2021 COVID-19 response: Letters to the Children's Commissioner

Re: Developing a Covid-19 strategy that prioritises vulnerable populations

19 October 2021
To: This email address is being protected from spambots. You need JavaScript enabled to view it.

Dear Judge Becroft and Tracy -

Most recently myself and a colleague presented (via zoom) to Dr Liz Craig and other MP members of the Health Select Committee on the subject of proposed new legislation that seeks to increase controls concerning isolation, and to increase penalties. We consider that our submission outlines a greater problem in Aotearoa New Zealand that requires deep reflection, in order to undertake the most appropriate steps to protect our young people and our children.

Our greatest concern is that the downplaying and marginalising of the scientifically recognised role of natural immunity, is risking the health of healthy children - while commensurately delaying the process of achieving herd immunity (and thereby protecting vulnerable groups with weak immune systems. The information and data that supports our position, plus the link to my presentation to the select committee is available here: https://psgr.org.nz/sars-cov-2-covid-19

PSGR's position is that vaccination should prioritise the elderly and those with substantial comorbidities (unfortunately this includes the disease of obesity which is tightly wound to poverty). In contrast healthy younger groups have less risk of COVID-19 than they do of influenza (Yilmaz, Ibrahim).

PSGR's position emphasised the plaguing problem of obesity and diabetes (2020) stemming from structural poverty, the undernutrition in these groups that increases risk of symptomatic infection, and the absence of government policy to increase nutritional supports to these groups. An OIA request to the Ministry of Health had earlier confirmed no other health protective policy has been undertaken in this pandemic.

The vaccine studies (Tartof, Levin) demonstrate that the vaccines only provide immunity up to 6 months, however and when they wane, when breakthrough infection (Riemersma) may happen can never be clear. Boosters from then on come with uncertainties. Unlike each year where a flu vaccine is 'updated' this is not the case for the current mRNA vaccine in use presently.

In PSGR's presentation to Dr Craig and members, we highlighted the solid base of scientific literature that demonstrates that healthy groups that elect to not get the vaccine - evidentially have longer and more durable (robust) immunity from present and unknown variants than the vaccinated.

Therefore - perhaps 6 issues are important - but remain downplayed by the state and by the media:

Those who have obesity and severe multimorbidities will be helped by vaccination - but they are also at constant risk of vaccines waning (this is a bigger problem for immunosuppressed groups) (This is why we recommended against punitive legislation- 'cases' are frequently poorer groups with poor immune systems, particularly Pasifika and Māori).
Families and friends of immunocompromised may help their loved one's long term if they get vaccinated - however, due to the waning potential substantial uncertainties remain.
Healthy families and friends of immunocompromised may help if they actually acquire robust immunity from exposure to the native virus/delta variant (Wang) - particularly while their loved ones are vaccinated- as they
will be more resilient to new variants. This is how pandemics slow and wane (the virus becomes endemic)
Young people will benefit from long term natural immunity, and this can be compared to pervasive uncertainty relating to novel mRNA vaccine safety.
The decline observed by Te Punaha reflects international trends, and this will also be assisted as the weather warms.
The fact that vaccines do not prevent transmission of the infection, render vaccine mandates invalid (Leask). The clinical trials for mRNA vaccines were not designed to assess whether COVID-19 vaccines prevented infection with or transmission of Sars-Cov-2.4
The pervasive problem of waning and breakthrough consequently mean that calls for vaccine mandates lack authoritative 'legs'.
Extensive data supports vitamin D as an adjunctive therapy (the Nordic states have adopted this position). For families from low-incomes with at risk members, requesting vitamin D tests, and if low-income - injections of vitamin D (plus access to other nutrients such as zinc, and vitamin C), is illustrated in the literature to be an effective adjuvant/combinatory therapy (Borsche, Ngo). (Pasifika and Māori have particularly low levels) - this may arguably shift health policy towards health equity - rather than simply 'medical' equity. We consider that the MoH has relied on regulatory protocols which narrowly judge vitamin D's usefulness rather than considering broader public health Bradford-Hill criteria (as a proven low risk treatment).

We can provide all the papers cited in our links. We have attached a few to provide emphasis for this (relatively) short
communication. We recognise the pervasive uncertainty and the tightrope of what might constitute a 'healthy' child.

However, the evidence is clear that a single condition such as asthma presents low risk - the risk is when multiple
conditions are combined. We also acknowledge the issue of pre-diabetes in the population that may increase risk. As
we have noted, no steps have been taken by the state to implement health protective policy which might reduce
diabetes.

