Religious Exemptions to Vaccine Mandates and the Law: Where Are We? Where Can We Go?

This is a guest post by Dorit Reiss.

In an article about religious exemptions¹ , Attorney Alan Phillips criticized Dr. Paul Offit’s call for an end to religious exemptions. While Mr. Phillips correctly pointed out some minor errors in Dr. Offit’s legal arguments, the bulk of his critique is extremely unconvincing (even setting aside his personal attack on Dr. Offit; on that, see Michael Simpson's thorough debunking²). There are three reasons to give substantial weight to the critique of religious exemptions. First, courts in the United States have clearly and consistently rejected claims of a constitutional right to a vaccine exemption. Second, the religious exemption is extremely problematic because of its vulnerability to abuse, even apart from the dubious morality of sacrificing a child’s health for religion. And finally, although interpreting exemption laws is the role of the courts, creating exemption laws – or abolishing them – is a question of public policy, and there is a powerful case for abolishing non-medical exemptions that deserves legislative consideration.

There is no Constitutional Right to an Exemption
School immunization requirements in the United States have been around at least since the latter part of the 19th century³  and have been upheld by the United States Supreme Court⁴. While Mr. Phillips suggests that parents “do have a Constitutional right to exercise a vaccine religious exemption,” no court in the United States – federal or state - has ever found that a state has a constitutional duty to provide parents with a religious or philosophical exemption. In fact, every court that directly examined the question arrived at the opposite conclusion, basing it on a state’s power to protect the health of children and the public health. The last time the Supreme Court addressed the issue – albeit as an example in another context – the Court said that a parent “cannot claim freedom from compulsory vaccination for the child more than for himself on religious grounds. The right to practice religion freely does not include liberty to expose the community or the child to communicable disease or the latter to ill health or death⁵.” Most recently, the 4th Circuit Court of Appeals found that school immunization requirements can withstand even strict scrutiny⁶ .

Even courts that struck down religious exemptions for preferring some religions over others – something most courts reject, as Mr. Phillips pointed out – struck down the religious exemption but kept the school immunization requirement intact^7,8 (no doubt to the chagrin of the winning – but losing – plaintiff).  These courts sent legislatures a clear message in two parts: 1) if you want to provide a religious exemption, it needs to be non-discriminatory; but 2) you are perfectly free to not provide a religious exemption.

Dr. Offit would go further. He supports the ruling of the Supreme Court of Mississippi, in Brown v. Stone⁹,  that a religious exemption violates the equal protection guarantee of the 14th amendment. Mr. Phillips is right to point out that Brown does not reflect the prevailing legal interpretation; no other court has adopted that part of the ruling. But it is a legitimate legal argument to advance Brown’s interpretation and to buttress it with policy arguments. Before it is a persuasive one, though, that discussion needs to be pushed further. The public policy reasons need to be more developed than in Brown, and the relationship of that interpretation to other 14th Amendment jurisprudence addressed. I would also like to see a principled way to draw the line: if we follow a constitutional doctrine that says you cannot treat children differently on religious grounds, how far do you take it, and what remains of freedom of religion in the family?

The Religious Exemption is Problematic
As Mr. Phillips highlights, “[f]ederal courts have interpreted the First Amendment's ‘free exercise’ [of religion] clause as protecting any belief that is ‘religious in nature’ and ‘sincerely held’ (as the law defines those phrases).” This broad interpretation is part of the problem. There is, no doubt, a minority whose opposition to vaccination is sincerely based on religious grounds. You can question whether states should privilege such sincere beliefs over protecting children and the public against vaccine-preventable diseases, and Dr. Offit does. Courts, as explained, uniformly left that decision to the states.

But even for a state that values religious beliefs, offering a religious exemption is problematic today, since the evidence suggests that the vast majority of exemptors oppose vaccines not based on religious grounds, but based on ill-supported safety concerns, and their use of the religious exemption is insincere.

The most extreme example of such abuse is the creation of special churches to oppose vaccination. For example, the Congregation of Universal Wisdom¹⁰ was created by a chiropractor at least in part to provide vaccine opponents with religious cover¹¹. 

Mainstream religions do not oppose vaccines, and often expressly support them. While that fact is not determinative under our jurisprudence, it is suggestive. When a Catholic, Jew or Muslim – in direct contradiction to the majority of religious authorities – claims opposition to vaccination on religious grounds, their religious argument is suspect. The broad jurisprudence Mr. Phillips highlights provides states with very few options to actually examine whether the reason for exempting is, indeed, religious (though some states do engage in such an inquiry).

