Institutional Confirmation Bias and the United Kingdom Department of Health: Letter to Dame Sally Davies
Below is the text of my recent letter to Dame Sally Davies (pictured), Chief Medical Officer since 2010 to the British government. Davies has now replied twice to my original challenge to substantiate her comment on the BBC regarding the MMR: ""It's a safe vaccination - we know that". My original reply was published last November. It is evident that if she had a strong reply to make she ought to have made it the first time around, and the second reply was only an amplification of the first, to which I have in turn responded in more comprehensive detail. I believe it demonstrates how a government department had come to justify its choices made originally on weak evidence, and how as the decades went by the resulting decisions got worse and more desperate: and as the problems got more drastic the denial - even if believed - got more implausible.
It is interesting and likely significant that when I asked about MMR safety it was Davies who brought up the issue of autism (which I had not mentioned). This mirrors the situation two decades ago when I tried to raise the subject with the department of the rising autism numbers and they brought up Andrew Wakefield (though I had mentioned neither Wakefield or vaccines). The message is that they make the connection as a reflex, the safety of MMR and the claimed stability of the autism figures are inextricably entwined and in both instances the department are making a “leap of faith”.
My title refers to “the Department of Health", but to clarify at the beginning of this period when the original decisions were being made it was part of the Department of Health and Social Security (DHSS), and since January last year it has been called the Department of Health and Social Care (DHSC), but for the three decades during which most of this happened it was the DoH or DH.
Dear Dame Sally,
Re: MMR Safety and Autism Numbers
Thank you for your further courteous reply (20 December), however I must point to a host of anomalies (apologies for the length and detail of my reply). The MMR programme was introduced to the UK in 1988 but the earliest of the autism safety studies included in the Cochrane review 2005  was published only 11 years after this (and apparently based on illegally obtained children’s records, which cannot be cross checked ), while the first listed in the review by Luke Taylor (2014), which you cited, comes from 14 years after the introduction of the products . Indeed, in 1988 the DH recklessly favoured SKB’s Pluserix MMR vaccine although it was already withdrawn in Canada  and contrary to your first letter it never made an attempt to withdraw the product until the decision was made to do so unilaterally by the manufacturers in 1992 .
The safety of the products had not been established at the time of introduction (quite the reverse as the main one in use was known to be hazardous), and the featured studies only began when, following the intervention of Andrew Wakefield, health officials came under pressure to justify the policy. The picture became further complicated in 1999 when the problem of mercury in other vaccine products, previously unacknowledged, came to light in the US. The problem of the Cochrane paper of 2005 is that the bland reassurance it gave regarding MMR and autism is in stark contrast to the cool to scathing comments about the six autism related studies it reviewed (three of which overlap with the Luke Taylor review of 2014 which you previously gave as your evidence for MMR safety and MMR not causing autism) . The manifest contradiction in the review should in itself raise red flags.
You make the point that all studies have limitations, but you have not argued more directly with my assessment of the 1+6 studies on which you based your claim in your original letter that MMR is safe and does not cause autism, while 6 or 9 inadequate studies do not make a single good one. There is obviously a huge conflict in those who have administered policies over decades ever admitting they have made gung-ho decisions, but the public would be astounded and outraged if they understood how slender the safety evidence base was for a policy which has now reached hundreds of millions of children globally over several decades. In fact, both your predecessor as Chief Medical Officer, Sir Liam Donaldson, and Prof David Salisbury (who headed the vaccine programme 1986-2013) were capable of suggesting that an infant would be able to receive safely thousands of vaccine products in one go without harm , which should not perhaps have reflected well on their judgment.
The opposite of side the coin is insouciant denial of any harm at all: it may be that the Department of Works and Pensions has recently been forced by the Court of Appeal to make payments in some Pandemrix/narcolepsy cases having adopted a Catch 22 approach claiming that long term damage could not be assessed , but until that point payments had dried up altogether for several years, despite the endless expansion of the programme . In the case of Pandemrix and narcolepsy the MHRA and the EMA failed to pick up signals despite there being a great many . In the general case of vaccines and autism, even if the MHRA paid attention to initial adverse events they would have no machinery to follow up on long term developmental problems: the enduring system is in fact designed not to pick them up. In view of the failure to actively monitor vaccine adverse events and their sequelae the DHSC is not even in a position to say that they are rare. Given, for instance, the current debate over HPV vaccines [11,12,13] what are the ethical grounds for not warning the public of failures, or even continuing to license the products?
By a coincidence the 2017 Mental Health Survey for Children and Young People in England  was published the day after I wrote to you. I raise an eyebrow at your suggestion that a 30% rise represents stability, but the survey also deserves to be taken much less seriously than the recent Northern Ireland census [15,16] where there was a proper attempt to count all the cases rather than project numbers from a tiny sample. It is possible that there may have been a few more fringe diagnoses in the 2.9 rate recorded compared with 1.2% 9 years before, but nevertheless Stage 5 diagnoses had all but doubled between 2008-9 and 2017-8, from 0.89 to 1.74%, which makes 1 in 57 children today with a complex ASD impairment. Given innumerable media reports of the system breaking down, and many new facilities having to be provided across the entire United Kingdom this seems to be much more likely to be representative than the results of the new survey [17,18, 19,20].
