From:
To:
Subject:
Date:
Attachments:
Paul G King
*OAH_RuleComments.OAH
Docket# 8-0900-30570
Wednesday, July 17, 2013 12:30:39 PM
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File 1 DrftRevu_Anti_vaccineMovementCausesTheWorstWhoopingCoughEpidemicIn70Yrs.pdf
File 2 Vaccines_The_Safest_of_Medicines_or_the_Biggest_Lie.pdf
Honorable Judge Eric L. Lipman - Assistant Chief Administrative Law Judge
Having been asked to comment on the adding of more vaccines and/or vaccine doses to the
mandated childhood vaccination schedule for Minnesota children, I offer the following comments
as a published scientist who has been in the in-depth study of vaccines, vaccine effectiveness and
vaccine cost effectiveness since the late 1990s.
My credentials and a list of published articles open to peer-review and/or peer-reviewed in journal
publications that are pertinent to the issues at hand, including science-based position essays on
vaccine issues and vaccine realities are published or listed on my Internet web site, http://drking.com in the "Credentials" web page and "PUBLICATIONS(by year)" section of the
"Documents" web page, respectively.
My most recent pertinent peer-reviewed publication is an "Open Access" review article was with
Gary S. Goldman, PhD, a recognized expert in the study of the epidemiology of infection by the
varicella zoster virus (VZV) in the world-renowned journal Vaccine, "Goldman GS, King PG.
Review of the United States universal varicella vaccination program: Herpes zoster incidence
rates, cost effectiveness, and vaccine efficacy based primarily on the Antelope Valley Varicella
Active Surveillance Project data. Vaccine 2013 March 25; 31(13): 1680-1684", which clearly
established that the U.S. national childhood vaccination program for variacella (chickenpox) is a
costly failure that exacerbates the recurrence of the infective alpha-herpes varicella zoster virus
(commonly referred to as the VZV apparently to conceal the reality that it is a herpes virus),
whether it is the vaccine-strain with which the vaccinated children are inoculated or some "wild"
strain acquired naturally, as "shingles".
1.
Regarding a "hepatitis A" vaccination mandate, there is no evidence that such a program is necessary especially for children under the age of 15 years and, the costs of such vaccination
program appear to greatly exceed the costs of the diseases cases, if any, prevented by the
hepatitis A vaccination program (see the supporting information following the body of this email). 2.
Based on the recent findings of significant liver toxicity caused by the hepatitis B vaccine and the lack of persistent protection from hepatitis B as well as the serious levels of adverse reactions cited in comparative studies, the current childhood hepatitis B vaccination program should be abandoned.
3.
The reality, as supported in detail by the attached review (see attached File 1 ...), that the current pertussis component in the diphtheria, tetanus, pertussis vaccine: a) does not protect the vaccinated child from subsequently contracting "whooping cough",
b) increases the number of Bordetella pertussis (B. pertussis) carriers who spread pertussis, c) provides no protection against the ACT toxin produced by B. pertussis, or the bacteria itself, and d) only provides some protection to about 85% of those fully inoculated according to the current vaccination schedule against some of the other toxins that are produced by B. pertussis. Thus, if anything, the number of doses should be reduced and, based on our current understanding of the development of the human immune system, no prophylactic vaccine should be administered to a child before that child is at least developmentally one (1) year of age.
4. Though many will tell you that current CDC-recommended vaccination schedule has never been proven safe, and is under scrutiny by members of Congress, the current vaccines have not even been proven to meet all of the current statutory and regulatory requirements for a
"safe" vaccine (as, in the manufacturers' package inserts for the vaccines, the vaccine makers directly, or by omission of a statement of compliance with the preclinical toxicity requirements
for proof that the vaccine does not cause cancer, is not mutagenic, and has no reproductive toxicity or impairment admit [see attached File 2 ...]). 5. Based on my current understanding of the facts, the meningococcal meningitis vaccination program does not provide adequate protection to those inoculated with it and may actually increase the inoculated individuals' susceptibility to infection.
6. Overall, the historical and current surveys have clearly established that the "chronic medical condition" health of vaccinated children has been and is worse (by a factor of 2 to 5) than that of children who have never been vaccinated.
For all of the preceding reasons, I strongly urge you to reject these proposed changes to the
mandated Minnesota vaccination schedule and to consider suspending the State's mandates for all
prophylactic vaccinations until the vaccines' manufacturers can provide you with proof that they
have fully complied with all of the current federal statutory and regulatory requirements required
for a "safe" vaccine and found that each of their vaccines is "safe" because, by statute, the
vaccine makers, and not the FDA, have an absolute nondischargeable duty to prove their vaccines
have met all of the applicable requirements for a "safe" vaccine before they market any doses of
that vaccine.
Respectfully, Paul G. King, PhD
http://www.dr-king.com
President, FAME Systems
PS: If you or any of your staff want to know more about any vaccine safety issue,
then there are many pertinent articles in the "Publications (by year)" subsection
of the "Documents" page on my web site starting in 2008 including an in-depth
2-part review of a commissioned Florida Department of Health report that addressed the then-mandated Florida vaccination program as well as those
non-mandated vaccines being strongly pushed by the Florida healthcare
establishment. ++++++++++++++++++++++++++++++++++++++++
Re: Hepatitis A:
Age distribuion data taken from the 2011 "Summary of Notifiable Diseases, ..."
http://www.cdc.gov/mmwr/preview/mmwrhtml/mm6053a1.htm?s_cid=mm6053a1_w
Hepatitis viral,
Age not
<1 yr
1–4 yrs
5–14 yrs
15–24 yrs
25–39 yrs
40–64 yrs
=65 yrs
acute
1 (0.02) 32 (0.19) 92 (0.23) 264 (0.61) 340 (0.55) 414 (0.41) 233 (0.57)
1 (0.02) 6 (0.04) 4 (0.01) 127 (0.29) 1,122 (1.82) 1,396 (1.38) 182 (0.45)
3 (0.08) 3 (0.02) 1 (0.00) 300 (0.72) 570 (0.96) 319 (0.33) 15 (0.04)
Hepatitis, Viral. Incidence,* by year — United States, 1981–2011
* Per 100,000 population.