Studies suggest that most parents who refuse vaccines do so on the basis of safety concerns¹². Cases exist in which claims for religious exemptions were rejected because the court determined that the parent’s real concern was a safety concern^{13, 14}. 

Even states that were initially motivated by a sincere desire to protect religious minorities should reconsider whether a religious exemption which is not constitutionally required is appropriate given this widespread abuse.

Vaccine Exemptions are a Question of Public Policy
Interpreting and applying exemption laws raises legal issues. Enacting them or abolishing them, however, is a question of public policy, within the appropriate constitutional limits. Mr. Phillips has his own view on this, and his view is decidedly anti-vaccine: vaccines are dangerous;  the health care systems that promote vaccines are corrupt;  and vaccine exemptions pose no health risks.  His medical claims have already been addressed by an academic physician-researcher, who certainly has the medical credentials to do so¹⁵.  But Mr. Phillips also argues that “there is a legal presumption that the exercise of a vaccine religious exemption does not pose a significant risk to anyone. If it would, state legislatures, who are presumed to have considered the possible consequences of enacting exemption laws, would not have enacted the exemption laws in the first place.” Mr. Phillips does not cite any authority for this proposition, and the only case I know of that even remotely supports it is the 2007 Diana H. case from Arizona¹⁶. That case is very weak support: even the majority (two judges and a very powerful, compelling dissent) cited several risks of not vaccinating. All the majority did was defer to the legislature’s balancing of the health risks it acknowledged with parental rights. Even if we were to accept this decision, which is not well-supported in my view, there is nothing preventing a legislature from revisiting this balance and finding that exemptions do pose a significant risk.

The legislature may do so in response to a rising number of exemptions, to outbreaks of diseases, or after being persuaded by an opinion voiced, for example, by Dr. Offit. After all, an infectious diseases doctor who sees the result of not vaccinating directly in the form of suffering or dying children is uniquely qualified to speak on the harms of having such exemptions, and to advocate for a change in policy. Dr. Offit, in particular, is a well-known, well-credentialed vaccine researcher, and has been engaged in vaccine policy and education for many years. His perspective deserves substantial weight.

Personally, I am still working through my views on exemptions. While freedom of religion is an important value in the United States, because of the very high risk of abuse, and because of the consequences for public health, I agree with Dr. Offit’s criticism of religous exemptions. But I find myself going back and forth between the two positions first,  the position that there should be no exemptions except medical ones; and alternately, and the position that states should offer a “personal choice” exemption -- but make such an exemption difficult to get. My reasons for supporting the latter position derive from the existence of a minority that would not vaccinate no matter what, because they sincerely – if wrongly – believe vaccines are toxic and will severely harm their children. I do not want to force those parents into a position where they see themselves as forced to lie about their religious beliefs, or alternatively, feeling they are forced to homeschool their children. The latter option is not only a substantial burden, it would deprive those children of a public education (that would hopefully provide them, among other things, with a good grounding in science). On the other hand, would tightening vaccine exemptions really motivate a substantial number of parents to homeschool that would not otherwise do so? And is it politically feasible to enact a personal choice exemption that is stringent enough to only apply to the tiny, die-hard minority that would not vaccinate at any rate? After all, anti-vaccine activists have mobilized in force to fight situations like California’s AB2109, which only required a health practitioner to confirm that the exemptor had received relevant information. How hard would they fight an attempt to make exemptions actually hard to obtain? I am conflicted.

Of course, unlike Dr. Offit, I have never had to deal with the results of not vaccinating directly. I’ve never seen a child die, let alone a seeing a child dying vaccine-preventable disease. I hope I never will. The force of these other considerations likely pales dramatically when you have to look into the face of a dying child or her parents. On the other hand, the problem Dr. Offit faces is that – thanks in large part to widespread vaccination – most people are in my position rather than his: not having seen up close the harms of vaccine-preventable diseases. That might be a good reason to listen seriously to those who have. We could, of course, choose to wait until we have more dead or disabled children to decide to clamp down on exemptions. But do we really want to pay that price?

