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Patti Carroll
*OAH_RuleComments.OAH
FW: Immunization Rules docket # 8-0900-30570
Tuesday, July 16, 2013 11:49:25 AM
Judge Eric Lipman-MDH.pdf
With correct docket number!
>
> Office of Administrative Hearings:
>
> Dear Sirs:
>
> Please find my letter and comments attached hereto concerning the proposed rule
changes by the Minnesota Department of Health (MDH) hearings due by 4:30 P.M., July
17th, 2013.
>
> Thank You,
>
> Representative Jerry Hertaus
>
Jerry Hertaus
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State Representative
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District 33A
Hennepin County
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Representatives
COMMITTEES: EDUCATION FINANCE
HOUSING FINANCE AND POLICY
Monday, July 15,2013
PROPERTY AND LOCAL TAX DIVISION
Honorable Judge Eric Lipman
600 North Robert Street
St. Paul, Minnesota 55164
Re: Immunization Rules Docket# 0900-30570
Dear Honorable Judge Lipman,
I am writing on behalf of all Minnesotan's concerning the Minnesota Department of Health (MDH)
proposal to require, modify and increase the number of vaccines administered to our children in excess
of the current established vaccination regime.
New vaccines proposed to be added to the current vaccination regimen include:
•
Hepatitis B and Hepatitis A for infants in child care;
•
Meningococcal and Pertussis vaccines for f1 graders;
•
Chickenpox vaccine at an earlier age.
Of special concern should be the compounding of vaccinations or piggyback administration of multiple
vaccinations administered at one time, especially with regard to infants and small children. Most
medication dosing is prescribed with body mass in kilograms (kg), yet vaccinations often unlike
medications are not. Infants weighing only 2-1/2 to 3 kilos are at greater risk of toxicity than older and
larger children (20-30 kilos) and adults (80-100 kilos). Infants and children already receive as many as 69
doses of vaccines, which interaction among the various vaccines has not received adequate study.
Our society, which is the most vaccinated in the world is also experiencing the highest rates of autoimmune disorders, autism, ADHD and other health anomalies and disorders in our youngest
populations.
Of special concern should be the overlying question of whether or not the spread and control of
infectious diseases is now currently being adequately controlled? Is there a public health crisis that
demands or justifies the addition of these additional mandatory vaccinations?
8055 Davis St., Greenfield, Minnesota 55357
State Office Building. 100 Rev Dr Martin Luther King Jr Blvd. St. Paul. Minnesota 55155-1298
FAX: (651)296-5378 Email: [email protected]
(763) 477-6950
(651)296-9188
Hepatitis B is of very little risk to infants and children as it is only transmitted by direct protein to
protein contact such as through blood, semen or other significant body fluid contact. Hepatitis B is rarely
found in infants unless the mother is infected prior to childbirth and then the infant is treated if tested
positive for the disease. Children and infants cannot spread Hepatitis B through common transmission
vectors such as coughing, sneezing or sharing of drinking glasses or oral contact with toys. In Minnesota,
only about one (1) in 10,000 children ages 0-4 have tested positive for Hepatitis B or in other words
10,000 vaccinations would have to be administered to prevent one (1) case of infant-child Hepatitis B.
Hepatitis B is primarily an adult transmitted infection through both heterosexual and homosexual
intercourse, including drug abuse by sharing of needles, people who have clotting disorders and people
working with non-human primates.
Chickenpox is considered to be a relatively harmless childhood disease. Every year millions of cases
occur with minor symptoms the last for only a few days. Yet only 50 deaths on average occur from
chickenpox related complications, many of which are adults with weakened immune systems whom
never had chickenpox as a child. But on the other hand, there are approximately 67.5 cases per 100,000
vaccinations of complications documented by both the FDA and CDC with severe adverse reactions
including neurological disorders, immune system damage, blood disorders, brain inflammation, seizures
and death.
Meningoccal Disease is not an epidemic in Minnesota or elsewhere in the nation. During the period
between 2004-2011 no deaths occurred in 11-22 year olds including the year before the vaccine was
licensed (One nineteen year old who had been vaccinated and one seventeen year old both died by
strains not covered by the vaccine). Yet, the Vaccine Injury Compensation Program compensated
individuals for multiple complications following vaccinations. Further, evidence indicates that the
benefits of the vaccine wane within 2-5 years from the time of vaccination.
In conclusion, although the federal Advisory Committee on Immunization Policy (ACIP) may make
recommendations from time to time to MDH, it should be noted that many of the members of the
committee have ties to the pharmaceutical industry. In Minnesota, we should only make decisions on
immunization policy based upon the documented known benefits and risks to our citizen population and
not be influenced by any other factors, including conformity with federal recommendations which are
not law. Infants and children have no voice in this matter, but their parents being fully informed, should.
Kind Regards,
Jerry Hertaus, R.N.
Minnesota State Representative