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Welsh hospitals face being under the highest state of pressure for almost a third of a year, the Conservatives have said.
Health boards have four levels of how much pressure emergency services are under and how hospitals should respond.
13 hospitals in six of the seven health boards could not cope with demand for 107 days on average last year.
The Tories said a letter from Vaughan Gething, Welsh Health Secretary, revealed the figures.
Darren Millar, Clwyd West AM, called the figures ‘truly alarming’ and warned that the health service was operating in a ‘near-permanent state of emergency’.
Angela Burns, shadow health secretary, said: “Having to operate at such an intensity for protracted periods is neither safe for patients nor fair to staff, many of whom are close to breaking point.”
A Welsh government spokesperson said: “We have been open about the challenges that NHS Wales and emergency departments are under, this is not unique to Wales.
"The escalation levels are not designed as a performance measure, they are an internal management tool to aid the management of patients through the hospital system and the levels change throughout a day.
"We are not complacent and are acutely aware the situation could escalate again very quickly, in particular, as a result of the combined effect of flu and cold weather."