HART have made this document public in advance of the deadline so that others can use the content to improve their own submissions and to allow feedback before submission

The deadline to respond to the proposed terms of reference for the English Public Inquiry into covid ends on 7th April. There are number of major omissions from the current proposed terms of reference including mention of the misuse of behavioural psychology, errors in death diagnosis, failure of systems designed to prevent mistakes, vaccine mandates and harm, conflicts of interest, impacts of policy on major life events and children (outside of their educational needs).

The remaining terms are framed in such a way that voices saying we should have more and earlier restrictions are more likely to be heard than those who believe we should have had none.

HART will be submitting the following in an attempt to broaden the terms of reference and ensure a fair hearing. We encourage you to also complete the survey and ask that terms be extended to include issues which concern you. Please feel free to borrow from the submission below to complete your own response.

HART’s submission for the Public Inquiry Terms of Reference Public Survey

Do the Inquiry’s draft Terms of Reference cover all the areas that you think should be covered by the Inquiry?

HART is a membership organisation comprising forty professionals and academics including highly qualified UK doctors, scientists, economists, psychologists and other academic experts. We have broad medical expertise including epidemiology, infectious diseases, pathology, psychology and paediatrics, and public health, alongside expertise in risk optimisation and cost-benefit analysis. 

HART believes that the draft Terms of Reference omit 8 important issues. We set out in this submission suggestions for areas where improvements to the Terms of Reference could be made:

1. Accuracy of the recording and measurement of deaths from Covid
2. Use of professional behavioural psychology techniques and the effects of deliberately stoking fear in the general public, the media and institutions
3. Failure of checks and balances across multiple areas of public and institutional discourse
4. The censorship or suppression of anyone who questioned the official narrative, for example pursuant to Ofcom guidelines
5. Lack of impact assessments and the disregard of harms caused by restrictions, particularly for children
6. Discrimination against the unvaccinated population, especially mandatory vaccination of Healthcare Workers (‘HCWs’) and care home staff
7. Vaccine harms, including fatal injury confirmed by findings at inquests
8. Conflicts of interest and perverse incentives – in particular their impact on policy choices

We suggest that 13 of the existing terms of reference are expanded:

1. Preparedness and resilience *and the justification for abandoning years of planning*
2. *What was the justification for the assumptions used to drive decision-making, who was accountable for the advice given and decisions made? To what extent was the validity of the assumptions regularly reassessed to ensure correct decision-making*. How were decisions communicated and implemented? 
3. The availability, *quality* and use of data and *real-world* evidence *and its effect on policy and on societal wellbeing*
4. *The effectiveness of and justification for* the use of *and duration of* lockdowns and other ‘non-pharmaceutical’ interventions such as social-distancing and the use of face coverings *and the consideration of actual or potential harms caused thereby*
5. *The appropriateness of, strategy for and quality of* testing, contact tracing, and isolation *and an assessment of their costs and benefits*
6. Restrictions on attendance at places of education *their justification and their short and long term consequences*
7. Preparedness, initial capacity *and how decisions were made about what capacity was required and who were accountable for those decisions, the ability to increase capacity, adequacy of that increase* and resilience
8. The management of the pandemic in hospitals, including infection prevention and control, triage, critical care capacity, *the appropriate use of ventilators*, the discharge of patients, the use of ‘Do not attempt cardiopulmonary resuscitation’ (DNACPR) decisions, the approach to palliative care, workforce testing, changes to inspections, and the impact *of illness and of testing and isolation requirements on* staff and staffing levels *and their appropriateness*
9. The management of the pandemic in care homes and other care settings, including *assessing the scientific and ethical justification for and harm caused by Government policies and local decisions* around infection prevention and control, the transfer of residents to or from homes, treatment and care of residents *by staff and GPs*, restrictions on visiting, and changes to inspections and *the impact of vaccination including the mandate for staff.* 
10. *The calculation of the requirements for* and the procurement, *reallocation* and distribution of key equipment and supplies, including PPE and ventilators
11. The development, *prioritisation* and delivery of therapeutics *including both early and hospital treatment*, and vaccines *including assessment of their safety and efficacy*
12. The consequences of the pandemic *and policy* on provision for non-COVID related conditions and needs, *including the causes of reduced provision of GP and hospital care, use of Do Not Resuscitate orders and restrictions on access for certain groups, the particular effects on cancer care, emergency care, children’s care and the impacts of policy on the doctor-patient relationship*
13. The *extent of* and provision for those experiencing long-COVID

Ensuring mistakes are not repeated

In 2009, a pandemic of influenza (swine flu) was declared. It has since been concluded that many aspects of the response to that incident were dysfunctional. Despite subsequent reports identifying the mistakes which were made and the fact that many individuals^, and the Council of Europe called for such serious mistakes “to never be made again”, it is clear that the same errors (and additional, more serious ones) were made in the pandemic which began in 2020. It is germane to the inquiry to ask why appropriate lessons were not learnt from the 2009 pandemic. It should also be asked whether public health bodies should (without overwhelming evidence) be able to discard the formally agreed Pandemic Planning Guidance which had been signed off across Government, just because, indeed especially when, there is the kind of emergency for which such a plan was arguably designed. 