The data supports a shift to recognising that those who acquire natural immunity act as population 'buffers'; and that
those at risk be prioritised for multi-target medical and nutritional support, due to the plaguing risk of infection from
Sars-Cov-2 and future variants.

Deficiencies in the at-risk populations have not been addressed by the state, and treatments at this stage are rudimentary (July 2021, October 2021) when compared with the complex pathology of the disease (Marik) ensure that low nutrient status of vulnerable low-income groups is targeted in addition to antithrombotic, antiviral (etc) therapies (eg. Ngo).

Unfortunately, Aotearoa's modelling for a 'future strategy' did not include waning and breakthrough, even though these issues were recognised at the time.

We cannot identify a public health official who is discussing these issues. We certainly understand that the above
perspective will have difficulty being covered by the media at this point in time.

The absence of discussion relating to the issues of waning, breakthrough - and relative risk to children in the NZ modelling is startling. We want to believe a single treatment is sufficient, but the science is pointing to the evidence that this is unlikely. By only discussing vaccines - and excluding broader dialogue - ironically, we fail to protect our most vulnerable.

PSGR would welcome an opportunity to meet to discuss this issue further.

Kind regards| Ngā mihi

Jodie Bruning.

Tracy Ford <This email address is being protected from spambots. You need JavaScript enabled to view it.>

To: <This email address is being protected from spambots. You need JavaScript enabled to view it.>
Kia ora Jodie,

Thank you for your email of today, 19 October 2021, regarding Covid vaccines, natural immunity, and impacts of legislation and governmental decisions on children – and your view that

As you can imagine, we receive a very high volume of emails on a range of topics and are unable to always individually respond to, or advocate on, every issue. Please be assured that

We appreciate you sharing your concerns with us. Unfortunately I am unable to offer you a meeting at this time. Your email will be passed to the appropriate personnel within our office

Nga mihi

Tracy Ford
Senior Executive Assistant to the Children’s Commissioner
Kaiāwhina ki te Kaikōmihana mō ngā Tamariki o Aotearoa

October 22, 2021.

Sarah Morris <This email address is being protected from spambots. You need JavaScript enabled to view it.>
To: "This email address is being protected from spambots. You need JavaScript enabled to view it." <This email address is being protected from spambots. You need JavaScript enabled to view it.>
Tēnā koe,

Thank you for taking the time to write to the Children’s Commissioner, Judge Andrew Becroft. I am responding on his behalf.

We thank you for your concern for keeping children safe and well. The Children’s Commissioner stands by his support for vaccinating all those who are eligible. This is to reduce spread important that children and their families are kept safe from Covid19 infection, which poses significant and real risks, including death, to some children and many adults. The evidence to achieving this protection.

We have sought advice from New Zealand’s Chief Science Advisor to the Ministry of Health, who, in turn, is advised by a panel of experts in the fields of public health, immunology and
are being very closely followed. So far, the evidence is very reassuring, but if that changes, the vaccine strategy will also change.

Covid19 infection still poses a risk of severe illness to all people, including children and, given those rates are higher in the populations we advocate for most, we are encouraging every

Again, thank you for sharing you concerns for the wellbeing of children.

Ngā mihi
Sarah Morris (she/her)
Manager Advice – Strategy, Rights and Advice
Te Tari o te Kaikomihana mō ngā Tamariki
Office of the Children’s Commissioner www.occ.org.nz

Letter posted to the new Children's Commissioner.

16 December 2021

Judge Frances Eivers

Office of the Children's Commissioner

PO Box 5610

Lambton Key

Wellington 6145

Dear Judge Eivers,

RE: INDEPENDENT SCIENCE & ADVOCACY FOR THE RIGHTS OF CHILDREN

On behalf of all Trustees of Physicians & Scientists for Global Responsibility (PSGR) we would like to congratulate you on your appointment to the Office of the Commissioner for Children and extend a warm welcome to you.

By way of a brief introduction, PSGR comprises of a network of primarily scientists and physicians; that network also has strong links to both public law and international public law.

In relation to matters of law, PSGR provides particular scrutiny of government administration and its degree of compliance (or otherwise) with fundamental principles of law on priority human and environmental issues.

In the 1980s, government-administrative reforms introduced a primarily ‘more-market’ focus; and the former Department of Scientific & Industrial Research (DSIR) was abolished.

Those reforms therefore removed an important source of independent scientific advice to government; independent advice that had earlier been available from the DSIR and which was required to give due weight to ‘the public interest’ and ‘the precautionary principle’.

