TO THE NUFFIELD COUNCIL ON BIOETHICS CONSULTATION ON "PUBLIC HEALTH: ETHICAL
SUBMITTED BY CLIFFORD G. MILLER
15th September 2006
revised & resubmitted 27th September 2006
This response has to be prefaced with the remarks that any consultation by The
Nuffield Council on Bioethics, especially one funded jointly by the Medical
Research Council, the Nuffield Foundation and the Wellcome Trust is unlikely to
be anything other than partial.
Further, in view of the facts stated below, one has to question whether it is at
all possible that someone as personally and so closely involved with the matters
described, with so close personal interests and direct responsibilities as some
of the members of your Working Party are in previous roles in public health
matters in this country, can in any way be considered otherwise. That therefore
casts a shadow over any findings.
Everything stated here can be verified independently for accuracy. As I only
learnt of this "consultation" the day before the last day for submissions this
paper lacks some of the references I would normally cite. What is said here is
firmly driven by the head and the known facts.
This Consultation is based on a flawed assumption. Unless and until the
following issues are answered fully, impartially and by wholly independent duly
authoritative persons, no actions of the kind implied by the questions posed by
this "Consultation" can be justified, clinically, economically or ethically.
To demonstrate this and as will be shown here, there is good evidence that our
public health officials have been historically and continue to be responsible
for overseeing the uncomfortable increases in allergies, asthma and the related
mortality and morbidity that plague public health today. There is also good
evidence to show that the harm caused greatly outweighs the benefits claimed for
interventions which have no adequate safety basis in any literature or in fact.
That evidence also suggests the facts set out below have been known for a very
long time to a very select few who have chosen to ignore the merited concerns of
the many and have failed to research basic safety issues. These are not the
only problems they have been overseeing and are responsible for.
The current position regarding the increases in allergies and asthma are
documented in a very recent paper from "Thorax" (1st September). It can be
Time trends in allergic disorders in the UK. Thorax. Published Online
First: 1 September 2006. doi:10.1136/thx.2004.038844
THE ASTHMA AND ALLERGY DISASTER
The Bigger Picture
The attached extract of Glaxo's 2004 Report & Accounts demonstrates why
there is such reluctance on the part of vaccine manufacturers to broadcast to
the public what causes their and their childrens' asthma and allergies. It
shows one third of Glaxo's sales turnover, £4.5 billion of a £17 billion total
sales turnover comes from asthma medication and nearly another £1 billion comes
from vaccine sales.
What Causes Asthma and Allergies Is Long Known
There are some peer reviewed publications on this issue, but the literature is
scant. In no small part this is due to the abject failure of the Medical
Research Council to fund ground-breaking research and to start asking the
questions proper scientists should ask. And it should be borne in mind that not
only are the medical community not proper scientists, but their medical training
trains them to think in a fashion that is the antithesis to science. A true
scientist has no truck with questioning the existence of the very ground by
which his or her feet are supported.
Excipients, adjuvants and preservatives (like thiomersal) in vaccines cause
sensitisation. This has been known for years to a select few (including Glaxo).
The following item which I had published in the British Medical Journal
responses has embedded links to factual reference material:-
Avoiding Adjuvants & Excipients Can Avoid Allergies Clifford G. Miller -
10 September 2006
Here is a 2005 paper which found unvaccinated children have less asthma and
allergy than vaccinated:-
relationship between vaccine refusal and self-report of atopic disease in
( J Allergy Clin Immunol. 2005 Apr;115(4):737-44.)
As a side note which illustrates the current atmosphere relating to criticism of
vaccination programmes, when I challenged the lead author over the final
statement, she replied "at least they published". The paper concludes:-
"Parents who refuse vaccinations reported less asthma and allergies in
their unvaccinated children. ........ The known benefits of vaccination
currently outweigh the unproved risk of allergic disease."
