Comments to HHS about Mandatory Vaccinations due March 9th

by Catherine J. Frompovich

Ms. Rebecca Fish, Senior Policy Advisor / Email: [email protected]

U.S. Health & Human Services

Ref: Federal Register Doc. 2015-02481 – NAIP Comment due date 3-9-15

Dear Senior Policy Adviser Rebecca Fish:

As requested in the Federal Register of 2-5-15, please accept my comments regarding mandatory adult vaccinations in the USA, the NAIP.

Realistically, most of the information promulgated about vaccines really needs to be revisited for accuracy, transparency, and scientific facts. Furthermore, misleading bureaucratic promotional information should not be the basis for mandating any more vaccines for anyone in the USA!

Probably, the most dramatic explanation for the above statement is found in the information discussed in the:

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Dr. Paul Offit, MD, Vaccine Inventor, Chief, Infectious Diseases, Children’s Hospital of Philadelphia, PA AND Dr. Boyd Haley, PhD, Researcher, Emeritus Professor Chemistry/Biochemistry, University of Kentucky Virtual Debate

Biochemistry Science versus the Pharmaceutical-Medical Paradigm

Dr. Haley claims that “people like Dr. Offit have no training in toxicology at all.” That statement probably can be applied to most—if not all—medical doctors and healthcare professionals who, through pharmaceutical industry proselytization/sales reps and ‘contrived science publications to approve their products’, believe “hook-line-and- sinker” all the rhetoric about vaccine ‘safety’, ‘efficacy’, and interpreted biochemical baloney.

One impeccable example of biochemical baloney about vaccines deals with mercury and ethylmercury, in particular. It is the Professor of Chemistry & Biochemistry Boyd Haley’s discussion regarding Thimerosal, ethylmercury and mercury, which HHS/CDC/FDA really need to take to heart and abide by. The science on Hg has been there for years! It’s a neurotoxin.

Dr. Haley emphasizes that the USA vaccinates the most of any country, but also has the highest infant mortality-death rate; that the USA is way down the list—number 27!

In 2010, The Washington Post published the article “Our infant mortality rate is a national embarrassment”, which contained a dramatic chart as to where the USA rated in regard to infant mortality: 27th behind countries like Slovakia (26), New Zealand (25), Hungary (24), Poland (23), United Kingdom (21), Ireland (16), Czech Republic (5), and Finland (1).

Dr. Haley lends his expertise as a biochemistry professor to explaining what happens biochemically and synergistically between toxic chemicals and, in particular, Thimerosal’s ethylmercury and aluminum.

Dr. Haley’s discussion of leaky membranes being created, and “leaky gut”, in particular, ought to be of particular interest to anyone who has allergies or an autoimmune disease.

The above information points out there are serious scientific differences between biochemistry and vaccine pharmacology, which cause adverse health effects—something that ostensibly is ignored when vaccines are forced on to children and adults. With healthcare costs in the USA in 2012 amounting to $2.8 Trillion [1], the U.S. healthcare system does not need any more vaccine-induced illnesses than we currently—and unfortunately—have been experiencing over the years, especially since the late 1980s when federal vaccine guideline mandates went in to effect.

Furthermore, the science put forward by CDC/FDA and Big Pharma regarding vaccines often is fraudulent, as the following three paragraphs indicate, as examples. However, there are many, many more. Based upon that fact alone, no individual—infant, toddler, teen, adult, or senior citizen—should be mandated to take any medical/pharmaceutical intervention, especially numerous multivalent vaccines, that apparently are based upon fraud!

  1. Causal links between vaccines have been identified in the past by CDC epidemiologists and researchers, viz.: the Simpsonwood Meeting in June of 2000—a clandestine meeting to figure out what to do with the Verstraeten study that showed the link between Thimerosal (ethylmercury) in vaccines and autism.
  2. Then, as recently as 2014, William Thompson, PhD, blew the whistle on how he fudged vaccine study papers regarding the link between vaccines and autism.
  3. Furthermore, the Mumps active efficacy rating in the Merck MMR vaccine was fraudulently stated/fudged as effective for numerous years until two whistleblowers came forward. There’s a federal lawsuit: Civil Action No. 10-4374, United States District Court for the Eastern District of Pennsylvania. [2] That lawsuit has to deal with the numerous-years of false reporting of the efficacy rate of the mumps active in Merck’s MMR vaccine, which CDC/FDA then supplied as ‘valid’ and ‘scientific’ to healthcare agencies and professionals around the USA, and global markets.