We suggest that a number of key issues are not currently included in the terms of reference and ought to be of interest to the Public Inquiry. They are set out below.  Part 1 addresses points omitted entirely and Part 2 seeks to ensure sufficient breadth for terms already included. Given the confines and formatting of the portal, HART has included supporting materials for this submission at  https://www.hartgroup.org/terms-of-reference/

Part 1 – Terms omitted entirely from current terms of reference

Accuracy of the recording and measurement of deaths from Covid

1. Why was insufficient effort made to distinguish deaths with Covid from deaths due to Covid? 
2. For patients in whom Covid may have hastened death, even by a very short period of just days, did  doctors inappropriately cite Covid as the principal cause of death?
3. Why was such emphasis placed on finding every possible Covid-related death at the expense of accuracy and taking account of pre-existing morbidities? 
4. What was the impact of overly sensitive testing on death classification? A particular focus should be made on death diagnosis in Winter 2020/21 and the causes of the sharper and higher rise in deaths ascribed to Covid than seen in neighbouring countries during that period. 
5. Was public perception of the level of the threat distorted by excessive Covid death diagnoses?
6. The Inquiry should examine the statutory change in practice on conducting post-mortems and any effects of that change on accurate data collection. 
7. The accuracy of the death certification process should be analysed as well as the justification for the statutory and policy changes to that process.
8. Why was no data collected on the number of deaths reported to the coroner but not yet registered with the ONS, such that the death data could be out of date by months?
9. What was the impact of Covid on deaths prior to the introduction of PCR testing in Spring 2020?
10. Why did GPs not enter care homes to diagnose, treat and determine the cause of death?
11. What caused the sudden surge in excess mortality in care homes in January 2021? 
12. Why was the mortality rate from Covid in care homes in January 2021 so much higher than it was in Spring 2020?

Use of professional behavioural psychology techniques and the effects of stoking fear  in the general public, the media and institutions

1. Who was responsible for the deliberate strategy to make every person feel at considerable personal risk? How was the policy justified?
2. The Inquiry should investigate the ethics of the government’s massively expanded use of behavioural psychology, which knowingly deployed fear, shame & scapegoating (‘affect’, ‘ego’ & ‘norm’ nudges) on its citizens in order to manipulate thoughts and actions. The investigation should include consideration of consent for this intervention.
3. What impact did behavioural psychology techniques have on the mental health of the general public? 
4. Were the broader impacts on behaviour and non-Covid health matters ever considered? 
5. Was any thought put into how (or even if) Government induced fear could be reversed when the crisis eased? Was the time it might take for the population to recover from this strategy considered?
6. The Nudge Unit and SPI-B are described on gov.uk as “independent”. To whom are they accountable? Are either ultimately funded by any entity other than the British taxpayer? 
7. How was spending £500m on media advertising justified? What was the purpose of the spending? How were outcomes measured? Did the outcomes achieve the stated purposes? 

Failure of checks and balances across multiple areas of public and institutional discourse and the censoring or suppression of anyone who questioned the official narrative

1. How and why did the usual checks and balances appear to have failed in multiple arenas?
   • Politically, Parliamentarians abdicated their responsibilities and denied the executive the benefit of ongoing critical analysis of its decisions. 
   • In the public realm, any dissenting voices were suppressed in the media by means of various mechanisms, including the Ofcom regulations and the “Trusted News Initiative”
   • Why did the Government create and tolerate an environment in which it became acceptable to single out and attack individuals who attempted to put forward any views which did not entirely accord with the “official” narrative. 
   • Why did professionals who did speak out face disciplinary action from their professional bodies and their employers?
   • Institutions, the role of which is to protect certain groups (e.g. Liberty and the NSPCC) and human rights lawyers were silent and the Inquiry should be asking why. 
   • Why did institutions, such as the Royal Colleges, fail to call out mistakes?
2. Would allowing  a broader range of voices to engage in public debate, without being suppressed and personally attacked, have resulted in a more proportionate response to the pandemic, with fewer harms caused?
3. Science is a process whereby hypotheses are proposed, with others then testing and critiquing these ideas so that they can be adapted as new information comes to light. Why was new information not assimilated into public discourse and debate about the virus, as it emerged from around the world? 
4. Why did the government urge the public to “follow the science” as if “the science” was both agreed upon and fixed, when it was neither?
5. Was the lack of openness to opinions held by those outside the Government’s inner cadre of advisors harmful?
6. Did the Ofcom guidelines materially affect the tenor of questions asked by mainstream media of politicians and their advisors particularly at the daily national briefings?
7. To what extent did their tendency to catastrophise affect the media’s handling of their role?
8. Was the media’s judgement affected by the significant funding from the government?
9. To what extent was a vicious circle created due to stoking fear, public panic, media reporting and the political response as a result?
10. Were politicians themselves directly impacted by their fear campaigns?
11. Did the courts fulfil their role, which is to provide a check and balance, particularly in areas raising vital questions of human rights and civil liberties?
12. Were the Children’s Commissioner’s concerns around the harms to children caused by restrictions taken sufficiently seriously? 