"Unproved" is revealing. It is the more so when in the light of this:-
rise in patients with deadly allergies - Children are worst hit by rise in
This is a story I researched and placed with The Observer. It is one I intend
to publish a peer reviewed paper on. Can the MRC be relied on to sponsor
research of this kind? That is to be doubted in view of the history of playing
safe and keeping to the status quo.
The Observer - Sunday April 16, 2006 - Jamie Doward, home affairs editor"
The Human and Financial Cost of Asthma
Here is a summary of the statistics showing asthma beats measles and the costs
of measles (source: Asthma UK - a charity funded by the pharmaceutical
Asthma is a significant problem in the US also:
- 1 death every seven hours
- 1400 deaths pa
- 21 every year are children
- 500 are adults under 65
- 5.2 million UK people
- 4.1 million adults
- 1.1 million children
- 1 hospital admission every
- tens of thousands are
debilitated by serious asthma
- 12.7 million working days are
year are lost due to asthma -
- this is a triple whammy -
we lose three times over - in productivity, increased burden of welfare
benefits and oncost in NHS services
- asthma costs the NHS £889
million every year
AAAAI Media Resources: Media Kit - Asthma Statistics Source: American
Academy of Allergy, Asthma & Immunology asthma statistics
Please bear in mind, asthma and allergies are just one area. There is justified
cause for concern in a many others which have increased significantly. Obesity
which this "Consultation" refers to has recently been linked to asthma. That
posits a link to the same causes. There are extraordinary increases across the
board in other areas also, including diabetes and cancers. And yet when faced
by the scale of evidence that exists those nominally responsible fail to carry
out the safety studies which will demonstrate the interventions are unsafe and
continue with them in the blind belief that the benefit outweighs the harm.
Regrettably, anyone with eyes to see knows that is a traverse of the reality.
The American Academy of Allergy, Asthma & Immunology is the largest
professional medical specialty organization in the United States,
representing allergists, asthma specialists, clinical immunologists, allied
health professionals, and others with a special interest in the research and
treatment of allergic disease. Established in 1943, the AAAAI has nearly
6,300 members in the United States, Canada and 60 other countries.
SNAPSHOT OF MEASLES
Please see the attached .pdf graph from ONS mortality stats. Measles vaccine
was introduced in 1968. However, by 1967 measles deaths had fallen to a ten
year average of 86 pa for all ages. And deaths had been dropping fast and were
continuing to drop.
|10 Year Period to
||10 Year Average
All childhood diseases follow this identical pattern. I can produce graphs for
all the diseases from the offical statistics from ONS which I have in electronic
Please note that 21 children pa are now dying from asthma. The Anaphylaxis
Campaign estimates 20 deaths pa from anaphylaxis. The current deaths are
quickly balancing out any claimed savings particularly because measles mortality
was still falling rapidly when the vaccine was introduced.
Morbidity must also be taken into account - the adverse effects of measles in
the few children who perhaps may be left deaf or brain damaged.
Two factors need to be considered on this. As mortality fell, morbidity also
fell. Further, and we now know, measles is much easier to treat than previously
thought and with simple treatments. Peer reviewed studies show we can prevent
the worst effects of measles with vitamin A supplementation. This has the
advantage over vaccination of providing broader disease protection and also
poorer children will grow up overall healthier and stronger with less disease.
Had we been developing treatments over the past 30 years in addition to
immunoglobulin and vitamin A we would have no issue on this at all now.
Vitamin A supplementation has been shown to reduce the mortality rate due to
measles dramatically. In this randomised clinical trial only 2 deaths in the
vitamin A treated group against 10 in the placebo group. And it reduced
morbidity by half:-
A randomized, controlled trial of vitamin A in children with severe measles.
Hussey GD, Klein M. N Engl J Med. 1990 Jul 19;323(3):160-4
There are a number of peer reviewed publications documenting the effect of
vitamin A on human disease resistance. WHO have been busily scurrying around
the world administering vitamin A to third world children and have even been
looking at a genetically modified rice rich in vitamin A as a way of enhancing
children's own disease resistance.
Without doubt the already low and falling mortality and morbidity from measles
could have been eradicated by developing the treatments we already know of.