†
Total
stated
A
B
C
Hepatitis A vaccine was first licensed in 1995.
22
65
18
1,398
2,903
1,229
§
Hepatitis B vaccine was first licensed in June 1982.
¶
An anti-hepatitis C virus (HCV) antibody test first became available in May 1990.
Since 1995, NNDSS data have shown declining rates of acute hepatitis A and B. …. The number of cases and rates of acute hepatitis C have been relatively stable from 2003 through 2010. However, the rate for acute
hepatitis C increased by 33.3% from 2010 to 2011. Additionally, a substantial burden of hepatitis disease remains as a result of the prevalence of both chronic hepatitis B and chronic hepatitis C.
Alternate Text: This figure is a line graph that presents the incidence per 100,000 population of viral hepatitis, with separate lines for hepatitis A, B, and C, in the United States from 1981 to 2011.
* Per 100,000 population.
Since 1999, rates of infection with hepatitis A virus have declined in all regions, with western states showing the greatest decline. in …. Hepatitis A virus infection rates are the lowest ever reported and are similar
across regions.
Alternate Text: This figure is a map of the United States that presents the incidence range per 100,000 population of hepatitis A by county in 2011.
Table 2. Cases of Selected Communicable Diseases Reported to the Minnesota Department of Health by District of
Residence, 2011 {See, http://www.health.state.mn.us/divs/idepc/newsletters/dcn/sum11/sum11.pdf}
[Hepatitis segment]
(population per U.S. Census 2009 estimates)
Metropolitan
(2,810,414)
Northwestern
(153,218)
Northeastern
(320,342)
Central
(715,467)
West
Central
(229,186)
1 (0.14)
1 (0.44)
3 (0.42)
3 (0.42)
South
Central
(286,956)
Unknown
Total
(5,220,393)
Southeastern
(486,517)
Southwestern
(218,293)
Residence
1 (0.35)
2 (0.41)
4 (1.83)
0
27 (0.52)
1 (0.44)
0 (0.00)
1 (0.21)
1 (0.46)
0
20 (0.38)
1 (0.44)
0 (0.00)
0 (0.00)
1 (0.46)
0
18 (0.34)
Disease 1
Viral
Hepatitis
14 (0.10)
0 (0.00)
4 (1.25)
A, acute
Viral
0 (0.00)
0 (0.00)
Hepatitis
14 (0.10)
B, acute
Viral
Hepatitis
8 (0.06)
0 (0.00)
5 (1.56)
C, acute
1
Number of cases and, in parentheses, case rate per 100,000 population
County Distribution within Districts
Metropolitan - Anoka, Carver, Dakota, Hennepin, Ramsey, Scott, Washington [incidences were significantly lower than state means for acute hepatitis diseases]
Northwestern - Beltrami, Clearwater, Hubbard, Kittson, Lake of the Woods, Marshall, Pennington, Polk, Red Lake, Roseau [absence of acute hepatitis diseases]
Northeastern - Aitkin, Carlton, Cook, Itasca, Koochiching, Lake, St. Louis [hepatitis A and C incidences were significantly above mean incidence ]
Central - Benton, Cass, Chisago, Crow Wing, Isanti, Kanabec, Mille Lacs, Morrison, Pine, Sherburne, Stearns, Todd, Wadena, Wright
West Central - Becker, Clay, Douglas, Grant, Mahnomen, Norman, Otter Tail, Pope, Stevens, Traverse, Wilkin
South Central - Blue Earth, Brown, Faribault, LeSueur, McLeod, Martin, Meeker, Nicollet, Sibley, Waseca, Watonwan
Southeastern - Dodge, Fillmore, Freeborn, Goodhue, Houston, Mower, Olmsted, Rice, Steele, Wabasha, Winona
Southwestern - Big Stone, Chippewa, Cottonwood, Jackson, Kandiyohi, Lac Qui Parle, Lincoln, Lyon, Murray, Nobles, Pipestone, Redwood, Renville, Rock, Swift, Yellow Medicine [hepatitis A incidence was
significantly above mean incidence ]
Note: Presuming the age distribution for the United States adequately approximates the age distribution in the state of Minnesota, there
were probably 3 or less cases of hepatitis A and 1 or no (“0”) cases of acute hepatitis B or hepatitis C in children under the age of 15 years
in Minnesota in 2011 regardless of whether they were vaccinated with the hepatitis A vaccine or not -- based on the following
information. Moreover, given the fact that there is no hepatitis C vaccine, it would seem that
From the Minnesota Health Department reports for 2008 – 2012, the reported case data,
Disease
Viral hepatitis A
Viral hepatitis B
Viral hepatitis C
Reported Cases of Acute Infection by Year
2008
2009
2010
49
30
37
39
39
24
25
15
2011
27
20
18
2012
29
17
32
15
(CDC 17)