Notes

1. Phillips, A., Attorney Refutes Dr. Offit's Vaccine Exemption Criticism. Green Med Info website, posted June 10th 2013 http://www.greenmedinfo.com/blog/attorney-refutes-dr-offits-vaccine-exemption-criticism, accessed 11/2013.
2. Simpson, M. Debunking Myths about Dr. Paul Offit, Skeptical Raptor website,  http://www.skepticalraptor.com/skepticalraptorblog.php/debunking-myths-dr-paul-offit/, accessed 11/2013.
3. Duffield v. Williamsport Sch. Dist., 29 A. 742 (Pa. 1894).
4. Zucht v. King, 260 U.S. 174 (1922).
5. Prince v. Massachusetts, 321 U.S. 158, 166-167 (1944) found at http://www.law.cornell.edu/supct/html/historics/USSC_CR_0321_0158_ZO.html, accessed 11/2013.
6. http://www.ca4.uscourts.gov/Opinions/Unpublished/092352.U.pdf, accessed 11/2013.
7. Sherr v. Northport-E. Northport Union Free Sch. Dist., 672 F. Supp. 81, 83 (E.D.N.Y. 1987)
8. Dalli v. Bd. of Educ., 267 N.E.2d 219 (Mass. 1971)
9. Brown v. Stone, 378 So.2d 218, 220 (Miss., 1979)
10. Church of Universal Wisdom URL: http://www.cuwisdom.org , accessed 11/2013.
11. Calandrillo SP., Vanishing vaccinations: why are so many Americans opting out of vaccinating their children? Univ Mich J Law Reform. 2004 Winter;37(2):353-440., http://www.ncbi.nlm.nih.gov/pubmed/15568260 accessed 11/2013.
12. Gust DA, Darling N, Kennedy A, Schwartz B., Parents with doubts about vaccines: which vaccines and reasons why. Pediatrics. 2008 Oct;122(4):718-25. doi: 10.1542/peds.2007-0538. http://www.ncbi.nlm.nih.gov/pubmed/18829793, accessed 11/2013.
13. Check ex rel. MC v. New York City Dept. of Educ. E.D. N.Y., 2013. Slip Copy, 2013 WL 2181045
14. Farina v. Board of Education of the City of New York, 116 F.Supp.2d, 503 (2000)).
15. Orac Knows (pseudonym) Responsibility versus antivaccine Activists Respectful Insolence Blog http://scienceblogs.com/insolence/2013/06/27/responsibility-versus-antivaccine-activists/, accessed 11/2013.
16. Diana H v. Rubin, 217 Ariz. 131 (Ariz. App. 2007).

Dorit Rubinstein Reiss is a professor of law at UC Hastings College of Law. She graduated Magna cum Laude from the Hebrew University of Jerusalem,  where she served as Editor in Chief of the Law Review, and holds a  Ph.D. from the Jurisprudence and Social Policy program in UC Berkeley. Her doctoral dissertation was on the accountability of agencies, whic continues to be a focus of her research.

Comments

[Megan Lee]

Very well said. I've said it before, and am quite happy to say it again. The only exemptions that should be allowed, are VALID medical exemptions. I don't personally think religious exemptions should be permitted. Too many anti vaccine proponents are using bogus religious exemptions to get out of vaccinating their children, when in reality, the reason for not vaccinating is that they have 'heard' vaccines are not safe. The scientific evidence shows, beyond a shadow of a doubt, that NOT vaccinating, is far more dangerous, far more costly - in monetary and health - than vaccinating can ever be. Community Immunity is not just a fairy story. It's a fact.

[Liz]

Thanks for the comment, Megan. I come down on the side of having a personal choice exemption available, but hard to get.

I'd vote for an exam, modeled on the driver's license exam. The person wanting an exemption for herself, or for her child, would have to show that she had actually mastered the facts about the risk of disease and vaccine safety and efficacy, even if she chooses not to believe them.

[Doritmi]

I was thinking of a similar model, Liz, though with a day-long course before: a day of study and an exam to make sure you really know what you're doing.

[Harriet Huestis]

I am in favour of only medical exemptions. Why should religion have any say in public health decisions. Why should religion mean you can neglect your child. Why should everyone have to pay for irrational personal choices. I am Canadian and we have public health care so all the costs of illnesses are borne by everyone. But even in the US this would be true. There are enormous public health expenditures necessary to control outbreaks. Insurance rates would have to be high enough to cover the costs of treatment. Even though it is private doesn't mean that someone is not paying. In Canada it is our tax dollars. In the US it is taxes and insurance costs. My single case of encephalitis has cost taxpayers millions of dollars and will be millions more before I die. This may be the dollar sign argument but allowing any non-medical exemptions is not financially solvent. I would not support forced vaccination but there should be limits on the unvaccinated. The current outbreak in Alberta started after a traveler to the Netherlands returned, most likely a member of the Dutch Reform Church as it is common in this area. Why should they have been allowed to travel on aircraft open to the public even locally let alone internationally. What about the children's rights? Religion is an adult choice not something that should be applied automatically from the parent to the child.

