From: To: Subject: Date: Attachments: Jerri Johnson *OAH_RuleComments.OAH Immunization Rules docket 0900-30570 Wednesday, June 26, 2013 1:29:09 PM Hepatitis B vaccine - Not needed, Not reasonable.docx Document on why the hepatitis B vaccine is not needed and is not reasonable. Jerri Johnson Jerri Johnson Public Relations Coordinator National Health Freedom Coalition' 651 688 6515 [email protected] Hepatitis B Vaccine Jerri Johnson, Vaccine Safety Council of MN Requiring hepatitis B vaccine for infants instead of Kindergartners is not needed, and is not reasonable. The Minnesota Department of Health has a goal to stop the transmission of hepatitis B in the state in order to eliminate hepatitis B entirely. This is a noble goal and worthy of much resources to attain. However, even that goal must always be superceded by an even greater goal: the best possible overall health of all people in the state. The goal to eliminate hepatitis B must not be accomplished at the expense of the health of the people. Sometimes focusing on eliminating a specific disease using vaccination results in harming people in the process. Requiring this vaccine is not reasonable because the hepatitis B vaccine carries risk of injury. A vaccine is not a treatment, but a preventive intervention. It could harm healthy people that never would have gotten the disease it intended to prevent. Therefore, it requires a very high standard of safety to utilize. And making it a mandate by the state (even with an exemption option) requires an even higher standard of safety. If the state requires parents to agree to a vaccination unless they utilize exemption, and then the baby is killed or disabled by the vaccine, (when the baby would likely have never been exposed to the disease, especially in childhood) then the state bears responsibility for that death or disability. This is not needed because hepatitis B infection is exceedingly rare in Minnesota infants and preschoolers; the rate of incidence in preschoolers is only 0.01%. One in 10,000 infants in MN contracts the infection, so it would require vaccinating 10,000 babies to prevent one case. Requiring vaccination for all babies in child care is not reasonable, because of the risk of Serious Adverse Reactions to the Vaccine Documented harm from the hepatitis B vaccine The Vaccine Adverse Event Reporting System (VAERS) has been set up by the federal government to receive reports from individuals who believe that a vaccine caused an adverse event. Critics of VAERS data point out that VAERS does not establish causality between a vaccine and a death or injury, but collects reports that may point to causality. But other scientists point out that reports in VAERS usually grossly underestimate vaccine injuries. The CDC has admitted that probably only 5-10% of events are reported because it is a passive reporting system, not required. Parents of vaccine injured children report frequently that their doctor refused to report the injury because of fear of admitting that the vaccine caused harm. And parents usually are not aware they can report it themselves. Reports of harm from hepatitis B vaccine (VAERS) As of March 2012, there were a total of 66,654 hepatitis B vaccine-related adverse events reported to the federal Vaccine Adverse Events Reporting System (VAERS), including reports of headache, irritability, extreme fatigue, brain inflammation, convulsions, rheumatoid arthritis, optic neuritis, multiple sclerosis, lupus, Guillain Barre Syndrome (GBS) and neuropathy. There have been more than 1500 hepatitis B vaccine-related deaths reported, including deaths in infants classified as sudden infant death syndrome (SIDS). [13] http://www.cdc.gov/hepatitis/Statistics/SurveillanceGuidelines.htm VAERS reports on Minnesota children 0 to 5 years of age following hep B vaccine Found 240 events where Age is under-5 and Location is Minnesota and Vaccine is HEP B http://www.medalerts.org/vaersdb/findfield.php?EVENTS=on&PAGENO=2&PERPAGE=10&ESORT=NONE&REVERSESORT=&LOWAGE=%280%29&HIG HAGE=%285%29&WhichAge=range&STATE=%28MN%29&VAX=%28HEP%29 Note: this is about 12 reports per year of adverse reactions to the hepatitis B vaccine in children in Minnesota. That is more than the number of new cases of hepatitis B in children every year in Minnesota. That means that a child is more likely to have an adverse reaction to the hepatitis B vaccine than to contract the disease. Found 90 events requiring Emergency Room Visit http://www.medalerts.org/vaersdb/findfield.php?EVENTS=on&PAGENO=2&PERPAGE=10&ESORT=NONE&REVERSESORT=&LOWAGE=%280%29&HIG HAGE=%285%29&WhichAge=range&STATE=%28MN%29&VAX=%28HEP%29&ER_VISIT=Yes Found 25 events requiring hospitalization http://www.medalerts.org/vaersdb/findfield.php?EVENTS=on&PAGENO=2&PERPAGE=10&ESORT=NONE&REVERSESORT=&LOWAGE=%280%29&HIG HAGE=%285%29&WhichAge=range&STATE=%28MN%29&VAX=%28HEP%29&HOSPITAL=Yes Found 6 events where child died Examples of write-ups on the VAERS reports: (“Days after vaccination: 0” means onset of symptoms on same day as vaccine given) Example of one write-up where a Minnesota baby died the same day as the vaccine was given: Write-up: baby died in car ride home, no preceding symptoms or signs; EMS called @ 942AM Days after vaccination: 0 Write-up: Unresponsiveness in a 9 month old male who received hep B vaccine recombinant (Engerix-B). the vaccinee reportedly was "pale and lifeless, would not respond to us at all" and had a "bright red rash on face." The mother reportedly sought ER attention on 04/29/2002 because of her son''s unresponsiveness. Days after vaccination: 0 Write-up: Child screamed a high pitched squeal, went pale and then a gray/blue color. Was lethargic and glazed over eyes, slow breathing. Called 9-1-1. Took child to Hospital--and they performed every test to rule out everything. (Episode happened again while in Emergency room.) Monitored for 2 days in hospital with cause documented as reaction to immunization shots. Days after vaccination: 0 Write-up: pt recvd vax 31OCT95 & given APAP;630PM mom heard a high pitched weak cry ;pt color was pale ashen & bubbles of saliva noted @ mouth; grunty