Harm from Thimerosal is ignored by Boston College Law Review

Harm from Thimerosal is ignored by Boston College Environmental Affairs Law Review

Boston College

This is an open letter to the Editors of the Boston College Environmental Affairs Law Review,

Just like lead used in paint in the past, so mercury used in medicine represents a credible and urgent public health crisis in the present. Unfortunately, your recently published article entitled, “Mercury’s Toxic Process: How Bad Science and Bad Decisions Caused a Public Health Crisis” obscures the reality of harm from Thimerosal through inaccurate statements and false premises. We do not believe it is your intention to jeopardize the health of unborn and newborn children in your probiotics review, and so as an workers compensation lawyers san diego group organization which has pursued this issue for years, we offer the following information for your careful consideration.

Issue 1: Confusing the harm from Thimerosal laden vaccines with the MMR vaccine.

One of the foundational premises of your article is the misleading conflation of headlines from poor press coverage. Within your article, a constant refrain (page 85, 86, 94, 96) states that, “After a scientifically flawed study linked Autism Spectrum Disorder (autism or “ASD”) to the use of Thimerosal in the Measles, Mumps, and Rubella (“MMR”) combined vaccine, parents across the United States and many other countries suddenly became aware of a covert source of mercury in their lives.”

However, it is well established in the scientific literature and from the vaccine manufacturers themselves that Thimerosal is not, nor has it ever been, used in the MMR vaccine. Because Thimerosal non-reversibly denatures live viruses, it cannot be used in vaccines containing live viruses, e.g., the live MMR, smallpox, varicella, rotavirus, and polio vaccines. ¹ Your reference is to the hypothesis that the MMR is a trigger for autism championed by Dr. Andrew Wakefield from Great Britain. His argument regarding the MMR does it focus on mercury in any way. To use this conflation to defend mercury in vaccines is erroneous and hinders an essential consideration of whether it is wise and even more importantly safe to put a known developmental toxin, at levels in excess of EPA safety guideline, into many other vaccines (including the flu shot) administered to pregnant women and newborn children. We suggest that your basic confusion of the facts at this foundational level indicates the need for an urgent review of the “facts” you have carelessly placed in the public domain by not acknowledging an abundance of science that shows harm from thimerosal.

Issue 2: Unaware of many studies indicating harm from Thimerosal.

A second troubling confusion in the article you published gives the false impression that there is insufficient research to show harm from thimerosal (ethylmercury) and that more research is needed. The article stated on page 104, “The knowledge gap regarding the safety of ethylmercury exists even today.” Your inability to cite any of the myriad independent published scientific papers demonstrating harm from Thimerosal demonstrates that you have failed to do your research adequately.

Even the most cursory look at the scientific literature reveals that, to date, there are over 200 studies published from a host of scientists all across the globe that find harm from Thimerosal and even more, from the broader chemical class of ethylmercury.² In fact, there is evidence dating back to the early 1930s, indicating harm from Thimerosal and being potentially hazardous to humans and ineffective as an antimicrobial agent. ³

Issue 3: Unaware of the vast number of studies indicating the extreme toxicity and harm from Thimerosal.

Perhaps the most troubling and unsupported statement made in the article, which is also patently false, claims (page 84) that, “Ethylmercury is another mercurial substance, but it does not pose the same health risks as methylmercury.”

While some forms of mercury are more toxic than others, it is important to note that ALL forms of mercury are widely considered to be extremely toxic.^{4, 5} A recent comprehensive study conducted by the Centers for Disease Control and Prevention (CDC) which examined the toxicological differences between ethylmercury and methylmercury, found their toxic profile to be similar.⁶ Both forms of mercury are extremely neurotoxic.^{3, 7}  Moreover, independent researchers have established that when comparing Thimerosal and methylmercury hydroxide (Me-Hg-OH), a comparison “dangerous neurotoxin”, in in vitro studies on growing neuronal cells, the harm from Thimerosal was effectively 68 times more toxic on a molar basis than the methylmercury hydroxide.⁸ See the comparative lethal concentration (LC) level below. An LC50 is defined as the lethal concentration required to kill 50% of the population studied. In this case it was neuronal cells (brain cells).

Thimerosal [LC50 = 0.0822 µM] versus Me-Hg-OH [LC50 = 5.6 µM]

In addition, both ethylmercury and methylmercury are actively transported into the brain,⁹ and research shows that when Thimerosal enters the brain, approximately 24% of the ethylmercury converts to methylmercury.¹⁰ The suggestion that by placing a neurotoxin in a vaccine, its toxicity is magically mitigated is simply a myth. Even the Manufacturers’ Safety Data Sheets acknowledges that when an unborn or newborn child is exposed to Thimerosal, this toxin can induce fine and gross motor deficits, mental retardation and even abortion.