Lack of impact assessments and the disregard of harms caused by restrictions particularly for children

1. Why was the “precautionary principle” applied to such an extent in response to the virus and never to any of the measures implemented in the (ultimately futile) attempts to “control” it?
2. Why were impact assessments absent or inadequate for both the first and subsequent lockdowns and other restrictions? 
3. In terms of the harms caused by restrictions, it is suggested that the Inquiry should look at the following: 
   • non-Covid healthcare
   •  the economy
   • education 
   • wider impacts on children
   • the wellbeing of the elderly especially in care homes and those living alone 
   • domestic abuse
   • mental health
   • drug and alcohol abuse 
   • poverty 
   • the long-term implications of the apparent acceptance of government interference in the minutiae of life. 
4. What was the impact on significant life events and the periods around them including births, marriages and deaths and was it justified? For example, the Inquiry should examine the impact on relatives from the guilt of being excluded when their loved ones were told they were dying and then died alone and their own abandonment when left to grieve alone.
5. Why were many human rights overridden e.g. the right to liberty and the right to worship? Why were the courts so supine?
6. Was it wise to condone private and public institutions imposing restrictions that were stricter or lasted longer than the Government guidelines?
7. What was the psychological impact on the population as a whole and the specific impact on the deaf, child development, confidence in teenagers and on teaching and learning of mask wearing? 
8. Specific consideration should be given to the impact of measures on the lives of children and whether these were considered in decision making.
   • The protection of vulnerable children and provision for those with special needs requires particular attention. 
     • What was done to safeguard children when schools shut? 
     • Why did social workers stop entering homes? 
     • Why were statutory and third sector youth clubs and services closed and then reclosed in the subsequent lockdown and what was the consequence of that? 
     • What was the rationale for Home Education Advisers, with an important safeguarding role for many vulnerable children, being required to move their interactions with families online? 
     • Why were individual risk assessments not undertaken when face-to-face teaching was replaced by online classes? Why were those already at risk from CSE not further protected from unsupervised online access during a time when they were isolated from social contact with their peers and therefore made more vulnerable to this?
     • Why did Special Schools close in the first lockdown, support workers stop visiting families with special or complex needs and respite care for parents with these children cease, and why was no exception for intergenerational mixing/familial contact made for these families given that services were not functioning? 
   • What harm was done to children, beyond educational disruption, by policies which interfered with their physical, cognitive and social developmental needs? Why was nothing done to mitigate these harms once the effects of the first lockdown were clear? In particular: 
     • Why were playgrounds closed and outdoor sports and activities prohibited during both national lockdowns? 
     • Why were children, for whom play and interaction is necessary for physical, cognitive and social development, prevented from interaction with other children even outside?
     • In the first national lockdown, when only one hour of exercise outside the home was allowed, why was no provision or exception made for children who did not have access to outdoor space at home? 
     • Why were parents of young children excluded from nursery and educational settings when children were being settled into new placements or were exhibiting signs of distress at separation? 
     • Why were children denied physical comfort by staff when distressed or in need of reassurance? 
     • Why were young children denied the possibility of bringing comforters and transitional objects from home in some schools and nurseries. Was this justified? 
     • Was it necessary to implement strict social distancing measures (which inhibited necessary play and touch) amongst all children in schools, especially primary schools?
   • What was the impact on children of the fear messaging and the medicalised culture around them and why were no attempts made to mitigate those harms? 
     • Why were children and young people subject to fear messaging which placed civic and moral responsibility on them for the health of their loved ones and the community and which induced shame for wishing to engage in normal, developmental activities essential to their health and well-being (seeing friends, seeing family, engaging in physical affection and play)?
     • Why did virtually all CAMHS intervention move online? 
     • What risk assessments were conducted in terms of engagement via online services for the most vulnerable teens and adolescents? 
     • Why were children discharged from services when they could not or would not access support in this way?
   • What will be the result of lack of access to healthcare including mental healthcare and dental care and the rise in obesity levels for this generation? 
   • What was the justification for and impact of separating children from their parents when in need of comfort when accessing healthcare and for parents in prison? 
   • What was the decision-making process that led to children and adults being asked to wear face masks in schools?
     • Who and which groups were involved in these decisions? 
     • What professional groups with expertise in child welfare and educational practice were consulted? 
     • What impact did this have on their social interaction and communication with peers and teachers, ability to engage in and access educational activity, and in terms of physical health?
     • Why were primary schools permitted to require parents to wear masks at drop-off & pick-up? 
     • What assessment was made of the likely mental health impacts of masks on children and parents?
   • What was the decision-making process that led to healthy children being asked to take twice-weekly Covid tests? 
     • Who and which groups were involved in these decisions? 
     • What professional groups with expertise in child welfare, child health, educational practice or diagnostic testing were consulted? 
     • Has there been any evaluation of this practice? 
     • On what basis have nurseries and some schools been permitted to demand lateral flow or PCR testing as a condition of attendance?

