March 23, 2022
The Honorable Richard Pan, Chair
Senate Health Committee
1021 O Street, Room 3310
Sacramento, CA 95814
Re: SB-871 Public health: immunizations - OPPOSE
Dear Senator Pan:
We are writing as members and scientific advisors of California Parent Power, a grassroots network of parents advocating for sensible, data-driven policies for children.
As physicians and scientists, we recognize the immense benefits of childhood vaccines that are currently mandated by law for schoolchildren in California, which include diphtheria, hepatitis B, haemophilus influenza type b, measles, mumps, pertussis, rubella, and tetanus. We also view the COVID vaccines as remarkable lifesaving advances and have broadly encouraged their use as our most potent tool against COVID, because the data has so clearly shown their tremendous benefit in most populations. However, the data shows a more complex picture for children, such that mandating COVID vaccination is likely to do more harm than good. Consequently, we are writing to express our opposition to SB871, which, among other things, would require all children K-12 to be vaccinated against Covid-19 in order to attend school in person after January 1, 2023.
To summarize our concerns:
1) SB 871 will likely cause net medical harm for children who already have COVID immunity from prior vaccination or infection. This group constitutes a majority of California children.
2) The ability of COVID vaccines to prevent virus transmission is marginal and decreasing.
3) While the adverse event risks of COVID vaccination are small at an individual level, they are real and will manifest in broad population use. The benefits of mandatory COVID vaccination in children cannot be confidently said to outweigh these risks in a population in which COVID immunity is already widespread.
4) Mandating a vaccine under these circumstances will lead to additional unintended negative societal consequences, including reduced public school enrollment and funding, learning loss for children kept from the educational system, and increased vaccine hesitancy for other critical childhood vaccines.
Below we address each of these points in greater detail backed by the most recent data.
1.SB 871 may cause net medical harm for the vast majority of children who already have immunity to COVID
Fortunately, children are the group at lowest risk of severe disease from COVID. We are doubly fortunate that all available evidence shows that immunity in healthy children, whether vaccine-derived or infection-derived, is nearly 100% effective in preventing severe disease upon subsequent COVID infection.
For immune-naive (unvaccinated and no prior infection) children, even a single dose of COVID vaccine virtually eliminates severe disease risk in even high risk children, with no demonstrable benefit to a second dose.
Figure 1: Vaccine effectiveness against adolescent hospitalization and ICU admission
Furthermore, a large CDC study with data from New York and California found no extra benefit against severe disease from vaccination following infection, and immunity following infection is durable: post-infection antibody response has now been measured out to 20 months and counting.
Consequently, in children who already have COVID immunity, any further vaccine doses do not provide demonstrable clinical benefit to the children being vaccinated. This group is overwhelmingly large and ever-increasing. Around 40% of 5-11 year olds and 66% of 12-17 year olds have already received at least one vaccine dose. To this we must add those with immunity from prior COVID infections. Per CDC data, nearly 60% of children under 17 years old had evidence of infection-induced immunity by January 2022. That was the middle of the Omicron wave, so that number is now likely higher than 70%. Combining vaccine-induced and infection-induced immunity, the overwhelming majority of California children affected by the SB-871 mandate would not benefit from additional required vaccinations.
2. Global data and studies show COVID vaccines now have a small and uncertain benefit in reducing transmission and preventing infection.
While continuing to reduce severe disease in those without immunity, the vaccines are now poor at preventing both transmission and infection, even when boosted.
For the first few months post-vaccination, these vaccines reduce the chance of infection somewhat, but that protective effect declines rapidly (see data below). This pattern is consistent across multiple countries which are more vaccinated and boosted than even California (Denmark, UK, Iceland, New Zealand).
Currently, vaccinated, boosted or unvaccinated people who become infected are all roughly equally likely to transmit to others in their household. A hallmark Danish study shows similar transmission from infected people who are unvaccinated, double vaccinated or have had a booster (29% vs. 32% vs. 25%).
Our California experience with Omicron reinforces the above. During January 2022, 79% of cases in the Berkeley Unified School District were in fully vaccinated students. This approximates the vaccination rate in that community at that time.