[Science Mom]

Excellent post Prof. Reiss and thoughtful comments. I have proposed (informally) on prior occasions that religious exemptions be eliminated and have only medical and philosophical. With some caveats though; philosophical exemptions should be restricted to maintain herd immunity threshold. Allow a certain percentage of exemptions, say 2% in any given district, county or what have you (a substantial geographic or populated region). This would allow for selective vaccination and should be tracked. It can be done.

I would also propose that strict adherence to outbreak exclusions be in place. I also agree with the idea of making them more difficult to get via testing as has been suggested. I believe that such a proposal would balance the needs of individuals and public health in the fairest way possible.

[Doritmi]

Harriet: I understand your point of view, and it makes a lot of sense. I still hesitate, because of the reasons in my post. Mostly, the effects of those that just won't.

Science Mom: The only problem with restriction is that every time you have a quota, you need to consider how to allocate it. I agree with the goal - keeping the numbers to around 2% - but I've been thinking and am still thinking on what is a fair way to implement this. I have my own thoughts, but am curious to hear yours before voicing them...

[Science Mom]

I would suggest first-come-first-serve although I would imagine the lines that would form in places like Marin county CA. My idea is premised upon single vaccines, not blanket refusals although are also included. For example, set the 2% to each vaccine so no more than 2% can refuse MMR but any vaccines they do get will be accounted for. This has multiple benefits, first we can get a better count of vaccine uptake, not just count exemptions because many or even most states now don't allow people to exempt certain vaccines, it's all or nothing. Secondly, it may even help to increase uptake; for example if a child is only short their Varicella and DTaP for school entry and the exemption quota is met, the parent is probably going to just fulfil the requirement.

I think states may vary on how often one needs to fill out an exemption, some or possibly all are every school change, i.e. elementary, middle and high school while some may be once for the entire district. I would make it every year. I hope I clarified instead of muddy the waters even more.

[Joy Davis]

Religious belief is a core constitutional right for all of the citizens of America. Taking away freedoms that are intrinsic to the human race to gain a perception of uniform safety through conforming to a medical procedure that has been defined as, "unavoidably unsafe", is not sustainable. The vaccine industry has been exempted from any and all liability and accountability so they have little to no incentive to make a safe or effective product. As for educating people who wish to use their religious freedoms when it comes to opting out of a known dangerous medical procedure-they usually know far more than the doctors or nurses administrating the shot or shots. The fear circulating over the risks for massive outbreaks of the measles, or chicken pox has most families scrambling for the shots. The ones that abstain usually have done the homework and have a medical, philosophical or religious reason for not going through with the procedure. I generally have to educated the doctor and nurse about vaccinations and my medical history which according to the manufacturer insert creates a contraindication. An individual with a family member who has had stroke, a seizure, migraine headaches, neuropathy, or autism (just to name a few) should not receive a DTaP vaccination. To sum it up: I am at serious odds with this article as It is not for anyone else to decide what religious belief is "valid". Fear has been the greatest push behind all large scale hate crimes. The fear of a measles outbreak should never propel people in this Country to strike down such a fundamental liberty as our Religious liberties.

[Science Mom]

"Religious belief is a core constitutional right for all of the citizens of America. Taking away freedoms that are intrinsic to the human race to gain a perception of uniform safety through conforming to a medical procedure that has been defined as, "unavoidably unsafe", is not sustainable."

The guarantee of religious freedom, up to a point, is constitutionally-protected. Refusing vaccination is not. Besides you just proved a point in that it isn't your religious beliefs at all that deter you from vaccination; it's an irrational belief that they will cause harm.

"The vaccine industry has been exempted from any and all liability and accountability so they have little to no incentive to make a safe or effective product. "

Demonstrably false. Pharmaceutical companies have not been fully exempted from liability. There is stringent oversight and risk huge fines and even shut down of production facilities if non-compliance is found. Since vaccines are administered to healthy people as a preventative and not a therapeutic drug, the safety standards have to be even higher. This is continually monitored and in part by the Vaccine Safety Datalink.

