These are my comments as UK and European Editor of Age of Autism on the European Commission document 'Roadmap: Strengthened cooperation against vaccine preventable diseases'. This is one of 368 comments, which are overwhelmingly negative to the project:
This project is misconceived in several dimensions. While it latches on to the issue of measles and flu mortality the number of diseases which could be defined as “vaccine preventable” is open ended, as is the number of vaccine products that the vaccine industry hopes to be licensed, and recommended for use or mandated – at the present time hundreds of different products are in development  purely on the principle that there will be a captive, or quasi-captive market available when they are ready to be marketed. The drive for more compliance and more products is not coming from citizens but from the industry and bureaucrats. At a simplistic level anyone could agree that preventing disease is a good thing (though some may have long term health benefits) but it could not be true at any cost to the population. There is no scientific or historical model for subjecting a population to an ever-expanding schedule of vaccine products. This is simply becoming the biggest human experiment in history.
As the schedule expands it would be rational to consider that perhaps some diseases are not so dangerous, or not so common, and that some of the products may not be so effective or safe – and by now there are already a great many. It may also be by now that the population is not so well from the proliferation of chronic diseases, mental ill-health and neuro developmental disorders. The possible relationship between these manifestations and the expanding schedule have been flippantly dismissed and attempts to research it have been persecuted. We do not presently have institutions which are as capable of protecting the public interest as that of the industry. But the pioneering recent paper by Mawson et al which attempted to address the problem reported :
A convenience sample of 666 children was obtained, of which 261 (39%) were unvaccinated. The vaccinated were less likely than the unvaccinated to have been diagnosed with chickenpox and pertussis, but more likely to have been diagnosed with pneumonia, otitis media, allergies and NDD. After adjustment, vaccination, male gender, and preterm birth remained significantly associated with NDD. However, in a final adjusted model with interaction, vaccination but not preterm birth remained associated with NDD, while the interaction of preterm birth and vaccination was associated with a 6.6-fold increased odds of NDD (95% CI: 2.8, 15.5). In conclusion, vaccinated homeschool children were found to have a higher rate of allergies and NDD than unvaccinated homeschool children. While vaccination remained significantly associated with NDD after controlling for other factors, preterm birth coupled with vaccination was associated with an apparent synergistic increase in the odds of NDD. Further research involving larger, independent samples and stronger research designs is needed to verify and understand these unexpected findings in order to optimize the impact of vaccines on children’s health.
Leslie et al reported :
Results...Subjects with newly diagnosed AN (anorexia nervosa) were more likely than controls to have had any vaccination in the previous 3 months [hazard ratio (HR) 1.80, 95% confidence interval 1.21–2.68]. Influenza vaccinations during the prior 3, 6, and 12 months were also associated with incident diagnoses of AN, OCD (obsessive compulsive disorder), and an anxiety disorder. Several other associations were also significant with HRs greater than 1.40 (hepatitis A with OCD and AN; hepatitis B with AN; and meningitis with AN and chronic tic disorder).
There has been much concern recently about the aluminium components of many vaccines, paediatric as well as the HPV vaccines: these issues have not been resolved [4,5,6,7], and should not be dismissed – nor should some irrevocable policy be launched without all the evidence being considered, without further research being done [8,9,10]. Only liars and profiteers say the science is in – the science is never in.
Presently, in the UK – where we have high vaccine compliance although no mandates - we are drowning cases of mental ill-health and neuro-developmental disability. Media reports, however, tend to focus on the absence of resources to deal with the problems rather than causes. Another vital and catastrophic question hovers: how could it all be economically - let alone humanly – sustainable . Driving ahead with the policy without paying attention to its serious consequences has to be considered reckless and headstrong.
Given the reality that everyone ultimately dies of something is the policy to focus on such diseases as measles and flu necessarily wise, or a distortion of policy? In the United Kingdom, the country in which Andrew Wakefield is held to have undermined the vaccine programme, only 4 people have died of measles since 1992 according to official statistics (that is out of about 13m deaths) . Flu mortality is higher but still comparatively insignificant. In 2009 when the Chief Medical Officer was challenged over the projections annual flu deaths in the tens of thousands he admitted that there had only been 132 deaths in the four preceding years – an average of 33 a year out of above 500,000 deaths (about 1 in 15,000) . Realistically, the statistical insignificance of actual flu deaths (as against projections in the thousands) needs to be weighed against such issues as the notorious inefficacy of the vaccines . We do not even know how many of the 132 were not vaccinated.