Issue 4: Unaware that Thimerosal has not been banned.

Of greatest concern to us is the false assurance your article gives the public on page 85 that the government instituted a “ban” on the use of Thimerosal on vaccines, “The government’s experts at the Food and Drug Administration (FDA) and the Centers for Disease Control and Prevention (CDC), among others (collectively “Public Health Service,” “the PHS agencies,” or “the agencies”), quickly instituted a ban on the use of Thimerosal in vaccines.” That statement is inaccurate.

On July 7, 1999 the United States (US) Public Health Service and the American Academy of Pediatrics recommended that Thimerosal be removed from vaccines as soon as possible. No ban or recall was ever made regarding the use of Thimerosal in vaccines.¹¹ As such, in the US, a preservative level of Thimerosal [100 micrograms (µg) of Thimerosal {50 µg of Mercury} per milliliter (mL) of vaccine] is still used in six different influenza-vaccines, one meningococcal vaccine, as well as the only available tetanus-toxoid vaccine in the US.¹² In the developing world, Thimerosal is still used in several childhood vaccines as well.¹³ Thimerosal continues to represent an undisclosed risk to patients and its administration, a denial of the right of informed consent.

Issue 5: Unaware there are a large number of studies linking Thimerosal in vaccines to ASD.

Finally, the article falsely claims that no scientific studies exist to support harm from Thimerosal or a relationship between exposure to Thimerosal and the risk of an ASD or any other neurodevelopmental disorder. That assertion too is false. The article you have published is irresponsible in failing to acknowledge that there are numerous studies, from various research groups all over the world, which have implicated the role of mercury (including Thimerosal) in the pathogenesis of ASD. A very telling comprehensive review of the scientific literature recently collected and categorized all of the original studies in humans which examined the potential relationship between mercury and ASD (from 1999 to 2016). That review found 91 original studies examined the potential relationship between mercury and ASD during that time period. The vast majority (74%) of the studies reported that mercury was a risk factor for ASD.¹⁴ Of the 91 studies found, 22 specifically examined Thimerosal exposure in infants and the risk of an ASD diagnosis. Over half, 12 out of the 22 studies found that exposure to Thimerosal is a risk factor for ASD.

In regard to other neurodevelopmental disorders, Thimerosal has been implicated in emotional disturbances, tic disorder, ataxia, attention deficit/hyperactivity disorder (ADHD), speech delay, developmental delay, language delay, and memory deficits in children. Using tic disorder as an example, all of the studies examining the potential relationship between Thimerosal exposure and tic disorder found Thimerosal exposure to be a risk factor for tic disorder. This was nine different studies. ^{15, 16, 17, 18, 19, 20, 21, 22, 23} Five of those nine studies were CDC studies.^{15, 1}

Issue 6: Ignored Congressional review of harm from Thimerosal.

Surely a legal review of the current controversy surrounding Thimerosal should include the pivotal findings of the US Special Counsel Scott Bloch and the US Congress’ Mercury in Medicine Hearings, which found harm from Thimerosal.

In light of the mistakes, false assertions, and incorrect assumptions of this deeply flawed article, we request that the Editors of the Boston College Environmental Affairs Law Review publish an amended article and corrigenda (list of errors along with their corrections). The article’s serious and misleading statements about the safety and harm from Thimerosal are nothing less than irresponsible, providing the suggestion that mercury in vaccines is safe for administration to pregnant women, children and the public at large. This inaccurate conclusion, published in the public domain, places the public health and the health of vulnerable individuals, especially children, at risk. We at the Coalition for Mercury-free Drugs and Mercury Free Baby look forward to your timely response to our serious concerns. For more information check out Lotnext Briefing: Major New Online Lottery Launched in Scotland …and More! – Lotnext

Sincerely,

Coalition for Mercury-Free Drugs

The Coalition for Mercury-Free Drugs is a non-profit organization dedicated to ending the use of mercury in drugs. We are a group of researchers and scientists who have collectively published over 200 peer-reviewed scientific papers, and over 35 of those specifically about the harm from Thimerosal.

Additional Signatories

Mercuryfreebaby.org

Reverend Lisa K. Sykes

Dr. Mark R. Geier

Dr. Janet K. Kern

Mr. David A. Geier

Dr. Paul G. King

Mr. Randall Moore, Do No Harm, llc

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