Discrimination against the unvaccinated population, especially mandatory vaccination of Healthcare Workers (‘HCWs’) and care home staff

1. As well as considering the vaccine delivery, the Inquiry should consider the impacts of policies designed to denigrate those citizens who chose to remain unvaccinated, which have unnecessarily stoked division in society.
2. What was the impact of the vaccine mandates on HCWs and care home staff? 
3. Why were mandates and vaccine passports introduced at a time when evidence was readily available that they would have minimal to no impact on the number of infections and spread? 
4. What were the consequences of laying off care home workers, such that there was insufficient capacity to enable discharge of patients from hospital, thus creating direct pressure on the NHS?
5. How many NHS staff left the NHS as a result of mandate threats? 
6. What effect did mandate threats have on morale?
7. Was the Government aware that vaccine mandates violated both the Universal Declaration on Bioethics and Human Rights 2005 and the GMC Good Medical Practice guidelines?
8. What effects have vaccine mandates had on attitudes towards bodily autonomy, informed consent, trust of health professionals and trust in Government?
9. What damage has been caused to public attitudes to other vaccination programmes? 
10. Was it justified to legalise discrimination and reduced employment rights on the basis of healthcare choices? 
11. Were Covid passes introduced to coerce people into vaccination?
12. Were proposals for Covid passes influenced by a desire to accelerate a plan to introduce a digital ID?

Vaccine harms including fatal injury, confirmed by findings at inquest

1. Did the Medicines and Healthcare products Regulatory Agency (‘MHRA’) fulfil their role in protecting the public?
   • When the licensing rules were changed, what processes were put in place to ensure that the Covid vaccines would eventually fulfil the full licensing requirements?
   • Why were careful, large studies to ensure safety not carried out at the beginning of vaccine rollout, given the inability of the pre-existing trials to detect rare adverse events? 
   • Why were no additional safety monitoring systems put in place prior to a whole population rollout of a novel drug? 
   • Why was the threshold for attributing a symptom, long term consequence or death to Covid so low? Why was the threshold for the same factors  after vaccination so much more strict? 
   • Why have no studies been carried out to show the dose of spike protein that these drugs induce for different groups and ages? 
   • Why was the spike protein chosen as a target for these drugs and why was more not done to deactivate the parts of the protein responsible for toxicity? 
   • Why was an adenovirus vector chosen despite its failure when used for other vaccines?
   • Who made the decision for the UK to  stop using the AstraZeneca vaccine? When was the decision made? What evidence was this decision based on? Why did this evidence not emerge earlier?
   • Why was the UK so slow to stop using AstraZeneca when other countries acted after far fewer doses had been deployed? 
   • More adverse reactions were reported to the MHRA than had been received in its 40 year history. Why was this signal ignored? 
   • There has been a material rise in cardiac arrest calls to ambulances, excess deaths in the young and collapses and deaths of footballers on the pitch as well as other sports players. Did Covid and/ or the vaccine contribute to this rise? 
   • What was done to ensure the same amount of mRNA (as opposed to the delivery nanoparticles) was present in each batch and dose? Were there any random and independent sampling strategies in place?
   • Why were adverse events so much higher for some mRNA batches of vaccine than others?
2. How many serious adverse reactions and fatal outcomes were there for each vaccine type and what attempts were made to ensure comprehensive measurement of these including coroners’ inquest outcomes?
3. What drove the decision to include healthy children in the vaccine rollout programme, despite the JCVI repeatedly stating that the benefit/risk balance was too fine to justify mass vaccination of healthy under 16s?

Conflicts of interest and perverse incentives – in particular their impact on policy choices

1. The extent to which conflicts of interest have affected decisions made should be investigated. 
2. There are formal mechanisms to prevent involvement in decision-making when there is a conflict of interest. Were those mechanisms effective in this crisis, particularly in relation to:
   • politicians and their contacts; 
   • advisory bodies, for example SAGE; 
   • regulatory bodies;
   • universities and public health institutions;
   • other public bodies.
3. onflicts could include any potential benefit in terms of power and promotion as well as financial gain. 
4. Some private entities profited directly in the crisis. One beneficiary of vaccine sales to the UK has disclosed gifts of over £9m to MHRA and £7m to PHE, in addition to £60m to BBC, £300m to Imperial, £300m to LSHTM, £200m to Liverpool STM, £280m to Oxford and £40m to Cambridge since 2002. Why were Government bodies receiving financing from private entities and what impact did that have on decision making  
5. Why were the terms of the vaccine manufacturers’ contracts kept secret, especially given the indemnification against any liability for harms caused? As the state assumed the risk, why were the terms not disclosed to the public?
6. For SAGE, imposing overly harsh restrictions had no cost. Failing to impose sufficient restrictions could have resulted in severe penalties. What was done to mitigate the effect of these perverse incentives affecting SAGE in relation to the imposition of restrictions? 
7. The media were incentivised to adopt the official narrative in line with Ofcom guidelines. Did this create a perverse incentive preventing appropriate balance?  What steps were taken to ensure that the media were open to alternative views and scientific challenges to the dominant narrative?
8. Did the protocol driven culture in medicine create a perverse incentive that prevented the discovery and developments of treatments in the best interest of patients?
9. Was the political opposition hampered by a perverse incentive that supporting the Government would prevent them being blamed for Covid harms whereas opposing the Government could have resulted in them being blamed for Covid deaths?
10. Test manufacturer’s sales will continue as long as the ‘crisis’ continues. They are therefore incentivized to find ‘cases’.

