Virginia Regulatory Town Hall
Virginia Department of Health
State Board of Health
Regulations for the Immunization of School Children [12 VAC 5 ‑ 110]
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11/28/22  7:13 pm
Commenter: Jennifer F.

Please Repeal this Regulation


As you likely well know, all pharmaceutical products--including immunizations--carry risk, and that risk varies from person to person, depending upon their individual make-up and health status. (The ever-increasing instances of serious adverse reactions to immunizations serves as testament to the existence of this risk.) Where there is risk, there must be choice; and, where there is choice, there must be fully informed consent.

If we accept the premise that we all have a right to bodily integrity (acknowledged worldwide as a basic human right), then immunizations absolutely must be voluntary. Consequently, mandating that all children be required to follow the immunization schedule--a schedule that is merely recommended by the U.S. Centers for Disease Control and Prevention (CDC)--violates that very basic human right. Moreover, mandating (i.e., coercing) such action, e.g., in order to attend school, precludes (by its very nature) informed consent.

The limited and narrowly-define exemptions in the current regulations do not change that fact. Mandating immunizations for school children is coercing them and their parents/guardians into accepting a medical intervention in order to attend school or day care under the guise of public health (and rarely with fully informed consent). That is a violation of the basic human right of bodily integrity. 

While we ought to be able to count on the CDC as well as other agencies responsible for protecting public health and and for public health regulation, a review of their history shows that we cannot; indeed, it paints a very different picture--one of politicization, corruption, and regulatory "capture" (REF a multitude of financial conflicts of interest at these agencies with the pharmaceutical industry, for one). Indeed, the influence of the pharmaceutical industry over the CDC and other agencies is more than significant enough to demonstrate that these agencies cannot possibly be honest brokers with regard to the immunization schedule, among other things.

With regard to the specific points to be addressed in your review:

-if the regulation were necessary for the protection of public health, safety, and welfare, there would be no exemptions, and there would be evidence to support the impact; besides, whom are we relying upon to determine this?

-whether the regulation is necessary for the "economical performance of important government functions" does not seem pertinent to immunizations (though I would be interested in hearing any arguments on this point);

-whether the regulation "minimizes the economic impact on small businesses in a manner consistent with the stated objectives of applicable law" is lost on me (though I would be interested in hearing any arguments as to how this is relevant to childhood immunizations);

-lastly, I agree that the regulation "is clearly written and easily understandable" albeit inappropriate.

For all the reasons stated above, I urge you to REPEAL THIS REGULATION!


CommentID: 206341