Furthermore, there are numerous other indicators of scientific data fraud, especially Big Pharma and CDC/FDA knowingly taking credit for vaccines saving lives. Whereas, FACTUALLY and HISTORICALLY, all communicable infectious diseases had waned to almost no communicable contractions in Western/modern culture countries years—if not decades—before vaccines were ever introduced for respective communicable infectious diseases, as the following set of charts verifies.

Immunization Graphs: Natural Infectious Disease Declines; Immunization Effectiveness; and Immunization Dangers

Prepared by: Raymond Obomsawin, Ph.D., Senior Advisor – First Nations Centre, National Aboriginal Health Organization, October 2009

Additionally, peer-review, evidence-based scientific research indicates that vaccines are not safe or even very effective. Here are 361 PubMed scientific papers collected into a database by GreenMedInfo [3], which CDC/FDA should be incorporating into vaccine safety and efficacy monitoring, but apparently rejects in favor of vaccine manufacturers vested-interest ‘science’ submitted for licensing. Much of that science is considered similar to the MMR/Merck & Co. mumps efficiency ratings fiasco addressed earlier in this comment. Whistleblowers, come forth, please.

Unfortunately but factually, I have to include the comments of constitutional attorney Jonathan Emord, via this link , about how false and negative information has been kept away from FDA by pharmaceutical companies to approve drugs—and vaccines are drugs.

The 361 PubMed publications database addresses vaccine research indicating, among other issues:

  1. Lack of evidence supporting vaccines
  2. Vaccine-induced toxicity 
  3. Allergies and hypersensitivities
  4. Inactivated flu vaccines have not been proven to be effective in preventing influenza in healthy children under two.
  5. Influenza vaccination for healthcare workers who work with the elderly has no effect on laboratory-proven influenza, pneumonia or deaths from pneumonia.
  6. Male newborns vaccinated with Hepatitis B prior to 1999 had a 3-fold higher risk for parentally reported autism.
  7. Over 1,000 confirmed cases of vaccine-induced thrombocytopenia were reported between 1990-2008. 
  8. Over 600 cases of sudden infant death syndrome following vaccination were reported from 1990-1997.
  9. The effectiveness of the 2008-2009 seasonal flu vaccine in England was -6%.
  10. The risk of adverse events from the pertussis outweighed the risk of pertussis infection during the period 1970-83 in children living in non-deprived circumstances in Britain.
  11. There are no randomized controlled trials that assessed the effects of hepatitis B vaccine during pregnancy for preventing infant infection.
  12. There is a highly statistically significant correlation between increasing number of vaccine doses and increasing infant mortality rates.
  13. There is lack of evidence for the effectiveness of influenza vaccines in adults aged 65 years or older.
  14. Adverse effects of tetanus toxoid, reduced diphtheria toxoid, and acellular pertussis vaccine in 6- to 7-year old children.
  15. Adverse events following smallpox vaccination with ACAM2000 in a military population have been reported.
  16. Aluminum hydroxide-induced macrophagic myofasciitis (MMF) associated with vaccination has been reported.
  17. Aluminum vaccine adjuvants appear to contribute to the rising prevalence of autism. [I respectfully suggest it contributes to Alzheimer’s disease too!]
  18. Among U.S. military personnel vaccinated against smallpox, myopericarditis occurred at a rate of 1 per 12,819 primary vaccinees, and 3.6 fold higher in those without previous vaccinia vaccination.
  19. An Italian study found that 61% of women experienced an adverse event after the administration of the first dose of HPV vaccine.
  20. An outbreak of measles occurred in a high school with a documented vaccination level of 98 per cent.
  21. Anthrax vaccination contributes to joint related adverse reactions.
  22. BCG revaccination may raise mortality in young children.
  23. Between 1995 and 2005, 25,306 adverse events were reported from varicella vaccine.Incidence of adverse reactions to vaccines in pediatric populations are under-reported and may be as high as 43.4% for certain vaccine combinations. 
  24. Incidence of adverse reactions to vaccines in pediatric populations are under-reported and may be as high as 43.4% for certain vaccine combinations. 
  25. Influenza A vaccination containing adjuvant causes cardiac autonomic dysfunction and inflammation which may transiently increase the risk of cardiovascular events.
  26. Influenza vaccination does not appear to be effective during pregnancy in preventing hospitalizations and outpatient visits for respiratory illnesses in pregnant women and their infants.
  27. Influenza vaccination does not prevent ischemic stroke and it does not reduce the rate of acute previous infections in stroke patients.
  28. Influenza vaccination may increase the risk of Guillain-Barré Syndrome.
  29. Injection site reactions occur in 28% of those who receive the anthrax vaccine, with women having twice the incidence of reaction versus men.
  30. Live attenuated influenza vaccines may cause shedding of the virus in children 6-59 months.
  31. Loss of vaccine-induced immunity to varicella over time.
  32. Measles outbreak in a fully-immunized secondary-school population with up to 99 percent vaccination.
  33. Measles virus DNA from the MMR vaccine has been found in peripheral mononuclear cells in patients with ulcerative colitis and children with autism, indicating its possible role in the pathogenesis of these disorders. [This totally exonerates Dr. Andrew Wakefield’s research in 1998!]
  34. Vaccine-associated paralytic poliomyelitis (VAPP) has emerged as the predominant form of the disease in the United States since 1980.
  35. Varicella vaccine has been reported to cause herpes zoster skin lesions and meningitis in a previously healthy boy.
  36. Varicella vaccination in South Korea, despite high compliance rates (via mandatory vaccination), has not eradicated the disease.
  37. Varicella vaccine may be associated with aplastic anemia in children.
  38. Whole cell pertussis vaccines may have been causing serious neurological disorders.