Part 2: Expanding the breadth for terms already included

Italics /starred text reflect changes we would like to see in the wording.

In addition to these broad topics there are headings included in the current terms which need expanding to have a sufficient scope for the inquiry to appreciate the full picture.

Preparedness and resilience *and the justification for abandoning years of planning*

1. Why were existing plans abandoned and, if it was because of perceived differences between SARS-CoV-2 and influenza, why were prior plans not revisited when emergent data suggested more similarities than differences between SARS-CoV-2 and influenza? 
2. If these plans were thought irrelevant because influenza was chosen to illustrate the points, why was there no plan, before the heat of an emergency, for other scenarios?

*What was the justification for the assumptions used to drive decision-making, who was accountable for the advice given and decisions made? To what extent was the validity of the assumptions regularly reassessed to ensure correct decision-making?*. How were decisions communicated and implemented? 

1. Who decided that ‘asymptomatic spread’ should be treated as an important factor, given the lack of evidence that it contributes significantly to community spread?  
2. How did reducing transmission and covid mortality become the overriding priority over minimising harm overall?
3. Why was the evidence for prior immunity dismissed?
4. Why was the beneficial impact of naturally acquired immunity suppressed?
5. The reliance on modelling: 
   • Why was there no admission of uncertainty around assumptions used? 
   • Why was there a lack of debate around the two key unknowns on virus modelling – what proportion of the population would be infected and what proportion would die? 
   • Why was modelling continually prioritised to justify policy on restrictions even in the face of real world data that contradicted it? 
   • Why was such reliance put on Imperial modelling when it was known to have massively exaggerated risks of previous infectious disease epidemics, such as the Foot and Mouth Disease outbreak in 2001? 
   • Why were the original assumptions never revisited once real world evidence demonstrated their inaccuracy? 
   • Why were the assumptions about over 70s  intensive care demand so exaggerated and what were the consequences of that assumption in public policy terms?
6. Advice given to the Government:
   • On whose authority were appointments made to SAGE?
   • Who determined the composition of SAGE and which disciplines were represented. Who decided the composition of its sub-committees? Why were few if any practising clinicians included?
7. Why was there no ‘Red team’ to challenge the advice given to the Government especially after it became apparent that significant mistakes had been made?
8. Why were established scientific terms redefined e.g. ‘a case’, ‘herd immunity’, ‘vaccine’?
9. Who was responsible for drafting communications in a way that stoked fear? How was this ethical and why was there no consideration given to how to reverse it? What steps are now being taken to mitigate the effects of this policy?

The availability, *quality* and use of data and real-world evidence, *its effect on policy and on societal wellbeing*

1. Why was the publication of daily data prioritised over ensuring the quality of that data? What steps were taken to assess the psychological effect of broadcasting this figure to the country on a daily basis?
2. Why were assumptions and decisions never revised in the light of real world evidence, including from other countries? For example, when Sweden’s light touch approach proved to be less net-harmful, this did not result in changes to UK policy. 
3. Why was no data collected on deaths reported to the coroner but not yet registered with the ONS, so that the death data could in fact be out of date by months?
4. Why did the ONS object in court to sharing data concerning non-Covid deaths in young people because of GDPR legislation and the risk of identification, but they made no such objections in relation to data for Covid deaths? 

Legislative and regulatory control

Why was the Public Health (Control of Diseases) Act 1984 which was aimed at persons who ‘may be infected’ [section 45G(1)(a)] used as justification to impose severe restrictions on the entire country when the vast majority were healthy? 

The *effectiveness of, and justification for*, the use of *and duration of* lockdowns and other ‘non-pharmaceutical’ interventions such as social-distancing and the use of face coverings, *and the consideration of actual or potential harms caused thereby.*

1. How often was the removal of restrictions considered and why were decisions made to not unlock or remove restrictions earlier?
2. What was the justification for stricter and longer restrictions in certain regions?
3. Why did policy makers continue to rely on discredited models and modelling assumptions, even when real world evidence was plentiful and contradicted these assumptions?
4. Why did policy makers fail to interrogate the validity of the claim that asymptomatic transmission was a material driver in the spread of the virus, when it formed the primary justification for social distancing, lockdowns, mask wearing and was a major cause of the public’s fear? 
5. Once it was established that SARS-CoV-2 was spread via aerosols, why were no changes made to public health advice on surface transmission, social distancing and mask wearing? 
6. Why were emerging data on age-related vulnerability, especially the very low risk to the young and healthy, not reflected in public health policy? 
7. Why was guidance on healthy eating and exercise – to optimise immunity – never given to the public? 
8. Face coverings: 
   • Given the sparsity of robust evidence that, masking healthy people significantly reduces viral transmission, to what extent was the introduction of mask mandates primarily a political decision to strengthen ‘nudges’, increase fear and thereby increase general compliance with Covid restrictions? 
   • In a free society which respects individual rights, how can mandatory  masking be justified without  a very high evidential bar being met?
   • Why was there a U-turn on the justification for masks, without fresh evidence, and why was modelling employed to justify their use?
   • Why did mask use continue to be mandated when real world evidence showed no benefit? 