This is consistent with the recent discovery of rapidly waning vaccine efficacy of only 12% in the 5 to 11-year-old age group after only 4 weeks.
3. While the adverse event risks of COVID vaccination in children are small at an individual level, they are real and will manifest in broad population use.
Given the robust effectiveness of COVID immunity, we must seriously weigh any potential adverse events from requiring additional COVID vaccine doses in all children. The near-term harms of these vaccines are statistically low, but large enough to ensure they will manifest with population-wide mandatory use. Most importantly, potentially serious heart inflammation (myocarditis) is a rare but well-documented issue with COVID vaccines in children, particularly after 2nd or 3rd doses, and particularly in otherwise healthy adolescents aged 12-17.
In adolescents 12 to 17, vaccine-induced myocarditis occurs at a rate of between 1/10,000 and 1/3300 with the highest rates in adolescent boys. A Kaiser chart review demonstrated that official reporting undercounted cases. With 3.5 million adolescents in the State of California, we can expect 300 to 600 cases of vaccine-induced myocarditis in otherwise healthy boys, most of which could be avoided given the majority have immunity from prior infection. These cases would constitute clear violations of the “first, do no harm” principle.
The topic of “Long COVID” comes up frequently as a justification for accepting these risks of vaccine side effects. However, high quality studies show that post-infection symptoms after COVID infection in children are similar to those after other common childhood infections. This includes a large UK database analysis, which found no difference in prevalence of Long COVID-like symptoms among children who had COVID and control children who had not been infected. A recent large Danish study confirmed these findings. Thus, concerns about long COVID in children cannot justify imposing even rare known harms on children when the overwhelming majority of those children already have protective immunity against severe disease.
4. Imposing this vaccine as a mandate would have negative consequences on children’s overall well-being.
Given the limited and unclear benefits, along with the known risks of mandating COVID vaccination in children, many parents are understandably hesitant to vaccinate their children at this time. Forcing them to do so in the absence of convincing evidence will foment distrust of doctors, public health officials and even the public school system. This distrust could lead to lower rates of vaccination for other childhood diseases for which the benefits of vaccination clearly outweigh the risks.
If this bill were to pass, unvaccinated children would either be forced into remote learning or out of the school system altogether undermining their ability to catch up on critical academic and social experiences. In December, when the Los Angeles Unified School District tried to implement a K-12 Covid-19 vaccine mandate, they found that 30,000 students ages 12 and older hadn’t met the mandate requirements. If we extrapolate those numbers to the entire state, and take into account lower vaccination rates among children ages 5 to 11, over one million California children could be forced into remote learning for no measurable societal benefit. Equity considerations demand that we acknowledge that Black and Latino children are less likely to be vaccinated and therefore more likely to be excluded from school than their white peers.
For children of all economic backgrounds, schools act as a safety net. Low-income children who would end up being forced out of school by this bill rely on crucial services provided through the public school system. This would negatively impact the physical and mental health of these children compounding the impact of learning loss that without adequate in-person instruction.
In closing, mandating a COVID vaccination is imprudent and very likely to do more harm than good (both medically and socially) given the high rate of COVID immunity in both children and the population at large. These harms would come with fleeting protection against transmission in schools while simultaneously banishing hundreds of thousands of kids from in-person learning. Consequently, we urge committee members to vote “no” on SB-871.
Regards,
Scott Balsitis, PhD
Dr. Balsitis is a viral immunologist and vaccine developer living in San Mateo county, and the father of two children.
Tracy Beth Hoeg MD, PhD
Dr. Hoeg is a physician-scientist affiliated with the University of California-Davis. As an Epidemiologist, her academic focus of late has been on COVID transmission in schools and risk benefit analysis of COVID vaccination in adolescents. She is the mother of 4 children.
Ram Duriseti MD, PhD
Dr. Duriseti is a physician-scientist who practices Emergency Medicine with a focus in Pediatric Emergency Medicine at Stanford Health and General Emergency Medicine in Sutter Health. His doctoral background is in statistical computing and computational modeling of complex decisions. He is the father of 3 children.