respiration; lethargic & unresponsive requiring stimulation; to ER Days after vaccination: 0 Write-up: Nurse administered hepatitis B vaccine to baby at 1010 on 4/8/10 -baby developed bilateral pneumothorax, neck swelling. Pt transferred emergently to another facility. Days after vaccination: 0 Write-up: pt recvd 1st dose of Hep B on 9FEB93 & 4 hrs following vax devel apneic episode, limpness & paleness; pt was admitted to a hosp; Days after vaccination: 0 Acute pancreatitis (broad), Pseudomembranous colitis (broad), Gastrointestinal nonspecific symptoms and therapeutic procedures (narrow) Days after vaccination: 0 Write-up: pt seen in clinic in AM & later had apnea, spell & turned blue in face The National Vaccine Injury Compensation Program (NVICP) has compensated many individuals severely injured by the hepatitis B Vaccine The NVICP was set up by the federal government to receive complaints of vaccine injury, investigate to determine whether individuals should be compensated. Unlike the VAERS system, which does not determine causality, this investigation is detailed and strenuous. Multiple court rulings by the Vaccine Court have awarded financial compensation to individuals claiming autoimmune diseases and death following receipt of the hep B vaccine. Diseases included inflammatory disorders of the brain and nervous system, including multiple sclerosis, acute disseminating encephalomyelitis, Guillian Barre’ Syndrome, and other autoimmune diseases such as rheumatoid arthritis, lupus, and fibromyalgia. Claims Filed and Compensated or Dismissed by Vaccine 1 June 4, 2013 Vaccines Listed in Claims as Reported by Petitioners Vaccine(s) Filed Injury DTaP-Hep B-IPV Compensated Death Dismissed Total 30 16 46 23 23 Injuries 535 Deaths 45 Total 580 Compensated 228 Dismissed 352 Hep A- Hep B 9 0 9 8 1 Hep B-HIB 6 0 6 3 3 4,678 6 4,684 4 4.679 11,873 1,042 12,915 3,295 9,620 Hepatitis B (Hep B) Unspecified3 TOTAL 1 The number of claims filed by vaccine as reported by petitioners in claims since the VICP began on October 1, 1988, which have been compensated or dismissed by the U.S. Court of Federal Claims (Court). Claims can be compensated by a settlement between parties or a decision by the Court. 2 Claims filed for vaccines which are not covered under the VICP. 3 Insufficient information submitted to make a determination. The majority of these claims were part of the Omnibus Autism Proceedings. Example of Federal Vaccine Court compensation following death Petitioner has prevailed on the issue of entitlement. The medical records during decedent's final hospitalization reflect that she died from demyelinating disease. Not only did decedent have a vaccine injury, but also her death was vaccine-related. CONCLUSION Petitioner is entitled to reasonable compensation. The undersigned hopes that the parties may reach an amicable settlement and will have a telephonic status conference soon with the parties to discuss further proceedings. http://www.uscfc.uscourts.gov/sites/default/files/MILLMAN.DOE012109B_0.pdf The hepatitis B vaccine has too many documented cases of vaccine injury and death for the State of Minnesota to be requiring it for babies. Clinical Studies Identify Harm from the hepatitis B vaccine A wide variety of neurological and auto-immune disorders, including multiple sclerosis, rheumatoid arthritis, optic neuritis, Bell's Palsy, Guillian-Barre' Syndrome and diabetes, have been reported in peer-reviewed journals following administration of hepatitis B vaccine. Here are just a few: Autoimmune Hazards of the hepatitis B Vaccine A French study looking at research on the hep B vaccine concluded: “According to Hippocratic tradition, the safety level of a preventive medicine must be very high, as it is aimed at protecting people against diseases that they may not contract. This paper points out that information on the safety of hepatitis B vaccine (HBV) is biased as compared to classical requirements of evidence-based medicine (EBM), as exemplified by a documented selectivity in the presentation or even publication of available clinical or epidemiological data. Then, a review is made of data suggesting that HBV is remarkable by the frequency, the severity and the variety of its complications, some of them probably related to a mechanism of molecular mimicry leading to demyelinating diseases, and the others reproducing the spectrum of non-hepatic manifestations of natural hepatitis B. To be explained, this unusual spectrum of toxicity requires additional investigations based upon complete release of available data.” Autoimmunity Reviews 4 (2005) 96– 100 http://www.ncbi.nlm.nih.gov/pubmed/15722255 Marc Girard* 1 bd de la Re´publique 78000-Versailles, France "Recombinant hepatitis B vaccine and risk of multiple sclerosis: a prospective study." A Harvard study found that: When researchers analyzed hepatitis B vaccination statistics from 163 individuals with multiple sclerosis and 1,604 "controls," they found a correlation between getting the hepatitis B vaccine and developing multiple sclerosis. Specifically, the results indicated that the risk of developing multiple sclerosis was three times higher in the group that was vaccinated against hepatitis B than in the group that wasn't vaccinated. Neurology 2004 Sep 14;63(5):838-42 Hepatitis B Immunization Linked to Autoimmune Rheumatic Diseases Two abstracts being presented at the 62nd Annual Meeting of the American College of Rheumatology (held November 8-12, 1998, in San Diego, California) link the development of autoimmune rheumatic diseases to immunization with hepatitis B vaccine. A recently published paper from Canada also links the development of rheumatic diseases to immunization with hepatitis B vaccine. In all cases immunization starting after 2 months of life was associated with autoimmunity while immunization starting at birth has not been linked to the development of autoimmunity. The development of rheumatoid arthritis after recombinant hepatitis B vaccination. OBJECTIVE: Hepatitis B vaccination has been associated with reactive arthritis and rarely rheumatoid arthritis (RA). We defined the clinical, serologic, and