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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11/28/22  12:55 pm
Commenter: Anonymous

Informed consent should be the foundation of the state's immunization program

The regulations fail to acknowledge the principle of informed consent, the legal right to be fully and accurately informed about the benefits and risks of a medical intervention, including a pharmaceutical product, and the right to make a voluntary decision about whether to accept the risk for oneself or their minor child without being coerced or punished. The right to informed consent is universally affirmed as a human right by ethicists, medical societies, Virginia regulation, institutional patient bills of rights, and the United Nations Universal Declaration of Human Rights. If the principle of informed consent is incorporated into the state’s immunization regulations it would necessitate a paradigm shift from a mandatory, one size all vaccination schedule required for all Virginia’s school children to one that acknowledges that a child’s health interventions should be made by the parent(s).

The U.S. Supreme Court has recognized that vaccines are “unavoidably unsafe” and can cause injury and death in some recipients and therefore, where there is risk, there must be choice. The decision to accept a vaccine, like any other medical intervention, should be made by the individual and in the case of a minor, the decision should be solely that of the parent(s). 


 The state should amend the penalty and fines associated with non-compliance with the vaccine schedule


Any immunization registry/tracking program should be done on an opt in basis

CommentID: 206252