UK GOV Consultation on Covid “Vaccine” etc. suggested response

Open consultation

Consultation document: changes to Human Medicine Regulations to support the rollout of COVID-19 vaccines

Published 28 August 2020


About You

(name and surname)



(individual/ organisation)

(ethnicity and area of UK)

5 areas you can comment on (tick all):

Temporary authorisation of the supply of unlicensed products

No. Authorisation of the supply of unlicensed products, temporary or not, is an extremely dangerous and disproportionate response to the current situation.

Civil liability and immunity

No. Immunity from civil liability means that there is no incentive for pharmaceutical companies (who have a history of causing human harms, especially in developing countries) to ensure that their product is safe and therefore they can act with impunity with profit as their sole concern.

Expansion to the workforce eligible to administer vaccinations

No. Administration of vaccines by unqualified persons is, clearly, unsafe and risks more harm than good.

Vaccine promotion

No. Vaccine promotion violates UK advertising standards and is unsafe.

Provisions for wholesale dealing of vaccines

No. Unlicensed wholesalers should not be dealing with vaccines in any capacity whatsoever. This is clearly unsafe and open to abuse.


How satisfied are you with the consultation process?


How did you hear about the consultation?

(Various options, mine is Social Media)

On which social media channel did you hear about the consultation?

(Department of Health & Social Care/ Another government department/ [mine is Other – individual Twitter])

What could we do better?

  1. “a tested, unlicensed vaccine against COVID-19” suggests that this pharmaceutical product has gone through usual testing. This is untrue and is the reason why it is unlicensed. This wording is misleading and risks human harms.
  2. “the proposed changes will also facilitate the efficient mass distribution of treatments for COVID-19”. Pushing an untested unlicensed drug, administered by unqualified persons, using currently illegal advertising can hardly be described as “efficient mass distribution of treatments”. This wording is misleading and risks human harms.
  3. “Clarify the scope of immunity from civil liability”. The aim is not to clarify but to *change* the scope. This wording is misleading and risks human harms.
  4. “the deployment of a safe and effective vaccine or therapeutic product, will of course have a beneficial impact”. It would but for the reasons given here this is, clearly, not what is being promoted. This wording is misleading and risks human harms.
  5. “having to move quickly means having less time than we would like to consult on these proposals – indeed, we are asking for comments by the end of Friday 18 September 2020.” This is an unprecedented rush, clearly designed to truncate the consultation period so that responses from primed stakeholders will outweigh those of the general public. This is undemocratic.
  6. “Even though we are happy to receive comments from anyone, the purpose of this consultation exercise is to engage directly with specific stakeholders that we have identified.” How patronising!!!!! So this is set up as a sham PR event, when the UK people appear to be consulted (in a rush, with misleading wording) but actually it is only primed responses that the UK Government is interested in.
  7. All in all this survey is unethical and lacks academic integrity. The wording is leading and misleading and there is not distance from the data. For all of these reasons, it should never have made it through whichever Ethics Committee approved its use.

Thanks to George Hodan for releasing his image Plastic Syringe into the Public Domain.


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