immunogenetic background of patients developing RA, soon after recombinant hepatitis B vaccination. CONCLUSION: Recombinant hepatitis B vaccine may trigger the development of RA in MHC class II genetically susceptible individuals. Pope JE, Stevens A, Howson W, Bell DA Department of Medicine, the University of Western Ontario, London, Canada. J Rheumatol 1998 Sep;25(9):1687-93 SEVERE RHEUMATIC DISORDERS ASSOCIATED WITH HEPATITIS B VIRUS (HBV) VACCINATION HBV vaccination may induce hypersensitivity and autoimmune reactions in susceptible individuals and healthy Subjects. Seven patients (4 F, 3 M; mean age 35 ± 10 yrs), developed severe rheumatic disorders after the first (4) or the third (3) injection of HBV vaccine. Before HBV vaccination, one was a healthy subject and 6 were previously suffering from: eosinophilic fasciitis (1), systemic lupus (1), HLA B27 positive axial ankylosing spondylitis (2), sickle cell disease (1) and idiopathic cutaneous urticaria (1). Fourteen days (mean) after vaccine injection, they developed rheumatic disorders including: 3 severe symetric polyarthritis fulfilling ARA RA criteria, associated in one case with vasculitis and 2 monoclonal IgM cryoglobulins. Two cases of oligoarthritis (one associated with palatine and laryngeal oedema, ocular sicca syndrome, hypereosinophilia, positive ANA, and C4 defect), 1 case of Sjögren syndrome, 1 severe systemic flare of lupus with arthritis, pleural effusion, vasculitis and a grade IIIa glomerulonephritis. Conclusion: Hepatitis B virus vaccination may induce severe reactions requiring the use of a long term treatment (mean period of time of 32.5 ± 24.8 months) in healthy subjects and in patients who suffer from autoimmune diseases and from ankylosing spondylitis or reactive arthritis, even if a complete remission has been already obtained. S. Laoussadi, V. Sayag-Boukris, C.-J. Menkes, André Kahan Department of Rheumatology A, Cochin Hospital, Paris V University, Paris, France RHEUMATIC DISORDERS DEVELOPED AFTER HEPATITIS B VACCINATION Aim: to obtain an overview of rheumatic disorders occurring after hepatitis B vaccination. Methods: a questionnaire was sent to rheumatology departments in nine French hospitals. Criteria for entry were rheumatic complaints of one-week duration or more, occurrence during the 2 months following hepatitis B vaccination, no previously diagnosed rheumatic disease, exclusion of bacterial or viral reactive arthritis. Results: 21 patients (18 women, 3 men; mean age = 30.7 years +/- 12.6 SD) were included. All received recombinant hepatitis B vaccine. The time interval between the vaccination and occurrence of complaints was one week or less for 10 patients, between one week and one month for 8 patients, between one and two months for 3 patients. In 9 patients, the next vaccinal dose was inoculated despite the complaints. The symptomatology worsened in 7 cases, and was not modified in one case (effects unknown for the last patient). The observed disorders were as follows: rheumatoid arthritis for 6 patients, systemic lupus erythematosus for 2, reactive arthritis for 5, polyarthralgia-myalgiafatigue for 3, suspected or biopsy-proved vasculitis for 3, miscellaneous for 2. Conclusion: hepatitis B vaccination might be followed by various rheumatic conditions, and might trigger the onset of underlying inflammatory and/or auto-immune rheumatic diseases. However, a causal relation between hepatitis B vaccination and the observed rheumatic manifestations cannot be easily established. Further epidemiological works are needed to establish whether hepatitis B vaccination is associated or not with an incidence of rheumatic disorders higher than normal. J.F. Maillefert1, J. Sibilia2, E. Toussirot3, E. Vignon4, R. Juvin5, C. Piroth1, D. Wendling3, J.L. Kuntz2, C. Tavernier1, P. Gaudin5 Departments of Rheumatology; 1Dijon; 2Strasbourg; 3Besançon; 4Lyon; 5Grenoble, France HepB Vaccine Causes Liver Disease Hepatitis B vaccine and liver problems in U.S. children less than 6 years old, 1993 and 1994: Children given hepatitis B vaccinations are 2.57 times more likely to suffer from liver problems. Abstract: Data to assess the benefits and risks of hepatitis B vaccine for the general population of U.S. children are sparse. This study addressed the problem of external validity found in previous studies of high risk populations by evaluating the benefit of hepatitis B vaccination for the general population of American children. We calculated the risk of liver problems among hepatitis B vaccinated and non-hepatitis B vaccinated children using logistic regression. Hepatitis B vaccinated children had an unadjusted odds ratio of 2.94 and age-adjusted odds ratio of 2.35 for liver problems compared with non-hepatitis B vaccinated children in the 1993 National Health Interview Survey. Hepatitis B vaccinated children had an unadjusted odds ratio of 2.57 and age-adjusted odds ratio of 1.53 for liver problems compared with non-hepatitis B vaccinated children in the 1994 National Health Interview Survey dataset. Epidemiology. 1999 May;10(3):337-9. PMID: 10230847 M A Fisher, S A Eklund Department of Epidemiology, University of Michigan, Ann Arbor 48109, USA. Autoimmunity following Hepatitis B vaccine as part of the spectrum of ‘Autoimmune (Autoinflammatory) Syndrome induced by Adjuvants’ (ASIA): analysis of 93 cases 1. 2. Objectives: In this study we analyzed the clinical and demographic manifestations among patients diagnosed with immune/autoimmune-mediated diseases post-hepatitis B vaccination. We aimed to find common denominators for all patients, regardless of different diagnosed diseases, as well as the correlation to the criteria of Autoimmune (Autoinflammatory) Syndrome induced by Adjuvants (ASIA). Patients and methods: We have retrospectively analyzed the medical records of 114 patients, from different centers in the USA, diagnosed with immune-mediated diseases following immunization with hepatitis-B vaccine (HBVv). All patients in this cohort sought legal consultation. Of these, 93/114 patients diagnosed with disease before applying for legal consultation were included in the study. All medical records were evaluated for demographics, medical history, number of vaccine doses, peri-immunization adverse events and clinical manifestations of diseases. In addition, available blood tests, imaging results, treatments and outcomes were recorded. Signs and symptoms of the different immune-mediated diseases were grouped according to the organ or system involved. ASIA criteria were applied to all patients. 