Legislative changes to The Human Medicines Regulations 2012 (HMRs) that fast-track mass vaccination using unregistered vaccines, as well as permit their advertising by commercially interested parties and their administration by non-healthcare professionals, should not be supported until such time that:
A full range of plausible therapeutic treatments and pharmaceutical and non-pharmaceutical prevention options have been thoroughly evaluated and found to be of no significant benefit to public health
Definitive results from trials (Phase III) are placed in the public domain that demonstrates COVID-19 vaccines have an acceptable risk/benefit profile to justify mass vaccination
Scientific testing of possible interactions between COVID-19 and influenza vaccines has been conducted and shown to not cause any disease enhancement or other negative interaction given the two vaccines may be administered jointly.
The proposed amendments to the HMRs undo over half a century of regulatory development in the fields of medicinal and consumer protection law that had the intent of protecting the interests of citizens.
The expansion of legal immunity to civil liability, coupled with a reversal of the prohibition of direct-to-consumer advertising and the expansion of the workforce of vaccine administrators outside the healthcare professions, provides a recipe for coercion and a disregard for informed consent. This would create an environment where the planned mass vaccination programme of the British public using novel, unlicensed COVID-19 vaccines could constitute serious breaches of The Human Rights Act 1998.
Following is the response (in both full and summary forms) by the Alliance for Natural Health International to the Department of Health and Social Care’s consultation on Changes to Human Medicines Regulations to support the rollout of COVID-19 vaccines.
The deadline for responses is 18 September 2020 and responses should be made online at the
following portal:
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