HOCl Trust and the UK Covid Inquiry: Our submission
Re: UK Covid-19 Inquiry, a submission from the HOCl Trust
17th October 2023
Introduction to the HOCl Trust for Hygiene and Safer Water
The HOCl Trust for Hygiene and Safer Water was established in 2016 to promote and raise awareness of the antimicrobial effectiveness, safety and cost benefits of using hypochlorous acid, or HOCl, in human health care, food protection, and a variety of associated applications.
HOCl Trust Submission to the Covid inquiry: Summary
The Trust believes that due to the decision taken by the Government and its regulatory agencies to omit HOCl in public health care protocols, in particular for the limitation of virus spread, there continues to be a risk of harmful effects from transmissible human pathogens.
Background
Hypochlorous acid (HOCl)
HOCl is readily available in various forms and is most commonly used as a sanitising agent. HOCl occurs naturally, and is a critical component in the normal functioning of our immune system. One consequence of this is that HOCl is commercially unattractive as patents cannot be awarded for naturally-occurring molecules. Furthermore, being a very small molecule, with only three constituent atoms, enhancement and refinement of its properties and activity cannot be done. This is in contrast to the far larger and more complex molecules of organic-based chemicals found in nature that can be ‘fine-tuned’ by targeted molecular manipulation for the improvement of desirable properties. As a result, and in contrast to HOCl, they become eligible for patenting with consequent intellectual protection and potential for profitable economic return.
Outside the living body HOCl synthesis can be achieved in a number of ways, all of which require relatively simple and low-cost technologies. HOCl can even be made in domestic situations using cheap and readily available equipment.
HOCl and the pharmaceutical industry
Such well-established production technologies, together with low manufacturing costs add to the difficulties in patent protection and create even more barriers to economic exploitation of its capacity to protect people from infection by pathogenic organisms.
In the absence of profit potential there is consequently a complete lack of interest from the pharmaceutical industry. As a result of this, significant investment in the development, testing, trialling and promotion of the molecule has never been undertaken.
Some success was achieved by specialist companies in the highly effective use of HOCl in the processing of endoscopes1, decontamination of equipment in dental clinics2, and the maintenance of hygienic conditions in fresh produce supply in the United States3.
Confusion with bleach
HOCl is confused with the commonly used disinfectant referred to as ‘bleach’. However bleach is formulated as a highly alkaline solution and carries a severe risk of corrosion and damage to skin and epithelial surfaces of the body. HOCl (which exists only in aqueous solution), is only slightly acidic and carries no such risks and at typical concentrations of use, poses no risk whatsoever to humans or the environment. Despite this very clear difference the properties of HOCl are frequently assumed to be the same as bleach and HOCl has become associated with the potential serious harmful effects of such strong alkaline solutions4.
This misconception has hindered the adoption of HOCl as a safe and highly effective public health protection agent.
Advocacy
The indifference of the pharmaceutical industrial sector to HOCl led to it being manufactured, marketed and promoted by smaller companies and entrepreneurs keen to exploit the effectiveness of their products. Sadly in many cases companies in their pursuit of short term profit have not always been responsible in their exploitation of HOCl and have failed to ensure sound business and science-based practice. Consequently the reputation of the molecule has been severely damaged.
There has also been significant resistance by major industrial companies to the use of HOCl in seeking to protect the market for their profitable disinfection products.
It is the mission of the HOCl Trust to overcome these barriers to its use and promote the standing of HOCl, particularly to augment and support existing public health practices.
Evidence for the effectiveness of HOCl
A very large body of evidence has accumulated over the recent decades, largely from numerous independent companies, research organisations and academic institutions that provide overwhelming proof of the safe and highly effective use of HOCl in a wide variety of applications, and through a variety of delivery systems, both as an antimicrobial and most significantly as an anti-viral agent.
Actions by the HOCl Trust during the Covid 19 pandemic: a summary
Please note that on March 6th 2020 the WHO listed HOCl in the form of NaDCC granules as a critical commodity (together with scrubs, visors, goggles and alcohol hand rub) for the purpose of PPE in health care facilities in the face of Covid-19.
27th May 2020 In an attempt to enhance availability of HOCl generating product the HOCl Trust contacted NHS supply chain to advise them that they already had suitable HOCl products listed. The trust was advised that NHS Trusts were independently responsible for purchasing.
11th June 2020 The HOCl Trust contacted NHS England and NHS Improvement to bring to their attention the unique properties of the HOCl molecule for virus and pathogen control. Covid-19 Re-use Sprint Team responded with a data request.
17th June 2020 The HOCl Trust sent a data package that addressed all relevant aspects of HOCl use for virus contagion control, including SARS-CoV-2.
19th June 2020 NHS Improvement asked for further testing, but without any protocols being referenced.
1st July 2020 After pressing for protocols the NHS would accept so that the HOCl Trust could commission the testing independently to speed things up, a senior manager from NHS England & NHS Improvement got in touch with a dismissive and very brief communication, as below.
“From what I understand, some testing of HOCl has been undertaken by another government department which found it was not effective against the virus pathogens. However I have not seen the results of this testing.”
16th November 2020 A Senior Policy Advisor, PPE Reuse Innovation and Sustainability, got back to us to tell us to get in contact with the Health and Safety Executive.
The Trust had not been the only people to try and persuade government and the NHS to employ HOCl to combat SARS-CoV-2, we were contacted by numerous manufacturers and representatives of the industry, who had all been ignored, or passed from pillar to post in their attempts to have HOCl taken seriously, and all failed, despite grabbing the attention of decision makers.
The opportunity to utilise an effective technology for virus pathogen control was thereby lost, and most likely resulted in putting the public at greater risk of infection, as the HOCl Trust tried to publicise in the news media.5
It is clear that while there might have been good intent, the departments we dealt with failed to review the matter thoroughly and obfuscated the issue by passing responsibly between two agencies. There was clearly a failure of decision at a critical level and time.
Opportunities for anti-virus use of HOCl will continue to be available and we would welcome government agencies to engage with us to review future responses to contagion control.
Conclusions
- HOCl is a proven highly effective and safe anti-viral agent of an appropriate nature to be effectively incorporated into public health actions to curb the impact of virus spread.
- The HOCl Trust made considerable efforts to persuade health and regulatory authorities of the merits and potential benefits of HOCl use.
- The Trust was frustrated in its efforts to support initiatives to limit the impact of the virus by using HOCl due to a lack of any positive response from government or associated agencies.
- Government and regulatory authority unresponsiveness resulted in the imperative opportunity to aid in the control of SARS-CoV-2 spread being lost.
- We believe the unique properties and characteristics of this molecule will continue to be underexploited, despite its considerable potential to disrupt and limit virus contagion, if the government persists in its dismissal and rejection of HOCl as a safe and effective tool in public health protection.
The HOCl Trust welcomes a response from the Inquiry and anticipates an opportunity to contribute further.
This communication will be published on the Trust website.
Hugh Martin BSc (Hons), MSc, DIC, PhD
On behalf of the HOCl Trust - for Hygiene & Safer Water