3. 4. Results: The mean age of 93 patients was 26.5 ± 15 years; 69.2% were female and 21% were considered autoimmune susceptible. The mean latency period from the last dose of HBVv and onset of symptoms was 43.2 days. Of note, 47% of patients continued with the immunization program despite experiencing adverse events. Manifestations that were commonly reported included neuro-psychiatric (70%), fatigue (42%) mucocutaneous (30%), musculoskeletal (59%) and gastrointestinal (50%) complaints. Elevated titers of autoantibodies were documented in 80% of sera tested. In this cohort 80/93 patients (86%), comprising 57/59 (96%) adults and 23/34 (68%) children, fulfilled the required criteria for ASIA. Conclusions: Common clinical characteristics were observed among 93 patients diagnosed with immune-mediated conditions post-HBVv, suggesting a common denominator in these diseases. In addition, risk factors such as history of autoimmune diseases and the appearance of adverse event(s) during immunization may serve to predict the risk of post-immunization diseases. The ASIA criteria were found to be very useful among adults with post-vaccination events. The application of the ASIA criteria to pediatric populations requires further study. http://www.ncbi.nlm.nih.gov/pubmed/22235045 Lupus February 2012 vol. 21 no. 2 146-152 The Zabludowicz Center for Autoimmune Diseases, Sheba Medical Center, Tel-Hashomer, Israel Sackler Faculty of Medicine, Tel Aviv University, Tel Aviv, Israel Yehuda Shoenfeld, MD, FRCP, Zabludowicz Center for Autoimmune Diseases, Chaim Sheba Medical Center, TelHashomer 52621, Israel Email: [email protected] 1 2 HEPATITIS B TRIPLE SERIES VACCINE AND DEVELOPMENTAL DISABILITY IN US CHILDREN AGED 1–9 YEARS This study investigated the association between vaccination with the Hepatitis B triple series vaccine prior to 2000 and developmental disability in children aged 1–9 years (n¼1824), proxied by parental report that their child receives early intervention or special education services (EIS). National Health and Nutrition Examination Survey 1999–2000 data were analyzed and adjusted for survey design by Taylor Linearization using SAS version 9.1 software, with SAS callable SUDAAN version 9.0.1. The odds of receiving EIS were approximately nine times as great for vaccinated boys (n¼46) as for unvaccinated boys (n¼7), after adjustment for confounders. This study found statistically significant evidence to suggest that boys in United States who were vaccinated with the triple series Hepatitis B vaccine, during the time period in which vaccines were manufactured with thimerosal, were more susceptible to developmental disability than were unvaccinated boys. Carolyn Gallagher* and Melody Goodman Toxicological & Environmental Chemistry Vol. 90, No. 5, September–October 2008, 997–1008 Given the overwhelming evidence of long-term damage from this vaccine, one wonders how it was ever approved by the FDA. Here’s one answer: The pharmaceutical company making the vaccine did its own safety testing, and it did not follow up its subjects for longer than 5 days. So it made no effort to see whether subjects developed auto-immune diseases over time. No vaccine should be approved, let alone required, until long-term safety studies have been completed. Package inserts for hepatitis B vaccines outline adverse reactions, and show that in the safety studies for FDA approval, individuals were only monitored for 5 days. RECOMBIVAX HB® HEPATITIS B VACCINE (RECOMBINANT) ADVERSE REACTIONS RECOMBIVAX HB and RECOMBIVAX HB Dialysis Formulation are generally well-tolerated. No adverse experiences were reported during clinical trials which could be related to changes in the titers of antibodies to yeast. As with any vaccine, there is the possibility that broad use of the vaccine could reveal adverse reactions not observed in clinical trials. In three clinical studies, 434 doses of RECOMBIVAX HB, 5 mcg, were administered to 147 healthy infants and children (up to 10 years of age) who were monitored for 5 days after each dose. Injection site reactions and systemic complaints were reported following 0.2% and 10.4% of the injections, respectively. The most frequently reported systemic adverse reactions (>1% injections), in decreasing order of frequency, were irritability, fever (≥101°F oral equivalent), diarrhea, fatigue/weakness, diminished appetite, and rhinitis.10 In a study that compared the three-dose regimen (5 mcg) with the two-dose regimen (10 mcg) of RECOMBIVAX HB in adolescents, the overall frequency of adverse reactions was generally similar. In a group of studies, 3258 doses of RECOMBIVAX HB, 10 mcg, were administered to 1252 healthy adults who were monitored for 5 days after each dose. Injection site reactions and systemic complaints were reported following 17% and 15% of the injections, respectively. The following adverse reactions were reported: LOCAL REACTION (INJECTION SITE) Injection site reactions consisting principally of soreness, and including pain, tenderness, pruritus, erythema, ecchymosis, swelling, warmth, and nodule formation. BODY AS A WHOLE The most frequent systemic complaints include fatigue/weakness; headache; fever (≥100°F); and malaise. DIGESTIVE SYSTEM Nausea; and diarrhea RESPIRATORY SYSTEM Pharyngitis; and upper respiratory infection Incidence Less Than 1% of Injections BODY AS A WHOLE Sweating; achiness; sensation of warmth; lightheadedness; chills; and flushing DIGESTIVE SYSTEM Vomiting; abdominal pains/cramps; dyspepsia; and diminished appetite RESPIRATORY SYSTEM Rhinitis; influenza; and cough NERVOUS SYSTEM Vertigo/dizziness; and paresthesia INTEGUMENTARY SYSTEM Pruritus; rash (non-specified); angioedema; and urticaria MUSCULOSKELETAL