"As for educating people who wish to use their religious freedoms when it comes to opting out of a known dangerous medical procedure-they usually know far more than the doctors or nurses administrating the shot or shots."

Gleaning some non-filtered information from the internet is not "more educated", just arrogantly ignorant if you think that you will ever know more than a physician or scientist.

"I generally have to educated the doctor and nurse about vaccinations and my medical history which according to the manufacturer insert creates a contraindication. An individual with a family member who has had stroke, a seizure, migraine headaches, neuropathy, or autism (just to name a few) should not receive a DTaP vaccination."

Again false. None of those are contraindications to DTaP but feel free to show me your Google-U education.

"To sum it up: I am at serious odds with this article as It is not for anyone else to decide what religious belief is "valid"."

When your "religious freedom" imposes upon the health and well-being of others, it is absolutely right to curb your "freedoms". You are free to practise your "religion", just don't let it interfere with everyone else's right to live without some infectious diseases.

[lilady]

@ Joy Davis:

"As for educating people who wish to use their religious freedoms when it comes to opting out of a known dangerous medical procedure-they usually know far more than the doctors or nurses administrating the shot or shots."

And...

"I generally have to educated the doctor and nurse about vaccinations and my medical history which according to the manufacturer insert creates a contraindication. An individual with a family member who has had stroke, a seizure, migraine headaches, neuropathy, or autism (just to name a few) should not receive a DTaP vaccination."

None of the examples you provided are medical contraindications to receiving DTaP vaccine...or any of the vaccines that are listed on the CDC/AAP "Recommended Childhood Vaccine Schedule"

Here, for the actual medical contraindications for each childhood vaccine:

http://www.cdc.gov/VACCINES/recs/vac-admin/contraindications-vacc.htm

lilady, BSc-Nursing, Public Health Nurse Clinician-Epidemiologist (retired)

[Joy Davis]

Science Mom -

I am interested in why you believe that I am basing my opinions on "non-filtered information from the internet, and Google-U education." Assumptions are not productive.

I am not sure what your research background is but you can start with the books by the Institute of Medicine on Adverse Events Associated with Childhood Vaccines and the Manufacturers insert for ProQuad by Merck which states,"Use caution when administering ProQuad to children with a history of cerebral injury or seizures or any other condition in which stress due to fever should be avoided." and Merck & Co, "Due caution should be employed in administration of M-M-R II to persons with a history of cerebral injury, individual or family histories of convulsions, or any other condition in which stress due to fever
should be avoided." You can also look into the National Immunization Program for their guide to Contraindications.

BTW-The definition of Cerebral injury can be found on the CNS (CENTRE FOR NEURO SKILLS) site and confirms that Cerebral injury includes, vascular disruption (migraine headaches and stroke), metabolic disorders (autism), and toxic exposures.

It is easier to "believe, or have faith" that a vaccine will act like a "magic bullet" and keep children from all disease and only one child in every million will have a small red swelling at the site of injection, but that is magical thinking and not reality. Instead of having blind faith in a medical procedure, I choose to do the research and learn how to protect my child and others in a way that works with the immune system and is truly effective without the adverse events associated with the childhood vaccination program.

[Dorit Reiss]

Just two points to add to the analysis above: A. as the post explains, you don't have a constitutional right to a religious exemption. B. Here is an explanation of what unavoidably unsafe actually means, and how the Supreme Court did not apply it to vaccines in the way you suggest: http://momswhovax.blogspot.com/2013/11/vaccines-and-unavoidably-unsafe-products.html

[Dorit Reiss]

Autism is not a metabolic disorder, by the way. And I notice you do not address the risks of diseases to which you are leaving your child exposed - risks much higher than those of the vaccines.

[Joy Davis]

Dorit Reiss-

Autism and Metabolic Disease.
Journal of Child Neurology, Volume 23, Number 3

Risk of Disease vs. Risk of the Medical Procedure, Vaccination is a great discussion and one of the most important topics of our current day and deserves it's own article with accurate information.

One tidbit of information-
CDC states:
During Jan 1- Aug.1st 2013, 159 cases of Measles were reported Nationally from the ages of 0-61 years of age. Out of the 159 cases 17 people had to go to the hospital for pneumonia and no deaths were reported. 157 of the 159 were import associated.

The number of cases that the VAERS reporting service shows had an adverse effect resulting from the MMR vaccine with an ER visit-395 people.