The above listing represents 10 percent of the 361 files in that database, which confirms the need for the CDC/FDA to rethink vaccines, plus not mandate adults ≤65 years old get booster shots for children’s vaccines/vaccinations.

It is quite apparent from the above evidence-based science papers that vaccines at various stages of life—from pregnancy to infants to teens to adults, including the military—are harmful, not effective, and legally and ethically must be revisited for safety and efficacy, rather than HHS mandating more vaccines be given to infants, children, and adults.

Moreover, there is another serious immune health issue about vaccines that CDC/FDA need to investigate using independent, non-Big Pharma scientists to study: vaccines damage the thymus gland. According to medical doctor/vaccine researcher

[Robert Rowen, MD] detailed research on mice and explained: The immature thymus gland is similar to the immature ovary. It comes into the world with so many (but a fixed number) primitive thymocytes (thymus immune cells), each of which has the potential to develop into a full line of immunity against a pathogen. But, they are finite, “like the eggs in an ovary.” His work found that when given vaccines, like those our rulers mandate to our children, the thymus glands of the young rodents got depleted of these precious irreplaceable cells, up to a 70% loss. I was shocked. This is analogous to a 70% loss of key immune function, and, which is permanent! Imagine losing 70% of the muscle of your heart. Yes, you would be a cardiac cripple.

Natural Killer T cells come from the thymus. They regulate your immune system. Natural infection keeps up these cells. Vaccination might wipe them out. The depletion of thymocytes might wipe out whole lines of cells that could provide key immunity for you. For example, instead of an army holding 100 tanks against an invader, your system might only have 30. Not good odds for you. [4] [CJF emphasis added]

Clearly measles vaccine doesn’t work as advertised. In fact, in our own country, outbreak after outbreak has occurred in what has been called a fully vaccinated population. One example: Am J Public Health. 1991 Mar ;81(3):360-4. PMID:1994745. [4] [CJF emphasis added]

According to Dr. Rowen, “vaccines give you plastic immunity. They build up only one line of your immune system, the antibody system, and put the main immune system (cellular immunity) to sleep. You need both for fully developed immunity.” THAT, apparently, is the reason for fully-vaccinated individuals contracting the very diseases for which they have been vaccinated, I contend. Furthermore, it’s not ethical medical science to promote a false sense of ‘immunity’, which CDC/FDA and the medical professions have been doing for decades, about vaccine-induced “antigen response immunity,” while ‘castrating’ the cellular immune system. That’s bad pharmaceutical science and medicine, I contend.

No special interest groups should endeavor—or be permitted—to reprogram innate, natural bodily functions at any level of physiology, which is going on at various levels of business, industry, and government, i.e., mind control, etc. [5]

As a healthcare practitioner for many years, plus being a consumer health researcher for more than 35 years specializing in vaccine issues, I find the health problems attached to the HPV vaccines totally disgraceful insofar as those who have been damaged are considered nothing short of ‘nincompoops’ for having the experiences they have had, which vaccine ‘science’ and the medical profession consider ‘coincidences’. The real coincidence is the fact that so many young women experience similar symptoms and harms on a global basis, which CDC/FDA and others in medicine are not investigating nor taking seriously.