SYSTEM Arthralgia including monoarticular; myalgia; back pain; neck pain; shoulder pain; and neck stiffness HEMIC/LYMPHATIC SYSTEM Lymphadenopathy PSYCHIATRIC/BEHAVIORAL RECOMBIVAX HB® Hepatitis B Vaccine (Recombinant) 9987435 8 Insomnia/disturbed sleep SPECIAL SENSES Earache UROGENITAL SYSTEM Dysuria CARDIOVASCULAR SYSTEM Hypotension Marketed Experience The following additional adverse reactions have been reported with use of the marketed vaccine. In many instances, the relationship to the vaccine was unclear. Hypersensitivity Anaphylaxis and symptoms of immediate hypersensitivity reactions including rash, pruritus, urticaria, edema, angioedema, dyspnea, chest discomfort, bronchial spasm, palpitation, or symptoms consistent with a hypotensive episode have been reported within the first few hours after vaccination. An apparent hypersensitivity syndrome (serum-sickness-like) of delayed onset has been reported days to weeks after vaccination, including: arthralgia/arthritis (usually transient), fever, and dermatologic reactions such as urticaria, erythema multiforme, ecchymoses and erythema nodosum (see WARNINGS and PRECAUTIONS). Digestive System Elevation of liver enzymes; constipation Nervous System Guillain-Barré Syndrome; multiple sclerosis; exacerbation of multiple sclerosis; myelitis including transverse myelitis; seizure; febrile seizure; peripheral neuropathy including Bell's Palsy; radiculopathy; herpes zoster; migraine; muscle weakness; hypesthesia; encephalitis Integumentary System Stevens-Johnson Syndrome; alopecia; petechiae; eczema Musculoskeletal System Arthritis Pain in extremity Hematologic Increased erythrocyte sedimentation rate; thrombocytopenia Immune System Systemic lupus erythematosus (SLE); lupus-like syndrome; vasculitis; polyarteritis nodosa Psychiatric/Behavioral Irritability; agitation; somnolence Special Senses Optic neuritis; tinnitus; conjunctivitis; visual disturbances; uveitis Cardiovascular System Syncope; tachycardia. Patients, parents and guardians should be instructed to report any serious adverse reactions to their healthcare provider, who in turn should report such events to the U.S. Department of Health and Human Services through the Vaccine Adverse Event Reporting System (VAERS), 1-800-822-7967.31 Engerix 6.2 Postmarketing Experience In addition to reports in clinical trials, worldwide voluntary reports of adverse events received for ENGERIX-B since market introduction (1990) are listed below. This list includes serious adverse events or events which have a suspected causal connection to components of ENGERIX-B. The following adverse events have been identified during postapproval use of ENGERIX-B. Because these events are reported voluntarily from a population of unknown size, it is not always possible to reliably estimate their frequency or establish a causal relationship to the vaccine. Infections and Infestations: Herpes zoster, meningitis. Blood and Lymphatic System Disorders: Thrombocytopenia. Immune System Disorders: Allergic reaction, anaphylactoid reaction, anaphylaxis. An apparent hypersensitivity syndrome (serum sickness-like) of delayed onset has been reported days to weeks after vaccination, including: arthralgia/arthritis (usually transient), fever, and dermatologic reactions such as urticaria, erythema multiforme, ecchymoses, and erythema nodosum. Nervous System Disorders: Encephalitis, encephalopathy, migraine, multiple sclerosis, neuritis, neuropathy including hypoesthesia, paresthesia, Guillain-Barré syndrome and Bell’s palsy, optic neuritis, paralysis, paresis, seizures, syncope, transverse myelitis. Eye Disorders: Conjunctivitis, keratitis, visual disturbances. Ear and Labyrinth Disorders: Earache, tinnitus, vertigo. Cardiac Disorders: Palpitations, tachycardia. Vascular Disorders: Vasculitis. Respiratory, Thoracic and Mediastinal Disorders: Apnea, bronchospasm including asthma-like symptoms. Given the level of harm from this vaccine, it is absolutely unreasonable for the government to require it. A vaccine with this safety profile should never be given without giving parents truthful information on the risks and benefits. But parents are not informed of the true risks of the hepatitis B vaccine Despite the numerous studies documenting harm from this vaccine, and the large number of cases where the Vaccine Court has awarded compensation to individuals harmed or killed by the vaccine, the Vaccine Information Statement (VIS) federally mandated to be given to parents, says: “Hepatitis B is a very safe vaccine. Most people do not have any problems with it. Severe problems are extremely rare.” This is similar to the statement in the MDH SONAR: “Studies have found that the hepatitis B vaccine is safe. It has been in use for over 25 years and few serious side effects have been noted.” This denial of risk to parents renders the exemption meaningless, because parents are not made aware that they should consider an exemption due to possible harm. With the government wanting to require a vaccine with so many documented injuries and deaths, one would think that there must be a severe epidemic threatening a large portion of the population. On the contrary, the disease is extremely rare, can only be spread by contact with blood or bodily fluids, and is declining rapidly. Requiring the hepatitis B vaccine is not needed because the incidence of the disease is so low and is consistently dropping. Incidence of acute hepatitis B (new cases) nation-wide has decreased from a high of 11.5 per hundred thousand population in 1985 to 1.3 per hundred thousand in 2008. Table 1a. Reported number and rate per 100,000 population of cases of acute, symptomatic, viral hepatitis, by type and year, United States, 1966-2008 Hepatitis A Year Hepatitis B No. Hepatitis C No. Rate Rate No. Rate 1985¶ 23257 10.0 26654 11.5 4,192§ 1.8§ 1986¶ 23430 10.0 26107 11.2 3,634§ 1.6§ 1987 25280 10.4 25916 10.7 2,999§ 1.2§ 1988 28507 11.6 23177 9.4 2,619§ 1.1§ 1989 35821 14.4 23419 9.4 2,529§ 1.0§ 1990 31441 12.6 21102 8.5 2,553§ 1.0§ 1991 24378 9.7 18003 7.1 3,582§ 1.4§ 1992 23112 9.1 16126 6.3 6010 2.4 1993 24238 9.4 13361 5.2 4786 1.9 