Whilst not so lucrative as vaccines for the pharmaceutical industry, the overall
cost/benefit to the nation financially and in life quality would undoubtedly be
a safer healthier nation with a substantially reduced burden on social,
healthcare and education budgets.
Further, the effects of what we are doing to the sick and malnourished children
of the third world have yet to be studied. WHO produces only "estimates" to
support an intervention which on the above figures it seems we may have
difficulty justifying clinically, economically or ethically for our own first
It is interesting in the light of the foregoing, that whilst the pharmaceutical
industry has successfully lobbied at an EU level for stringent controls on
vitamin, health food and food supplements, I am informed that they have also
been busy buying up these competiting businesses. And this perhaps is at a
lower price had the new EU laws not been effected.
There is a temptation to say, "OK, let's have vaccines without excipients and
adjuvants". Will that be the solution? "Solution" suggests there is a problem
and careful study of the trends indicate that the "problem" is nothing like what
we have been led to believe but of lesser significance regardless of our
failures to develop effective treatments. Further, even if there was a problem
and even if a need was demonstrated, the safety would need to be established
before any step could be taken.
I am quietly confident that any truly independent, impartial and careful
analysis would indicate that overall cost/benefit for the individual, the nation
and the third world is weighted heavily in favour of alternative interventions.
It is also my belief that in addition to there being scant safety information on
long term acute and chronic illness caused by vaccination practices, our New
Labour government will be unable to lay their hands on a single cost/benefit
study either at all or one that survives any reasonable scrutiny. I had, for
example, requested under FOIA, a copy of the cost benefit analysis underpinning
the proposals to introduce universal varicella vaccination. What I was sent did
not vaguely resemble any form of cost/benefit analysis.
THE AVALANCHE OF AUTISM
I have submitted a paper on 26th September for peer review in a medical
journal which lays claim to demonstrating that the increase in pervasive
development disorders/autistic disorders (DSM IV/ICD10) since the mid
- is a real increase which cannot be attributed to better diagnosis
or greater awareness;
- the increase commenced during the period 1988 to 1993
- is attributable to one or more environmental causes, irrespective of
any postulated pre-existing genetic predisposition
- appears associated to changes in childhood immunisation schedules
during that period
The conclusions are presented on the basis of three sets of data from four
independent and diverse sources, and which data support the paper's
conclusions. One of the sets of data draws on the study
Advancing Paternal Age and Autism
 published Monday 4th September in
the Archives of General Psychiatry in combination with the Baird paper
published in July this year .
The Baird and Paternal Age papers indicate an increase in PDDs of up to 1200
percent between the mid 1980s and 1996, of which the minimum increase in
autism is 300% on Baird's narrow definition and is otherwise 450% on Baird's
figures based on DSM IV/ICD 10 criteria. Previously this increase has been
dismissed as "better diagnosis" and "greater awareness" as the government
and others claim. Baird in combination with the Paternal Age study permit
an "apples for apples" comparison based on contemporary criteria applied to
subjects born respectively in a two year period ending not later than 1996
and a six year period ending no later than 1988.
These two papers, in combination with other papers documenting PDD
prevalences, confirm the problem is international and validates at least
order of scale comparisons of prevalence across first world western economy
It is of interest that a lawyer living in a village in Kent is publishing
peer reviewed papers on these kinds of topics. The MRC's investigations
into the links between autism and immunisation omitted consideration of
relevant material and predictably played safe by closely following the
However, apart from why it is that a lawyer is writing these kinds of papers
when the MRC has not been, the questions people should be asking are:-
- why is the link to childhood vaccinations not being thoroughly
investigated with clinical science instead of easily manipulated
- what is the government doing about it now;
- what is the government going to do when all these children require
special education and after draining the social services budgets and
healthcare budgets, they then turn 18 and are unemployable.
These are questions I sincerely doubt this "Consultation" will either
address or answer with any conviction or convincing answers.