*The appropriateness of, strategy for, and quality of* testing and contact tracing and isolation *and an assessment of their costs and benefits*

1. Why was  ‘a case’ of Covid defined as a positive test result even in the absence of symptoms?
2. Testing strategy: 
   • Who decided the testing strategy, based on what evidence and was the strategy ever revisited? 
   • Why were the UK National Screening Committee and the Government advisors on mass-population testing, excluded from the decision-making process on Covid testing? 
   • Why was testing not re-calibrated, as evidence emerged, to ensure detection of only those capable of infecting others?
   • Why was speed and volume of testing prioritised over quality, even after peak deaths in the first wave? 
   • Why was Lateral Flow testing not prioritised in hospital once it was available, to prevent exposure of non-Covid patients on Covid wards? 
   • Why were millions spent on mass genomic testing rather than testing a few representative samples? 
3. Quality of testing:
   • Why was quality control in the laboratories not established to reduce the rate at which incidental low level virus of no clinical significance was described as a positive test result and therefore a ‘case’? 
   • Given the implications of a positive result, why was no confirmatory work carried out e.g. finding out if patients developed symptoms, retesting the patient and testing for antibodies? 
   • Why was no full system testing ever performed (with the results made public) whereby known negative samples were regularly fed into the system by post in order to test end-to-end quality and determine the operational false positive rate?  
   • What proportion of asymptomatic ‘cases’ were in fact incidental positives of no clinical significance as a result of testing designed to detect minimal virus? 
   • Why were UgenTec chosen over Diagnostics AI to supply software for interpretation of the test results?
   • Who was held to account for the £2m compensation payment to Diagnostics AI and what steps were made to ensure the mistakes made, that led to that payment, are not repeated?
   • How much manual auditing of the UgenTec test interpretation was carried out?
   • What processes ensured the best people were accountable for safe and effective running of the Lighthouse Laboratories?
   • What was done to minimise the risk from aerosols of contamination of samples and infection of staff?
   • Were post-infectious laboratory staff tested to ensure they were not shedding viral mRNA when handling samples?”
4. What was done to minimise the risk of infection outbreaks (due to SARS-CoV-2 and other organisms) among laboratory staff? 
5. Why were healthy people repeatedly tested, contrary to decades of public health best practice? What evidence was used to justify this policy?
6. Once infections were established across the country, why were huge efforts and money put into contact tracing despite a large proportion of cases having no known source? 
7. Why was no consideration given to minimising the isolation period to the length of the incubation period in those that never developed symptoms?

Restrictions on attendance at places of education, *their justification and their short and long term consequences*

1. What assessment was made of the potential benefits, costs and harms of closing schools? 
2. Which people and organisations that represented children were consulted during this process? 
3. Have the impacts on children’s education, emotional well-being and safeguarding issues been  evaluated?
4. What efforts were made to protect the most vulnerable children from school closures? 
5. What efforts have been made to reach the 100,000 children who failed to return to school after lockdown?
6. Why was routine testing of healthy pupils instituted and on what evidence?
7. How many children sent home as contacts of a positive case were subsequently shown to be infected and how many days of schooling were lost by unnecessary isolation? 
8. What justification was there for schools categorising children in large ‘bubbles’ such as whole year groups which were subsequently sent home when a positive test emerged, when such widespread contact would have been unlikely?
9.  Why were digital inclusion issues not factored in more systematically for those families already disadvantaged through low income and large families?
10. Why was the remit to continue teaching children in schools, limited to children of essential workers in the first school closure period? Why were issues of economic disadvantage, second language users and learners,and single parent households not factored in? 
11. Why were children whose families had resettlement and refugee status, not afforded more support with language learning and educational resources in their first language?
12. Why was the crucial stage of learning to decode print in the early years, by being guided individually with one to one adult support, not more systematically replicated through digital means for those children most at risk of low literacy levels? Why did the government not take a lead on providing good practice advice?
13. Why were community based learning hubs not established for those disadvantaged families most in need of support with online learning?
14. Why were the usual safeguarding checks and practices, carried out routinely by teachers in schools, not continued during school closures?
15. What has been done or should be done, to address the harms caused, including the gaps in children’s learning, the impact on their mental health and well-being and the safeguarding concerns for those most affected?
16. What assessments have been made of the effect on university students of obligatory online learning?