1994 26796 10.3 12517 4.8 4470 1.8 1995 31582 12.0 10805 4.1 4576 1.7 1996 31032 11.7 10637 4.0 3716 1.4 1997 30021 11.2 10416 3.9 3816 1.4 1998 23229 8.6 10258 3.8 3518 1.3 1999 17047 6.3 7694 2.8 3111 1.1 2000 13397 4.8 8036 2.9 3197 1.1 2001 10615 3.7 7844 2.8 1,640** 0.7** 2002 8795 3.1 8064 2.8 1,223 †† 0.5 †† 2003 7653 2.6 7526 2.6 891†† 0.3 †† 2004 5683 1.9 6212 2.1 758 0.3 2005 4488 1.5 5494 1.8 694 0.2 2006 3579 1.2 4,713§§ 1.6§§ 802 0.3 2007¶¶ 2979 1.0 4519 1.5 849 0.3 2008¶¶ 2585 0.9 4,033*** 1.3*** 878*** 0.3 Source: National Notifiable Diseases Surveillance System, 1966-2008. In infants, incidence of hepatitis B is extremely low This chart of acute hepatitis B in the US by age group shows that in 0 – 19 year olds, the rate has essentially been near zero since 2004. And all other age groups have been steadily dropping. NIH reports that the rate of acute hepatitis in children is now 0.1 per 100,000. (0.0001%) http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3290915/ Incidence of hepatitis B has dropped particularly sharply in children Incidence of hepatitis B in the US has dropped precipitously since From 1990 to 2004, and especially in children. “Incidence among children aged <12 years declined 94%, from 1.1 to 0.36 per 100,000 population.” CDC: A comprehensive immunization strategy to eliminate transmission of hepatitis B virus infection in the United States. Recommendations of the Advisory Committee on Immunization Practices (ACIP). Author’s note: 0.36 per 100,000 equals 0.00036% The strategy of testing pregnant women and treating and vaccinating their infants, along with offering voluntary vaccinations to infants, is having spectacular success, and adding a rule to require vaccination is not needed. In Minnesota, a very rare disease is even more rare In Minnesota, rates are some of the lowest in the nation and consistently dropping. Where the national average for acute hepatitis B has dropped from 11.5 per hundred thousand down to 1.3, in Minnesota, our rate has dropped down to 0.4 per hundred thousand in 2010, (almost all of them adults). This is 0.0004% for acute cases. Reported cases of acute hepatitis B, by state ― 2006–2010 (per hundred thousand) State 2006 Rate* 2007 (No.) Rate 2008 (No.) Rate 2009 (No.) Rate 2010 (No.) Rate (No.) Alabama 2.1 (95) 2.8 (128) 2.3 (109) 1.9 (89) 1.4 Alaska 1.2 (8) 1.3 (9) 1.5 (10) 0.6 (4) 0.7 (5) Arizona U† U 1.3 (81) 1.2 (80) 0.6 (42) 0.4 (26) Arkansas 3.1 (87) 2.5 (72) 2.3 (67) 2.2 (65) 2.3 (66) California 1.2 (427) 1.1 (402) 0.8 (303) 0.7 (258) 0.7 (252) Colorado 0.7 (34) 0.7 (35) 0.7 (33) 0.5 (27) 0.9 (46) Connecticut 1.4 (49) 1.1 (38) 0.9 (30) 0.5 (16) 0.6 (22) Delaware 5.5 (47) 1.7 (15) U U U U U U District of Columbia 1.5 (9) U U U U 1.7 (10) 0.5 (3) Florida 2.3 (42)0 1.8 (337) 1.9 (344) 1.6 (299) 1.6 (297) Georgia 2.2 (205) 1.6 (155) 1.9 (187) 1.5 (144) 1.7 (165) Hawaii 0.6 (8) 1.3 (17) 0.5 (7) 0.5 (6) 0.4 (6) Idaho 1 (15) 1 (15) 0.8 (12) 0.7 (11) 0.4 (6) Illinois 1 (132) 1 (129) 1.4 (184) 0.9 (118) 1.1 (135) Indiana 1.3 (80) 1 (64) 1 (67) 1.2 (74) 1.2 (75) Iowa 0.7 (21) 0.9 (26) 0.8 (24) 1.2 (37) 0.5 (15) Kansas 0.4 (11) 0.3 (9) 0.3 (9) 0.2 (6) 0.4 (11) Kentucky 1.6 (69) 1.8 (76) 2.4 (101) 2.1 (90) 3.1 (136) Louisiana 1.5 (63) 2.3 (100) 2.1 (94) 1.6 (73) 1.2 (55) 2 (26) 1.4 (19) 1.1 (15) 1.1 (15) 1.0 (13) Maryland 2.6 (148) 2 (113) 1.5 (85) 1.3 (72) 1.2 (67) Massachusetts 0.3 (19) 0.6 (42) 0.3 (21) 0.3 (17) 0.2 (13) Michigan 1.4 (141) 1.2 (120) 1.5 (149) 1.3 (132) 1.2 (122) Minnesota 0.6 (32) 0.5 (25) 0.5 (25) 0.7 (38) 0.4 (23) Mississippi 0.4 (13) 1.3 (37) 1.7 (50) 1.1 (33) 1.1 (33) Missouri 1.1 (62) 0.7 (39) 0.6 (38) 0.8 (47) 1.1 (67) Montana 0.5 (5) 0.1 (1) 0.2 (2) 0.1 (1) 0 (0) Nebraska 1.1 (20) 0.7 (13) 0.5 (9) 1.2 (22) 0.7 (12) Nevada 1.7 (42) 1.9 (49) 1.6 (43) 1.3 (34) 1.5 (41) New Hampshire 0.8 (11) 0.4 (5) 0.6 (8) 0.5 (6) 0.4 (5) New Jersey 1.9 (164) 1.9 (162) 1.4 (118) 1.1 (93) 0.9 (77) New Mexico 1.2 (24) 0.7 (13) 0.6 (12) 0.4 (8) 0.2 (5) 1 (202) 1.1 (211) 0.9 (173) 0.7 (129) 0.7 (139) North Carolina 1.8 (159) 1.4 (128) 0.9 (81) 1.1 (104) 1.2 (113) North Dakota 0.2 (1) 0.3 (2) 0.3 (2) U U U U Ohio 1.1 (123) 1.1 (124) 1 (118) 0.8 (88) 0.8 (95) Oklahoma 2.7 (96) 4.2 (152) 3.5 (129) 3.3 (122) 3.1 (115) Oregon 2.2 (82) 1.6 (59) 1.1 (41) 1.2 (44) 1.1 (42) Pennsylvania 1.4 (172) 1.5 (188) 1.2 (157) 0.8 (106) 0.6 (72) Rhode Island 1 (11) 1.5 (16) U U U U U U South Carolina 2.2 (97) 1.5 (65) 1.6 (71) 1.2 (56) 1.3 (59) South Dakota 0.6 (5) 0.9 (7) U U 0.5 (4) 0.2 (2) Maine New York (68) Tennessee 2.5 (155) 2.3 (144) 2.4 (149) 2.2 (136) 2.4 (150) Texas 3.6 (833) 3.1 (741) 2.3 (562) 1.7 (420) 1.6 (394) 1 (26) 0.6 (15) 0.5 (14) 0.2 (5) 0.3 (8) 0.6 (4) 0.8 (5) 0.5 (3) U U 0.3 (2) 1 (78) 1.9 (144) 1.7 (130) 1.4 (110) 1.2 (97) Washington 1.2 (74) 1 (65) 0.9 (56) 0.7 (48) 0.7 (50) West Virginia 4.1 (74) 4.5 (82) 4.6 (83) 4.6 (84) 4.7 (88) Wisconsin 0.6 (33) 0.4 (20) 0.3 (18) 0.4 (24) 0.9 (54) Wyoming 0.2 (1) 1 (5) 1.1 (6) 0.7 (4) 0.5 (3) Total 1.6 (4,713) 1.5 (4,519) 1.3 (4,029) 1.1 (3,371) 1.1 (3,350) Utah Vermont Virginia Acute Hepatitis B Statistics in Minnesota Number of Acute Cases per Year, 1998 – 2012 Acute hepatitis B is defined as persons who are symptomatic and newly infected. Year HAV HBV HCV 1998 145 53 19 1999 128 63 25 2000 197 39 13 2001 47 34 20 2002 53 45 10 2003 52 43 16 2004 59 42 16 2005 36 40 12 2006 31 32 11 2007 94 25 28 2008 49 25 22 2009 30 39 15 2010 37 24 15 2011 27 20 18 2012* 29 16 29 * In 2012 the case definition for acute hepatitis B and C changed to include asymptomatic cases with a positive test for hepatitis C six months or less after a negative antibody test (seroconversion). Of the 29 acute hepatitis C cases, six were asymptomatic seroconverters and of the 16 acute hepatitis B cases, two were asymptomatic seroconverters. Hepatitis B in infants in Minnesota, the group affected by the proposed rule Hepatitis B is transmitted only by exchange of bodily fluids such as blood. The disease exists primarily in adults and is transmitted most commonly through sexual contact, through sharing of needles during injected drug use, or in accidental needle sticks in