SUBJECT: THE NEW RESTRICTIVE MEASURES PROPOSALS REGARDING COVID-19

SUBJECT: Your letter of 31.08.2021 in connection with the Proposals of the Chief State Health Inspector for the introduction of new restrictive measures on the territory of the country in connection with COVID-19

DEAR MR MINISTER,

In connection with your letter of 31.08.2021, the Bulgarian Industrial Association (BIA) gathered the positions and proposals of its member industry organizations from the sectors that are mostly affected by the restrictions- tourism and restaurants, fitnesses and spas, branches with activities in culture, trade, congress and exhibitions. 

Employers in all the listed sectors understand the current situation regarding the spread of COVID-19 and the need to take preventive measures. In addition, they generally agree that the measures should be:

1. well justified in terms of their potential effectiveness.
2. non-discriminatory towards individual economic operators and/or their customers.
3. accompanied by appropriate compensation for financial damage.

Concerning justification:

The measures need to be based on an analysis and assessment of the effect of the general anti-epidemic measures applied in the previous periods. Unfortunately, such an analysis is missing, also in the "Analytical report prepared by the Ministry of Health for the activities related to public health services in response to the pandemic of COVID-19 for March 1, 2020 - May 31, 2021." Section 9 of the cited Analytical report only describes a chronology of the anti-epidemic measures introduced in the respective period, the performed inspections, and the established violations. The paper does not provide data on the effect of the actions in the current periods, incl—the morbidity rate, hospitalizations, mortality, personal and collective immunity. There is also no analysis of the effect of such measures in the international realm, incl. the impact of the vaccination, the obligatory masks, lockdowns, etc., on the population's health status, and the functioning of the health systems. Without such an analysis, the introduction of any measures is unjustified and with unproven effect. The only proven effect so far is the negative economic one!

Concerning non-discrimination:

The percentage of vaccinated workers and/or clients is discriminatory and has no objective bearing on the epidemic picture. The only effect would be to increase the vaccination rate, which should be a commitment of the health authorities. Transferring this responsibility to the economic operators is incorrect and harmful! The individual right of each citizen to decide on their health should be respected, especially when they are required to sign an informed consent! In essence, the proposal for full retention of economic activity with 100% vaccinated staff means that employers coerce their employees to take action for which the decision is their right. Last but not least, the question is to what extent it is legal and moral to require customers to provide information about their health status.

Regarding the compensation mechanisms:

Practice so far shows that the measures discuss rather than effectively support businesses whose activities are severely or completely limited due to circumstances beyond their control. In 2020 we witnessed how it took more than six months after the pandemic outbreak to formulate business support mechanisms and at least another six months for the mechanisms in question to start working effectively. Thousands of economic operators continue to experience difficulties recovering from previous shutdowns and are now informed that they need to close again. The topic of compensatory mechanisms is again in the realm of probabilities and conversations. Moreover, the issue is highly dependent on the update of the State Budget of the Republic of Bulgaria! With all this ambiguity, the introduction of urgent radical restrictions is unjustified!

In connection with all the above, we insist on precise mechanisms for compensation of the affected businesses and an analysis and evaluation of the effectiveness of the anti-epidemic measures before introducing any restrictions.

WITH RESPECT,

DOBRI MITREV

Secretary-General of BIA