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Key information omitted from WA No Jab No Play discussion paper

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The Western Australia Department of Health is currently conducting a public consultation into the government’s proposed No Jab No Play law.  The consultation closes on 26 March 2019.

Guide to making a submission

We will be publishing a guide to making a submission by next Tuesday 19 March, so if you are unsure about how you should answer some of the questions, we would suggest waiting until then before making a submission.  One of our volunteers will be available to answer any further questions once the guide is released.

Also see: Physicians call for moratorium on WA No Jab No Play pending independent review

FOI documents revealing

Documents obtained through Freedom of Information (FOI) by a concerned member of the public, and provided to the AVN, show that some key information was omitted from the No Jab No Play Discussion Paper.

Vaccination rate may already be at 95%

The vaccination rate in Western Australia may already be at the aspirational target of 95%, but this information has not been provided in the discussion paper.

According to data in the Australian Immunisation Register (AIR), 93%, 90% and 93% of WA children are fully immunised at one, two, and five years of age, respectively. The AIR data underestimate the proportion of fully immunised children in WA by approximately 4-5% due to sub-optimal data capture; this suggests overall coverage in WA is around 95%.

Source: Contentious Issue Briefing Note: No Jab, No Play Policy – 01 August 2018

No Jab No Play not the best option

An impact assessment conducted by the Department of Health in late 2016, which involved consultation with industry stakeholders (but not the general public), found that a requirement for parents to produce vaccination history/status documentation when enrolling their children provided the best net benefit to cost ratio, when compared with a vaccination requirement (No Jab No Play).

Preferred Option
Best net benefit to cost ratio. The end result will be that childhood vaccination rates will rise, preventing illness and ultimately saving health resources, without invoking the potential adverse consequences of denying a small number of children the benefits of early childhood education or creating lower household incomes in these families because parents were unable to attend work without childcare.

Source: Preliminary Impact Assessment – Immunisation Status Reporting – 13 December 2016 (page 4)

The preferred option (Option A in the current public consultation) has already been implemented in Western Australia.  Effective from 01 January 2019, childcare services, kindergartens and schools in Western Australia are required to collect and, on request by the Chief Health Officer, report on the vaccination status of all students, in accordance with new regulations made under the Public Health Act 2016.  This is a documentation requirement only, and does not require children to be up-to-date with scheduled vaccinations.

COAG process sidelined

The urgency to implement No Jab No Play in Western Australia, despite there being no evidence for its necessity, is being driven by Premier Mark McGowan, possibly to prevent agreement on a more moderate national approach by the Council of Australian Governments (COAG).  Only two states, Victoria and New South Wales, have implemented highly draconian No Jab No Play laws to date; if Western Australia enacts a similar law to those states, a more moderate national approach will become less likely.

On 2 August 2018, the Prime Minister wrote to the Premier proposing that COAG assess the costs, benefits and regulatory impacts of a national approach to mandatory immunisation requirements for early education and care.

The Prime Minister expects assessment of the national approach to be completed by March 2019, ahead of national agreement next year.

The Premier has indicated that WA will take a proactive position on this issue, regardless of an COAG decision.

Source: DPC Minute to the Community Safety and Family Support Cabinet Sub-Committee (CSFS) Meeting of 20 August 2018 – 03 August 2018

Further background information about COAG deliberations are available in a Briefing Note to the Minister for Health dated 28 June 2018.

Impact of federal No Jab No Pay law

A 2017 discussion paper noted that the federal No jab No Pay law has had little impact on vaccination rates, but as we know only too well, has caused significant harm to families.

There is little evidence from national childhood immunisation rates that the 2016 ‘No Jab, No Pay’ law has had any substantive impact on improving vaccination coverage in young children.

Source: Options for improving childhood vaccination rates including ‘No Jab No Play’ – talking points – 09 August 2017

Other omissions

Section 4.1 of the No Jab No Play Discussion Paper, which relates to notifications of so-called vaccine-preventable diseases, is particularly misleading, due to the way the information has been framed, or by the omission of key collateral information.  See for example Omissions – Consultation Regulatory Impact Assessment – WA No Jab No Play – Section 4.1.

All of the above information should have been provided in the No Jab No Play Discussion Paper.  It is not open to the Department of Health to promote the political position of the government of the day, by selectively disclosing information, or framing information in a way that may mislead politicians voting on the No Jab No Play bill, as well as the general public.  It is appalling that health departments across Australia appear to have been compromised in this way.

We reported last year that Dr. Stephen Lambert from Queensland Health, who has previously acted as Queensland’s Chief Health Officer, is also on the management team of mandatory vaccination hate group, Stop the Australian Vaccination Network (SAVN).  Notably, he has since deleted his Twitter account.

It is plausible that doctors from other health departments are also members of SAVN.  WA Health doctor, Paul Effler, the Project Manager for the No Jab No Play Public Consultation, has certainly been associated with the leaders of SAVN splinter group Light for Riley (Catherine and Greg Hughes).  As Tyrannical Times reported in 2017, Dr. Effler initiated the Whooping Cough pregnancy vaccination on or around the day Riley Hughes was admitted to hospital (13 March 2015), rather than in response to his death (which is what the general public have been misled to believe).

Light for Riley Factchecker has suggested that Dr. Effler handpicked Catherine and Greg Hughes to be the face of Whooping Cough pregnancy vaccination in order to create a sense of urgency that a national approach was required, following low uptake of pregnancy vaccination in Queensland, which had been trialling pregnancy vaccination since July 2014.

We will be writing to the Better Regulation Unit, which oversees the conduct of Regulatory Impact Assessments, to bring this information to their attention.

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