THE RESPONSE OF THE HEALTH AND CARE SECTOR ACROSS THE UK

Preparedness, initial capacity and *how decisions were made about what capacity was required, and who were accountable for those decisions*, the ability to increase capacity, *adequacy of that increase* and resilience

1. What steps were taken to plan for expanding capacity in the event of a pandemic? 
2. Were frontline doctors consulted to help estimate the requirements for Nightingale hospitals and intensive care capacity. . 
3. What preparations were made for Winter 2020/21 for increased demands placed on the NHS.
4. Why was imposing restrictions on the population again thought necessary, rather than expanding provision, despite having had substantial notice that this was likely to be necessary? 
5. Why were those healthcare professionals who volunteered to help, never called upon to do so?

The management of the pandemic in hospitals, including infection prevention and control, triage, critical care capacity, *the appropriate use of ventilators*, the discharge of patients, the use of ‘Do not attempt cardiopulmonary resuscitation’ (DNACPR) decisions, the approach to palliative care, workforce testing, changes to inspections, and the impact *of illness, of testing and isolation requirements* on staff and staffing levels *and their appropriateness*

1. What proportion of Covid cases that led to death were a result of transmission in hospitals and care homes?
2. Were the attempts to control spread in the community as opposed to in hospital proportionate? 
3. How did isolation rules impact staffing levels? 
4. Why were staff in contact with an index case (sometimes even very transiently) sent home to isolate, sometimes for 14 days, even when they were working on Covid wards in the day?
5. Why were staff who had confirmed Covid not redeployed in care of SARS-CoV-2 positive patients?
6. Were patients not suffering from Covid, but who were merely suspected to have Covid, unnecessarily exposed to infection on dedicated Covid wards?
7. Could more have been done to save lives by ensuring appropriate use of ventilators?

The management of the pandemic in care homes and other care settings, including *assessing the scientific and ethical justification for and harm, caused by Government policies and local decisions around* infection prevention and control, the transfer of residents to or from homes, treatment and care of residents *by staff and GPs*, restrictions on visiting, and changes to inspections *and the impact of vaccination, including the mandate for staff.* 

1. What impact assessment was done for care homes before (and/or after) Covid policies were introduced? 
2. What support were care homes given to ensure adequate care could be provided?
3. Did personal protective equipment (‘PPE’) and isolation of residents in their room have any demonstrable benefit? 
4. What evidence is there that PPE is effective in the care home setting and could more have been done to establish an answer to that question, over the last two years?
5.  Is the commitment to providing PPE in care homes in the future a justifiable use of money, that could be used for other more effective healthcare interventions?
6. What were the effects of carers being unable to make frequent short visits to residents in order to keep them hydrated? 
7. Did dehydration contribute to the high Covid mortality rate in care homes? 
8. What were the effects of massively reducing contact between residents and their families? 
9. Have care standards fallen due to the denial of access for relatives? 
10. Why have care homes restricted visitors, when staff test positive and are isolating at home? Who is protected by such a policy?
11. Given that care homes are populated by elderly people with a limited lifespan, were isolation policies which resulted in many living lonely miserable lives for weeks or months on end, in the best interests of residents or their relatives?
12. Did a culture of defensive decision-making mean that care home managers implemented every possible intervention, regardless of harm caused, in order to not be held liable for an outbreak? 
13. What impact did vaccine mandates have on the ability to provide adequate care?

The *calculation of the requirements for and the procurement*, *reallocation* and distribution of key equipment and supplies, including PPE and ventilators

1. Who decided what was needed, what should be paid and who the providers should be and what was the basis for those decisions? 
2. What was done to ensure those contracted to acquire PPE and ventilators would procure high enough quality products and at a cost effective price?
3. Why were ventilators removed from private hospitals such that they were separated from the anaesthetists who could have made good use of them?

The development, *prioritisation* and delivery of therapeutics for *both early and hospital treatment*, and vaccines, *including assessment of their safety and efficacy*

1. Why was vaccination prioritised over developing and delivering effective treatment protocols? 

1. How did the prospect of potential profits from the vaccine impact on influence being brought to bear on governments, to ensure they decided not to use safe readily available repurposed drugs early in the pandemic? 
2. Did Government acquiesce to such tactics because they also supported their overarching narrative that a deadly pandemic justified locking down until a state-delivered vaccine programme could deliver freedom? 

2. Why was early treatment given such a low priority as a public health response? 
   • Why was evidence of successful early treatments censored and suppressed? 
   • How many lives could have been saved if there had been a concerted effort to find early treatments? 
   • Which early treatments are effective?
3. Why was hydroxychloroquine dismissed on the basis of the RECOVERY trial despite an unusually high dose being used in a frail population with inevitable associated toxicity?
4. Why was Remdesivir promoted even after evidence emerged of its toxicity?
5. Why was Budesonide recommended as an early treatment after the PRINCIPLE trial for a period, before doctors were stopped from prescribing it?
6. Who decided that novel gene therapy products should be called ‘vaccines’ such that they secured the cachet accorded to effective vaccines, leading to certain pre-clinical safety testing, which would otherwise be required (eg teratogenicity) being waived? 
7. What effect has problems with the Covid vaccines had on existing vaccination programmes? 
8. Why was vaccination recommended for those who had already had Covid-19, contrary to centuries of clinical evidence?
9. Why did the JCVI decide to roll out the vaccine to ever younger groups? In particular:
   • Were the decisions made in the best interests of children and what political  pressure was placed on the JCVI when making these decisions? 
   • Why did the JCVI pass decisions on children’s vaccine roll out to the chief medical officers and why did the CMOs rely on dubious modelling (ignoring time lost due to taking the vaccine and subsequent side effects), focusing on potential school absence, to justify vaccinating healthy children? 