Since that time, PSGR Trustees have been struggling to assert the public interest and precautionary principle within both legislative processes and the every-day workings of the NZ machinery-of-government and its statutory decision-making. It is a most difficult and challenging task for PSGR.

A focus on children & inter-generational considerations

Much of PSGRs setting of priorities and projects has necessarily needed to be focussed upon inter-generational issues; and therefore, that focus has been inclusive of todays and tomorrow’s children – as well as the environmental circumstances that they are likely to face.

PSGR is at advanced stage of preparing a discussion paper on pressing issues relating to the right to health and poor immune system performance due to sub-optimal living conditions combined with food-intakes that are low on safety and low on nutritional value, and the role of prevention and protection during COVID-19.

Children have rights at national and international law to safe and adequate food – or, in the short-term absence of those conditions, to safe and effective interventions that will enable them to develop effective immune systems. Yet throughout COVID-19, no nutrition and hence immuno-protective policy has been enacted that might support health equity in low-income and vulnerable sectors.

Our PSGR research has indicated that there is a need for strong advocacy to secure strong immune system functioning for children – especially now that our species is facing what seems to be a long list of pandemic viral challenges.

The current Sars-Cov-2 virus is illustrating the weakness: earlier the World Health Organisation (WHO) had warned that when a virus of the pathogenicity of H5N1 gains human-to-human transmissibility, our species would be sorely tested if it had not learnt the importance of people developing robust immune systems. Now is the time to learn.

New Zealand requires urgent and community ‘bottom-up’ steps to be taken to protect the immune system health of high-risk communities.

Arguably there is now urgency to review current administrative government decision-making because of its intention to extend Pfizer gene-therapy – Comirnaty BNT162b2 - inoculation to children. There is increasing evidence that children are demonstrably not at risk from Sars-Cov-2; those that are at risk from COVID-19 risk vaccine failure due to suppressed immune systems. In addition, regulatory triggers that conventionally would have led to the withdrawal of mRNA vaccines (following evidence of harm), or that may have, at a minimum, signalled the need to rework relative risk calculations relating to children, have gone unheeded.

Following the principle, first do no harm, and with years of observing pakeha, Māori and other ethnic communities presenting with real-life complex health conditions in their clinics, PSGR physicians are concerned that a generic (global) approach to vaccination fails to account for both the robustly healthy and the vulnerable immunocompromised.

PSGR would therefore be most grateful for your assessment of our paper that will be completed very shortly. We would also be delighted to appear before you to discuss that paper and possible initiatives that might arise from it.

Arguably there is now urgency to review current administrative government decision-making because of its intention to extend Pfizer gene-therapy inoculation to children.

PSGR’s analyses of the relevant science is that the current gene-therapy inoculation does not meaningfully prevent the spread of the current variant, and the; however, it does seem to reduce the seriousness of an infection in adults who have ineffective immune systems.

Therefore, because children who have not had the gene-therapy inoculation are very unlikely to suffer serious morbidities, there appears to be no compelling reason why government administrative policy should target placing healthy children at unnecessary risk when both medium and long-term risks to children - of repetitive inoculations - are totally unknown; while there is substantial evidence that populations with poor immune systems can be protected from targeted immune-protective treatments which prevents hospitalisation and death.

PSGR would therefore be most grateful for your assessment of our paper that will be completed very shortly. We would also be delighted to appear before you to discuss that paper and possible initiatives that might arise from it.

For example, there is a reasonable probability of lasting damage to childrens’ heart and immune systems. But government administration is not disclosing what relevant consideration it has given to such factors; nor what due weight has been accorded to such factors.

Government administrative decision-making is not transparent to the families being asked to inoculate their children. Therefore, it seems to PSGR that the children of our Country need the scrutiny and powers of your Office to protect their lives from an arguably unnecessary inoculation. There is no evidence publicly available that government administration has considered and given due weight to all of the relevant facts, evidence and also given due weight to the Precautionary Principle.

Once again, we reflect on the statutory purposes, functions and scope of your Office at this most critical time for protecting our children: a high priority is to strengthen our childrens’ ability to resist disease by intrinsically-safe measures such as dietary reinforcements so that they can run effective immune systems.

By the end of next week, we aim to place with you our paper on this topic.

We would warmly welcome an opportunity to provide on-going support to your Office in the form of independent science assessments in relation to the rights-to-health of children in these challenging times.

Thus, New Zealand may avoid - through effective scrutiny of the science behind government administrative decision-making - the growing threat to public confidence in governments from unaccountable government decision-making.

Yours sincerely,

PSGR.

No response was received to the December 16, 2021 letter.

2021 COVID-19 response: Letters to the Children's Commissioner

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