Virginia Regulatory Town Hall
Virginia Department of Health
State Board of Health
Regulations for the Immunization of School Children [12 VAC 5 ‑ 110]
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11/23/22  9:17 am
Commenter: Robyn Middleton

Preserve True Public Health: Do NOT follow CDC ACIP COVID recommendations

My name is retired Lieutenant Colonel Robyn L. Middleton.  I served 23 years in both the Active Duty U.S. Air Force and Air Force Reserve as a hospital administrator (Medical Service Corps Officer).  The last 5 years of my service were spent as the Deputy Reserve Medical Forces Advisor to the USAF Surgeon General.  I continue to be horrified that our core medical ethics have been disregarded and abandoned during the pandemic response.  Patients' rights, physicians' right to treat, patient access to care, transparency, and ultimately patient safety have all been grossly violated in favor of corporate profit being illegally positioned as the only clinical tool in the toolbox.  Moreover, the blatant censorship in the scientific and medical communities continues to put patients at risk.  The obstruction of open scientific inquiry and discourse will leave clinical stones unturned.  Censorship is the complete antithesis of the empirical process, and its continued tolerance is destroying trust in our health and public health institutions.   As patients continue to lose trust in public health, many will cease to seek care.  This will only create more negative clinical outcomes in all disease categories.

The most dangerous and immediate crisis that must be intercepted is the recent CDC’s ACIP (Advisory Committee on Immunization Practices) reckless and unwarranted addition of the COVID-19 vaccine to the childhood vaccine schedule. These irresponsible recommendations are not grounded in reasonable, safe, or traditional empirical science.  The CDC has become a captured entity that has been unduly influenced by the financial conflicts of interest of big pharma.  The public now knows this. If the VDH follows these irresponsible CDC recommendations, know that Virginias will lose even more trust in public health.  We cannot afford our precious children to be unnecessarily put at risk in favor of corporate profit.  We know that the data have shown from the beginning (and continue to show) that the pediatric and young adult patient cohorts are not at significant risk of this virus (99.995% recovery rate with minimal symptoms).  Per CDC data, three out of every four children have also demonstrated natural immunity.  There is zero support to warrant the risk of mass vaccinating children when this patient category is (1) not at risk, (2) vaccine effects on children have not been sufficiently studied, and (3) the long-term effects are unknown.  I personally watched all of the ACIP presentations for this patient cohort.  The justification for recommending mass vaccination on this patient cohort was based on case data.  We know that number of cases is not the metric that matters here.  Risk and safety is what matters.  Shame on the CDC ACIP for not presenting sufficient patient safety data. What we DO know is that the push to add the COVID-19 vaccine to the childhood schedule by the CDC was not about children’s health or safety.  Anyone who revisits the 1986 National Childhood Vaccine Injury Act (Public Law 99-660) will quickly realize this is solely about the pharmaceutical industry achieving more immunity (freedom from liability) as the (illegally obtained) EUA protections expire.  We know he EUA was illegally obtained because (1) reasonable and safe alternative treatments for COVID existed from the beginning of the pandemic and were fraudulently maligned by the media (hydroxychloroquine, ivermectin, etc.), and (2) it was recently revealed by Janine Small’s recent statement to the European Parliament that the COVID vaccines were not tested for reducing transmission prior to deployment.  Rather, the pharmaceutical companies were operating “at the speed of science”.  We also know that the 2005 PREP Act has been grossly used as an opportunity to manipulate public health to serve corporate financial interests and toward political gain.  This has to stop and as healthcare professionals we must protect the true mission of public health.

In summary, the recent CDC ACIP’s move to add this insufficiently studied vaccine to the recommended childhood schedule serves only to assist the pharmaceutical industry’s continued evasion of liability. We must refuse to accept the prioritization of profit over patient safety and we MUST begin by protecting the most precious segment of our society….our children.  As echoed by our Virginia state governor and attorney general on October 21, 2022, the ONLY course of action here in Virginia is to prevent these particular vaccines from becoming a requirement here in the Commonwealth. 

AG Miyares:

Gov Youngkin:

Here in the Commonwealth, we will continue to stand for proper, ethical, legal and reasonable public health that safely accommodates all Virginians.  The bottom line is that medical ethics is not negotiable.  We must stand together to protect the integrity of public health and its true purpose.  Be of steadfast courage and stand with us as we do the right thing for the future of Virginia….protecting our precious children. Thank you in advance for leaning forward with Virginia to do the right thing. This VDH Review of Regulations for the Immunization of School Children serves as an opportunity to reaffirm our commitment to patient safety and ethical public health.

in solidarity,

Robyn L. Middleton


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