“Anecdotal” is the slam word attached to HPV harms. Why then, in a court of law, witnesses, plaintiffs, and defendants are asked to tell their “stories” if what happened to them is not to be taken into consideration as part of “causation and correlation” threads of reasoning and investigative science and forensics?

SaneVax is devoted to investigating and reporting HPV harms, and I encourage your committees at HHS/CDC/FDA to study their reporting of HPV vaccine harms on a global basis at their website

Furthermore, with the HPV harms track record: 20,575 adverse reactions; 352 reports of abnormal pap smears post vaccination; 89 reported deaths (plus 5 reports submitted to the FDA obtained by Judicial Watch under the Freedom of Information Act (FOIA) are now missing from VAERS) in the few short years HPV vaccines have been on the market, HHS, etal should not question why there is such contentious opposition to forced vaccinations.

Personally, I think for those who wish to ‘play pig in a poke’ or ‘Russian roulette’ with vaccines, vaccines should be made available. But, for those individuals who have done their research homework and know what’s going on and—especially if the USA is supposed to be a FREE country, as we are told—then vaccination should be on a freely voluntary basis. Don’t force a product that’s not been fully tested on to knowledgeable healthcare consumers. Each vaccine package insert states boldly and candidly that the vaccine has not been tested for the ability to cause cancer, birth defects, or interfere with fertility/reproduction. Why are the CDC/FDA allowing Big Pharma to get away with such scientific sleight-of-hand, and still say vaccines are safe?

What did the HHS/CDC/FDA do about all the doctors who promoted tobacco use in the 1950s forward? Here are “10 Evil Vintage Cigarette Ads Promising Better Health” [6]. Remember when MDs said it was better to feed formula than breast feed babies? [7]

Public health information in the past has been rife with false, misleading and downright harmful information promoted by government health agencies, the medical professions, plus the unfortunate and corporate-controlled lame-stream media.

Nothing short of malfeasance has been occurring within the vaccine industry, which has harmed over two generations of children in the USA, plus senior citizens who are pummeled by their MDs to get annual flu and pneumococcal vaccinations. Alzheimer’s disease may be attributable to the aluminum in vaccines, but no one wants to investigate connection with causation.

Isn’t it the job of the CDC/FDA to prevent disease? Isn’t prevention part of the CDC’s official title? From independent, non-pharma science reports vaccines increase the costs of healthcare from adverse events. The VAERS reports cite health problems from vaccines. Vaccine Court–HRSA payouts state vaccines contributed to almost $3 Billion-worth of lifetime health problems and costs.

Therefore, I respectfully ask HHS/CDC/FDA to embargo the entire U.S. vaccination program until the real scientific facts are made public, and healthcare consumers are guaranteed actual safety with choice of participation, rather than pharmaceutical spin and media misinformation, which is rampant and at a fever pitch.

Thank you very much for reading my comments, which I truly appreciate.

Submitted by:

Catherine J Frompovich

Consumer Health Researcher 35+ years / Retired Healthcare Professional (Consulting Nutritionist) Healthcare Journalist and Blogger



End of Comments


Catherine retired from researching and writing, but felt compelled to write this article. 

Catherine J Frompovich (website) is a retired natural nutritionist who earned advanced degrees in Nutrition and Holistic Health Sciences, Certification in Orthomolecular Theory and Practice plus Paralegal Studies. Her work has been published in national and airline magazines since the early 1980s. Catherine authored numerous books on health issues along with co-authoring papers and monographs with physicians, nurses, and holistic healthcare professionals. She has been a consumer healthcare researcher 35 years and counting.

Catherine’s latest book, published October 4, 2013, is Vaccination Voodoo, What YOU Don’t Know About Vaccines, available on

Her 2012 book A Cancer Answer, Holistic BREAST Cancer Management, A Guide to Effective & Non-Toxic Treatments, is available on and as a Kindle eBook.

Two of Catherine’s more recent books on are Our Chemical Lives And The Hijacking Of Our DNA, A Probe Into What’s Probably Making Us Sick (2009) and Lord, How Can I Make It Through Grieving My Loss, An Inspirational Guide Through the Grieving Process (2008)

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