Another question which the promoters of such policies need to face and address is that not only are they placing their views above ordinary citizens and their historic rights (informed consent etc.) but the extent to which making ever more demands on the public might in itself lead to more resistance, more private reading, more scepticism about the wisdom, integrity and motives of those trying to force the matter. The introduction of mandates in Italy has led to widespread protests – has brought tens of thousands of people on to the streets weekly - when before vaccination was not even an issue. It is a troubling prospect that the people we are increasingly having to regard as our rulers only want to raise the stakes.
 PhRMA, Medicines in development: vaccines, 11 September 20-13 https://www.phrma.org/press-release/medicines-in-development-vaccines#sthash.rI4cQ6Tg.dpuf
 Anthony R Mawson, Brian D Ray, Azad R Bhuiyan, Binu Jacob 'Pilot comparative study on the health of vaccinated and unvaccinated 6- to 12- year old U.S. children', Journal of Translational Science, 24 April 2017,
 Leslie, Kobre, Richmand , Guloksuz, Leckman, 'Temporal Association of Certain Neuropsychiatric Disorders Following Vaccination of Children and Adolescents: A Pilot Case–Control Study', https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5244035/
 Goetzsche et al, Complaint to the European ombudsman over maladministration at the European Medicines Agency (EMA) in relation to the safety of the HPV vaccines, https://nordic.cochrane.org/sites/nordic.cochrane.org/files/public/uploads/ResearchHighlights/Complaint-to-ombudsman-over-EMA.pdf
 Tom Jefferson, Lars Jørgensen, Human papillomavirus vaccines, complex regional pain syndrome, postural orthostatic tachycardia syndrome, and autonomic dysfunction – a review of the regulatory evidence from the European Medicines Agency https://ijme.in/articles/human-papillomavirus-vaccines-complex-regional-pain-syndrome-postural-orthostatic-tachycardia-syndrome-and-autonomic-dysfunction-a-review-of-the-regulatory-evidence-from-the-european-medi/
 Mold et al, Aluminium in brain tissue in autism, Journal of Trace Elements in Medicine and Biology, Volume 46, March 2018, Pages 76–82 https://www.sciencedirect.com/science/article/pii/S0946672X17308763
 Rigolet et al, Clinical Features in Patients with Long-Lasting Macrophagic Myofasciitis, Front Neurol. 2014; 5: 230. Published online 2014 Nov 28, https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4246686/
 Edwards et al, Is the timing of recommended childhood vaccines evidence based? https://www.researchgate.net/publication/295840691_Is_the_timing_of_recommended_childhood_vaccines_evidence_based
 Benn et al, Re: Non-specific effects of measles, mumps, and rubella (MMR) vaccination in high income setting: population based cohort study in the Netherlands, BMJ Rapid Responses 16 November 2017, https://www.bmj.com/content/358/bmj.j3862/rr
 Puliyel & Phadke, Deaths following pentavalent vaccine and the revised AEFI classification, Indian Journal of Medical Ethics Online First Published July 4, 2017, https://ijme.in/wp-content/uploads/2017/07/20170704_deaths_following_pentavalent.pdf
 John Stone, Re: US government website for collecting adverse events after vaccination is inaccessible to most users, BMJ Rapid Responses 29 May 2017, https://www.bmj.com/content/357/bmj.j2449/rr-5 In the UK the number of children with ASD in schools has been rising year on year for more than two decades. The figure for schools are published by various government sources: National Statistics, the Department of Education, the Scottish Executive etc. The January 2017 figure for England can be calculated at 1 in 67 and the September 2016 figure for Scotland 1 in 51, however the long term position is much worse since (a) these are 15 year rolling cohorts so the rates are much higher among younger children and (b) data for younger children is still incomplete since there are many who will still not be diagnosed.The rate for English schools is derived by dividing the total number of pupils in school (8,669,085) by the number with ASD diagnosis (128,948). The first number comes from the DoE publication, Schools, pupils and their characteristics: January 2017, p. 3 and the other figure extracted from National Statistics Special educational needs in England: January 2017, https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/623124/SFR28_2017_Main_Text.pdf & National Tables SFR 37/2017 table 8, and Additional tables SFR37/2017 table G https://www.gov.uk/government/statistics/special-educational-needs-in-england-january-2017The number of pupils in Scottish was 684,415 and the number of pupils with an ASD diagnosis was 13,423: data provided by the Scottish Executive.
 John Stone, English mortality from A/H1N1. Discrepancies in published data. BMJ 2010; 340 doi: https://doi.org/10.1136/bmj.c613 (Published 02 February 2010)
 Nigel Hawkes, Over 65s flu vaccination programme was ineffective, data show, BMJ 2017; 358 doi: https://doi.org/10.1136/bmj.j4146 (Published 05 September 2017)
 Letter by Kevin Barry to UNICEF, 26 December 2017 https://www.firstfreedoms.org/