health care workers. Persons with Chronic HBV in MN by Age, 2012 Incidence of chronic hepatitis B infection in children (defined as persons infected for longer than six months) MDH reported that there are actually zero cases of acute hepatitis in Minnesota children and a total of 27 cases of recorded chronic hepatitis in Minnesota children between the ages of 0 and 4. That includes all children who have ever had evidence of infection (they may not be ill or symptomatic, but have had laboratory evidence from blood tests.) Twenty-seven cases in four years equates to an average of 7 cases per year, or 7 cases per birth cohort of 70,000 babies born each year. Seven out of 70,000 is 1 in 10,000, or 0.01% of Minnesota preschoolers that are known to be infected. Minnesota children are already required to receive the hepatitis B vaccine for entrance to Kindergarten and again in 7th grade. So those existing vaccinations are intended to provide protection for the time when they might become sexually active, or use illegal injectable drugs. This new proposed rule is ostensibly to protect children between the time of their birth and entrance to Kindergarten. Yet, in Minnesota, as in the rest of the nation, hepatitis B infection in childhood is so rare as to be nearly zero. Vaccinating Minnesotans in infancy is not needed. Most cases of hepatitis B in children are from perinatal infection (childbirth) Further study of the epidemiology of hepatitis B in infants reveals that the major route for infants to be infected is perinatal infection, or transmission from an infected mother to her baby at childbirth. http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3290915/ Screening of women in pregnancy has been extremely successful. The SONAR statement mentioned that since vaccination for hepatitis B for infants was introduced in 1991, the incidence of the disease in infants has plummeted. But SONAR did not mention that screening of pregnant women for hepatitis B began at nearly the same time - in 1988. Virtually all women receiving medical care in pregnancy are now checked for hep B. If they are found to be positive for HsAg (infected) then their infant, when born, is treated immediately with immunoglobulin, and also receives three doses of hep B vaccine. Once a women has been identified to be positive for hep B, all of her family members and contacts can be tested and treated. This program has proven to be extremely effective, and is stopping the disease at the very place where it is most commonly transmitted to infants. These infants are all retested at 9 to 15 months. Almost all of the children thus treated do not develop hepatitis. A few every year do develop it, and most of the children in the 27 cases of hepatitis in preschoolers come from this group. This paragraph from the MDH Infection Control Newsletter describes the program and the results for 2009: In addition to the 39 hepatitis B cases, 4 perinatal infections were identified in infants who tested positive for HBsAg during post-vaccination screening performed between 9 and 15 months of age. The infants were born in 2008. The perinatal infections were identified through a public health program that works to ensure appropriate prophylactic treatment of infants born to HBV-infected mothers. All four infants were born in the United States and had received hepatitis B immune globulin and 3 doses of hepatitis B vaccine in accordance with the recommended schedule and were therefore considered treatment failures. Despite these treatment failures, the success of the public health prevention program is demonstrated by the fact that an additional 321 infants born to HBV-infected women during 2008 had post-serologic testing demonstrating no infection. This approach, which concentrates on high-risk individuals, is reasonable and is working well. Since the advent in 1988 of comprehensive testing of all pregnant women for HBsAg, including followup of those positive for hep B, and offering post-exposure immunoprophylaxis, as well as in 1991 of offering vaccination of some babies, the incidence of hepatitis B in infants has dropped by 95% and appears to be continuing to drop. These infants make up a major share (at least 15) of the 27 cases counted as chronic hepatitis B in preschoolers. Vaccinating all the healthy babies in Minnesota would not prevent these cases. How many cases in infants would be prevented by this rule? In the last four years of statistics in Minnesota infants thus treated, at least 15 were known to be perinatal cases. So out of 27 current preschoolers with chronic hep B, 15 were detected at birth, treated, and vaccinated. That leaves 12 cases in four years, or about 3 cases per year, of unknown origin of infection. So with an estimated 280,000 preschoolers age 0 – 4, there are 12 or fewer total cases (3 per year) where the infection was not from birth, not identified right away. The MDH goal of vaccinating all infants in order to wipe out transmission of hepatitis B would require vaccinating 70,000 children every year to prevent 3 cases, or vaccinating 23,000 children to prevent each case. This is not a reasonable or needed strategy, especially given that those 69,997 children that would not be exposed would be put at risk of injury from the vaccine. Requiring the hepatitis B vaccine is not needed because the incidence is so low, and is already declining significantly. Strategies to eliminate this disease are working. The existence of an exemption option in MN does not justify requiring any and all vaccines One could argue that because Minnesota has exemption available to parents, then it is reasonable to require a vaccine if there is any need. But using this argument, one could impose any vaccine requirement desired on the populace, even if there is little to any occurrence of a disease, and even if the vaccine clearly causes a severe risk of injury to a high percentage of recipients. So the existence of an exemption can not justify adding any and all vaccines to the immunization schedule. Consideration must be given to the actual need for the intervention, safety of the vaccine, and the risk/benefit