This for a disease that my husband, all of his friends and their friends and parents had that cleared up in 7-10 days with proper fluids and bed rest with the bonus of lifelong immunity, unlike the vaccine which gives waning immunity within 10-15 years.

[Dorit Reiss]

Joy Davis,
A. Your article does not say autism is a metabolic disease - in fact, it expressly says otherwise. It does say some metabolic issues are associated with autism at higher rates than in the population, but causation is unclear. http://jcn.sagepub.com/content/23/3/307.short
B. Note that the measles cases are on a background of very high rates of vaccination, with most of them in the unvaccinated. With the rate of death being about one in a thousand, it's not surprising there were none yet. Should we let this grow until people start dying? Sounds like a bad idea. I'm glad your husband cleared the disease. Of course, those who died from it are not here to testify, are they? I am sorry you see fit to dismiss the deaths and suffering from diseases. And by the way, immunity from MMR is probably lifelong.
C. VAERS data does not show causation. Here is an explanation of what it can and cannot be used for: http://www.harpocratesspeaks.com/2013/11/vaers-few-things-we-need-to-discuss.html
D. Here is the data on the relative risks of the disease v. the vaccines: http://www.health.gov.au/internet/immunise/publishing.nsf/Content/D35CD18A3985212ECA2574E2000F9A4F/$File/quick_sideeffects.pdf. As is easy to see, the harms of the disease are an order of magnitude greater.

[Science Mom]

I am interested in why you believe that I am basing my opinions on "non-filtered information from the internet, and Google-U education." Assumptions are not productive.

Joy Davis, it is no assumption. If you were actually using IOM reports you wouldn't have made this obvious gaff:
"I generally have to educated the doctor and nurse about vaccinations and my medical history which according to the manufacturer insert creates a contraindication. An individual with a family member who has had stroke, a seizure, migraine headaches, neuropathy, or autism (just to name a few) should not receive a DTaP vaccination."

No where in any IOM report are these contraindications for vaccination as you claim. If this is what you are using to "educate" physicians and nurses then my assumptions as to your information is correct.

BTW-The definition of Cerebral injury can be found on the CNS (CENTRE FOR NEURO SKILLS) site and confirms that Cerebral injury includes, vascular disruption (migraine headaches and stroke), metabolic disorders (autism), and toxic exposures.

Autism isn't tacit for a metabolic disorder nor is it brain injury. You are seriously misrepresenting CNS' mission and treatment programmes: http://www.neuroskills.com/brain-injury/brain-injury-overview.php

It is easier to "believe, or have faith" that a vaccine will act like a "magic bullet" and keep children from all disease and only one child in every million will have a small red swelling at the site of injection, but that is magical thinking and not reality. Instead of having blind faith in a medical procedure, I choose to do the research and learn how to protect my child and others in a way that works with the immune system and is truly effective without the adverse events associated with the childhood vaccination program.

Clearly your "education" fails you if you believe this. No one says vaccines are a "magic bullet"; that's a strawman people like you have to set up so you can look as though you are actually correcting a misnomer (which doesn't even exist to begin with). The magical-thinking is yours to believe that, "I choose to do the research and learn how to protect my child and others in a way that works with the immune system and is truly effective"

Please illuminate me as to how you achieve this; I'm always curious when someone makes these types of claims.

[Science Mom]

The number of cases that the VAERS reporting service shows had an adverse effect resulting from the MMR vaccine with an ER visit-395 people.

This for a disease that my husband, all of his friends and their friends and parents had that cleared up in 7-10 days with proper fluids and bed rest with the bonus of lifelong immunity, unlike the vaccine which gives waning immunity within 10-15 years.

With all of your education you haven't figured out how VAERS works nor where anecdotes are on the evidence scale? Please tell me Joy how VAERS reports have established causation? What would you use for a denominator to calculate a risk ratio? Attack rate? Prevalence rate? Why would you weight a passive surveillance system like VAERS higher than an active surveillance system like the VSD?

[Facts]

You say vaccines are safe- others disagree.. Shouldn't people be free to choose how they live their life? 100 Compiled Studies on Vaccine Dangers

Activist Post

There is no shortage of research regarding the negative effects of a wide variety of vaccines. From Gardasil to the seasonal flu shot, studies have proven that the extreme risks associated with vaccinating oftentimes outweigh the minor benefits. Here is a fraction of the research (over 100 studies) tying vaccines to a host of health conditions, broken down by category: http://www.activistpost.com/2011/09/100-compiled-studies-on-vaccine-dangers.html