communicated effectively and convincingly to affected populations.
• These infections will continue to increase SARS-CoV-2’s burden of illness on our societal systems, both in the acute stage and the chronic stage of the disease.

To address this, the final plan must:

• Include Long COVID prominently in the strategic objectives and operational pillars.
• Define Long COVID mitigation—including transmission prevention—as a core rationale for upstream protections including clean air and respiratory protection.
• Mandate investment in longitudinal tracking, treatment models, and research on pathophysiology and prevention.

4. Recommendations for Revisions

To address these gaps, we respectfully recommend the following changes to the draft plan:

• Reframe COVID-19 as a respiratory transmitted disease (RTD), distinct from other respiratory infections, with explicit recognition of its systemic effects.
• Establish airborne precautions as a foundational pillar across all operational domains—not as a secondary IPC measure.
• Treat clean indoor air as part of essential public health infrastructure, with guidance and support for national implementation.
• Include strong, specific commitments to Long COVID mitigation, prevention, and care integration across primary and specialty systems.
• Elevate respiratory protection (Respirator-grade masks, e.g. N95s or better) in community settings, with recommendations for public access, equity, and normalization of use in high-risk environments.

5. The Role of Risk Assessment and Institutional Credibility

A credible response to airborne threats requires more than technical capacity—it requires accurate risk assessment and transparent communication. When institutions understate or obscure the true risk of airborne transmission, they do more than delay action: they degrade public safety and erode public trust.

A risk assessment that fails to acknowledge the primacy of airborne transmission cannot be neutral. It actively impairs the ability of individuals, communities, and governments to protect themselves. Worse, it places the authority and reputation of the organization behind a judgment that will be proven incorrect by lived experience.

To preserve both public safety and institutional credibility, WHO must ensure that all risk assessments and guidance materials fully and explicitly reflect the dominant role of airborne transmission. Guidance that excludes or minimizes this risk is not just outdated—it is dangerous.

Closing

We recognize and support WHO’s role in building a coordinated global approach to infectious disease threats. This moment requires not only administrative integration, but scientific clarity and ethical leadership.

We urge WHO to correct the plan’s framing errors, center on airborne transmission, and reflect the true nature of COVID-19. Otherwise, we risk institutionalizing a model that cannot deliver the safety, trust, or effectiveness this moment requires.

Respectfully submitted,

The World Health Network