ratio. In the case of this disease, the risk of harm from the vaccine may be greater than the risk of contracting the disease. The exemption option becomes meaningless if parents have not been truthfully informed of the actual risks of the vaccine. The Vaccine Information Statement (VIS) federally mandated to be given to parents, says only: “Hepatitis B is a very safe vaccine. Most people do not have any problems with it. The vaccine contains non-infectious material, and cannot cause hepatitis B infection. Some mild problems have been reported: • Soreness where the shot was given (up to about 1 person in 4). • Temperature of 99.9°F or higher (up to about 1 person in 15). Severe problems are extremely rare. Severe allergic reactions are believed to occur about once in 1.1 million doses. A vaccine, like any medicine, could cause a serious reaction. But the risk of a vaccine causing serious harm, or death, is extremely small.” Parents of vaccine-injured children often comment that they were led to believe that no serious harm would come, nothing worse than a fever and sore arm, from a vaccine. If the government requires a dangerous vaccine, while denying its danger, it is betraying the trust of its citizens, and bears responsibility for the devastation that is caused in many lives. Reasonable strategies instead of requiring the hepatitis B vaccine Current strategy is working. Incidence of hepatitis B has been reduced by 95% and is still dropping. Automatically exempt from vaccination requirements all babies born to mothers who tested negative in pregnancy. Many leading European countries do not require hepatitis B vaccine for all infants, even though it has been available for 18 years. • • • • • Finland: “Hepatitis B vaccine is given only to infants of HbsAg carrier mothers or fathers at the age of 0, 1, 2 and 12 months.” Denmark: “Vaccination against hepatitis B is recommended to children of HBsAg-positive mothers starting at birth with both hepatitis B immunoglobulin and one dose of HepB.” Norway: “HepB is recommended for risk groups only.” Sweden: “HepB is only recommended to children considered high-risk groups. Vaccination is given at birth to infants of mothers positive for hepatitis B.” The Netherlands: “Only for children born to HBsAg positive mothers.” Continue to screen pregnant women and follow up with their infants and all close contacts. Continue to focus on the adult groups where transmission is highest. Summary The goal to eliminate a particular infectious disease must not be pursued at the expense of causing chronic disease in the population. The standard of safety for a preventive medical procedure must be extremely high. For the state to require it, it must be even higher. The state should not require any vaccine until it has been tested against a placebo group with no vaccine (in most studies the placebo is a different vaccine), the subjects are followed long –term to observe for chronic disease (not done except in very small numbers), and the data from the original large scale safety studies are made available to the public. The hepatitis B vaccine does not meet this standard of safety. On the contrary, there is voluminous evidence that it has harmed many people. Vaccination of all infants with hepatitis B vaccine is unreasonable because the documentation of risk of death and chronic disease and disability from the vaccine is clear. In the case of this disease, the risk of harm from the vaccine may be greater than the risk of contracting the disease. Vaccination of all infants for hepatitis B is not needed because incidence in infants and children is extremely low, and incidence in babies is primarily from perinatal (birth) infection, which is already being detected and treated at birth. As shown above, it would be required to vaccinate 23,000 babies to prevent each case of chronic hepatitis in infants. We already have in place an effective tool for addressing this transmission and it is working well: all mothers are tested for hepatitis B in pregnancy. If the mother is infected, then her baby is given immunoglobulin and hepatitis B vaccine at birth. Families and close contacts are notified and offered vaccination. This approach is extremely effective, and efficiently targets the primary mode of transmission of hepatitis B to infants in Minnesota. Since the introduction of this program, and at the same time, offering hepatitis B vaccine to infants (parents) on a voluntary basis, the incidence of hepatitis B in small children has declined by 94% and it is continuing to drop every year. It is not reasonable to require hepatitis B vaccine for babies whose mothers tested negative for hepatitis B in pregnancy All pregnant women are tested for hepatitis B in pregnancy. It is not reasonable to require a mother who already tested negative for hepatitis B during pregnancy to submit her infant to the risk of a hepatitis B vaccine because: We know her baby was not exposed to hepatitis B in childbirth. We know her baby’s chances of being exposed to hepatitis B until old enough to engage in adult risky behavior of sexuality or drug use are miniscule The Hep B vaccine is well-documented to have adverse, including death. The parents have not been truthfully informed of the actual risks of the vaccine and so the exemption is meaningless. In an effort to eliminate an infectious disease, we are creating chronic diseases in our children. Health care should be individualized to meet the needs of each patient. Public health programs, on the other hand, target epidemics, or diseases. Their goal is to eliminate a disease. The SONAR stated, “If we continue with this strategy, we have a chance of eliminating or greatly reducing the incidence of this disease in the United States in one or two generations.” Unfortunately, in order to do so, it may require seriously harming some individuals. We should not put at risk hundreds of thousands of children who are never going to be exposed to this disease. It is absolutely unreasonable for the State of MN to require this vaccine under the above circumstances.
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