Research for the MRC
Clearly, time is long overdue for proper studies comparing exposed
populations to non exposed populations in careful independent and impartial
studies. Regrettably, there does not seem much chance of that happening.
As it is tacitly accepted by the authors of the Paternal Age paper and as
appears to be the case from a review of the literature, that a study of
jewish Israeli subjects born in Israel can be relevant to subjects born and
living in other nations, there must therefore be good reason to study why
autism appears to be almost unknown in the Amish. The argument that the
Amish might be genetically different is clearly an inappropriate diversion
from appropriate action. A further study of a population of Israeli
citizens published in 2001  concludes (and MRC take careful note):-
"The epidemiological characteristics found in the Haifa area are
similar to those reported from non-Israeli communities. This finding
supports an underlying biological mechanism for this disorder. These
data can be used for future trend analyses in Israel."
A Review of the MRC's Approach To Autism Research
I quote with his express general permission, the following statements to me in a
private communication from Paul Shattock, Director of the
Autism Research Unit,
"....... I know that some very eminent child psychistrists (Baird,
Le-Couteur and others) submitted an excellent proposal for gluten free
trials and autism but the MRC turned it down and funded studies that are
of comparatively minor interest or usefulness. ............
The vast majority of their money appears to be spent on genetics or
on brain imaging which may be of scientific interest but so far has
given a completely nil return in terms of practical benefits to people
with ASDs or their families. .......................
............. We are self funding a number of biggish projects right
now. ................. Quite frankly, the only way one can conduct the
research that actually needs doing is to get your own money. MRC funded
research is so "safe" ....
......... the MRC has performed pathetically and betrayed people with
ASDs and the politicians who should be able to leave such decisions to them.
I think the MRC actually believe that they are doing a good job in
only funding studies that fit in with their own agendas - what we, as
parents, think of as "so what?" research.
..... all the meaningful research has involved parental input. All
the biomedical teams are either run by parents (such as ours; Rimland's
studies) or have substantial parent input in terms of finance and moral
support (Reichelt's in Norway, Waring's, Jill James (Arkansas) and, of
....... I am not saying that the genetic, brainscanning type studies
should not be done but they should be accompanied and balanced by areas
which hold promise of useful interventions or prevention.........
I stress that I am not attacking physicians or researchers
(geneticists or otherwise) who do get grants. These are the areas in
which they are expert and in which they work. They could not pretend
Fortunately, the American NIMH seem to have had a kick up the bottom and
just this year are looking at projects that are of relevance. I would like
to think that the MRC would take a leaf out of their book."
In the light of the foregoing, any conclusions of this "Consultation", which is
funded and executed by those among whose number seem to be representatives of
the vested and other interests responsible for overseeing what is the largest
public health disaster in history, can happily be ignored in so far as any
pretence is made as to their reliability as independent conclusions. What they
cannot be ignored as is their likely use as a political tool to continue the
public health mayhem started in the 1980s without any safety studies of any note
and continued to this day in the same fashion.
Publication of two peer reviewed papers, one currently in press and one in
review to follow shortly. Other papers in research.
Clifford G. Miller
50 Burnhill Road, Beckenham, Kent BR3 3LA, England
 “Advancing Paternal Age and Autism” Abraham Reichenberg; Raz Gross; Mark
Weiser; Michealine Bresnahan; Jeremy Silverman; Susan Harlap; Jonathan
Rabinowitz; Cory Shulman; Dolores Malaspina; Gad Lubin; Haim Y. Knobler; Michael
Davidson; Ezra SusserArch Gen Psychiatry 2006; 63: 1026-1032
 Prevalence of disorders of the autism spectrum in a population cohort of
children in South Thames: the Special Needs and Autism Project (SNAP). Baird G,
Simonoff E, Pickles A, Chandler S, Loucas T, Meldrum D, Charman T. Lancet. 2006
 Autism in the Haifa
area--an epidemiological perspective. Michael Davidovitch, MD, Gabriela Holtzman, MD and Emanuel Tirosh,
MD.IMAJ 2001: 3: March: 188-189