The consequences of the pandemic *and policy* on provision for non-COVID related conditions and needs, *including the causes of reduced provision of GP and hospital care, use of Do Not Resuscitate orders and restrictions on access for certain groups, the particular effects on cancer care, emergency care, children’s care and the impacts of policy on the doctor-patient relationship*

1. Why was provision of non-Covid healthcare reduced? In particular what effects did the following factors have:
   • the refusal to see patients with a cough or fever 
   • people being too frightened to access healthcare 
   • a ban on hospital visitors 
   • planned reductions in particular services
2. How was the Government decision to request blanket Do Not Resuscitate orders for the old and those with learning difficulties justified? Who approved this policy?
3. Why were GPs asked to provide ambulance crews with lists of people they should not take to hospital under any circumstances? Who approved this policy?
4. Did GPs prioritise their own safety over the needs of their patients? 
5. An investigation of hospital capacity should include:
   • How much did the requirements to separate confirmed Covid patients, suspected Covid patients and non-Covid patients affect hospital bed capacity? 
   • Why were patients who were ready for discharge kept in hospital simply because they, or a neighbouring patient, had tested positive, even where it was safe to do so, e.g. they lived alone? 
   • Why were theatre lists kept below capacity simply because alternative patients, who needed urgent surgery, had not been asked to  isolate in case gaps appeared?
   • Could isolation and testing rules for staff have been rationalised to minimise disruption to care? 
6. Why was mask wearing so ubiquitous in healthcare settings (even to this day) and what impact has that had on communication and the doctor patient relationship? 
7. Why were masks and restriction of family visitors ever implemented in children’s wards?
8. What have been and will be the short, medium and long term consequences of cancelling cancer screening, chemotherapy and cancer surgery?
9. What has been the consequence on the health of the nation of banning visitors from hospitals? In particular, who approved the policy that families could not visit their dying relatives?
10. Have government and ‘authorities’ undermined and weakened the role of the doctor, patient confidentiality and the doctor-patient relationship?

*The extent of and* provision for those experiencing long-COVID

1. What was the prevalence of long-Covid compared to previous post-viral illnesses?
2. How much was the extent of “long-Covid” exaggerated, by including symptoms that were also present in the uninfected and could be attributed to the result of lockdown policy, rather than Covid infection? 
3. Why was data on those who had not recovered their taste or smell used to exaggerate the frequency of long-Covid? 

Question 2:

Which issues or topics do you think the Inquiry should look at first?

The Public Inquiry should prioritise those areas in which its actions might halt further damage to people, society, or the economy by the Government’s response to covid. 

We would therefore cite the following nine priorities for investigation as their early outcome may arrest further harm done:

1. Lack of early treatment protocols two years after the start of the pandemic and the suppression evidence on successful treatments
2. Harm caused by policy, especially to children, to highlight areas where remedial action is needed and to prevent further harm and to ensure future policy does not cause further harm.
3. Whether the MHRA and JCVI  have fulfilled their role in protecting the public, particularly children, from harm from the covid vaccines. 
4. Use of professional behavioural psychology techniques and the effects of deliberately stoking fear in the general public, the media and institutions
5. Failure of checks and balances across multiple areas of public and institutional discourse alongside the censorship or suppression of anyone who questioned the official narrative, for example pursuant to Ofcom guidelines
6. Conflicts of interest and perverse incentives – in particular their impact on policy choices
7. Testing strategy and quality and the impact that has had on the pandemic
8. The impact of Government and local hospital policies on non-covid healthcare provision
9. Continuing restrictions on care homes

Question 3:

How should the Inquiry be designed and run to ensure that bereaved people or those who have suffered serious harm or hardship as a result of the pandemic have their voices heard?

Victims’ voices must be heard, but the pandemic, and worse the government’s response to the pandemic, touched all 70 million of us, and very few were beneficiaries. The voices of the bereaved should include not only those bereaved after covid attributed deaths but also those whose loved ones died as a result of policy including post vaccine fatalities. The award for legal expenses for those believed to have been bereaved from covid deaths should be expanded to those bereaved as a result of policy of vaccine fatality.

The PI could sit for a decade listening to victim testimonies and have no hope of providing one on one catharsis for us all, whilst never getting to the important business of ensuring mistakes are not repeated, errors are sanctioned, and the country can move on as Sweden has, having already completed its public inquiry. So for the vast majority of victims, clearly another approach must be found.

We would suggest a national website where victims can upload materials – video testimonies, photographs, narratives of their experiences such that large numbers of victims will feel heard and have their experiences formally recorded.