According to a recent report the number of young people with learning disabilities held in unsuitable conditions in short term assessment units (but not necessarily for a short stay) has doubled to 2,375 cases in the last three years . A Haringey budget consultation from January last year  states that the number of adults requiring support with learning disability is set to have risen from 556 in 2013 to 1,147 in 2022 – if the trend continues it looks like it will completely have overtaken the elderly by the later 2020s, but these are cases which unlike the elderly will have a lifetime of dependency ahead of them. Bearing in mind the huge and increasing budgetary constraints on local authorities, it seems improbable that their criteria for recognising new cases has become more lenient. Nor are the figures across the country likely to be much different from those in Haringey I have cited. Since each case is set to cost the state and more importantly the public millions of pounds, they really ought to be properly counted.
I fear we also need to return to the old data. In the 1999 schools’ mental health survey the PDD rate among secondary school children born between 1984 and 1988 was 1 in 500 compared with 1 in 250 in primary school , but by the 2004 survey when virtually all children in school were of the MMR generation the figure had risen to virtually 1 in 100 across the board . Already in that period some of us were exercised over claims that any of this was at all normal but now if we look at what was written at the time we are still looking at relatively modest figures. For instance, Gillberg and Wing wrote in relation to the rising trend in 1999 :
“The early studies yielded prevalence rates of under 0.5 in 1000 children, whereas the later ones showed a mean rate of about 1 in 1000. There was a marked difference in prevalence rates between those studies that included some children born before 1970 (low rates) and those that included only children born in 1970 and after (high rates). This is probably due to the lower rates obtained by use of criteria strictly based on Kanner's description of his syndrome.”
Even Eric Fombonne in the same year was talking comparatively small numbers :
“Over 4 million subjects were surveyed; 1533 subjects with autism were identified. The methodological characteristics of each study are summarized, including case definition, case-finding procedures, participation rates and precision achieved. Across surveys, the median prevalence estimate was 5.2/10000. Half the surveys had 95% confidence intervals consistent with population estimates of 5.4-5.5/10000…Based on recent surveys, a minimum estimate of 18.7/10000 for all forms of pervasive developmental disorders was derived, which outlines the needs in special services for a large group of children.”
This was one of the papers that the DHSC sent to reassure me when I first expressed concern about the situation in Haringey in 2000. But this is a whole order of magnitude different from the current situation, while attempts to locate the missing numbers (as opposed to the occasional case) in a population now over the age of 30 have signally failed. In 2013, in contrast to National Autistic Society projections, of 700,000 cases across the entire population the DWP knew of only 129,000 who were likely preponderantly minors . Brugha’s figure for adults in 2009 was extravagantly extrapolated, based on flawed diagnostic methodology and the hypothesis that they had somehow missed nearly 3/4s of the cases before weighting, and was downgraded by National Statistics to the status of “experimental statistics” in 2016 , while his 2014 data was published in 2016 as only “experimental statistics” . The “they must be there somewhere” line has been playing for two decades without the cases ever being found. But if they were there, they would be a massively dependent and expensive population and they would not have to be looked for.
The only conclusion to be drawn is that while the DHSC has for two decades been trying dispel the notion that autism is rising (and perhaps believing it themselves), a steady trickle of cases has turned into a stream, has turned into a flood. Twenty years ago, the rate was 5 in 10,000, 10 in 10,000, just possibly 20 in 10,000 but now it is 290 in 10,000 and going up. The rhetoric of “more recognition” continues (has been very effective as a public relations strategy), but we are no longer looking at the same thing. These costs will inevitably eclipse that of the care of the elderly, if they have not already. And the question is very much why as this population catastrophe has unfolded - at immeasurable financial cost to the nation, immeasurable personal cost to huge numbers of citizens - has the DHSC just stood by year after year telling everyone that nothing is happening? If the rise is real – and the hard data tells us it is all too real – it is something the DHSC are doing or not doing which is responsible. The “echo chambers” of social media are as nothing compared with the echo chambers of public health.
In 2013 you wrote in your Annual Report on another matter :
“In pointing out the lack of evidence for well-being, I have been asked to ‘take a leap of faith’ about well-being in mental health. As Chief Medical Officer I will not take a leap of faith with people’s health. The truth is that well-being in mental health is one poorly evidenced strand of a much bigger picture, and I recommend that bigger picture to policy makers”.
Yet you continue, as far as I can see, to take the leap of faith on MMR safety and “must be there” adult autism cases.
Thank you very much for letting me know of the “comprehensive Think Autism review” to begin early this year - I have not so far seen any public announcement so that ordinary citizens can give their views. May I also suggest that this correspondence be entered in evidence.
 The paper by Brent Taylor and colleagues, Demicheli et al, ‘Vaccines for measles, mumps and rubella in children’, Cochrane Database Syst Rev. 2005 Oct 19;(4):CD004407
 Lorraine Fraser, ‘Parents' fury over 'betrayal' of autistic boy’, Daily Telegraph, 4 February 2001, https://www.telegraph.co.uk/news/uknews/1321029/Parents-fury-over-betrayal-of-autistic-boy.html Brent Taylor who was at the time a member of the JCVI is reported as abusively describing “the idea that the vaccine may cause severe bowel problems and autism as "crackpot"”.
 The paper by Madsen. Luke E Taylor et al, ‘Vaccines are not associated with autism: An evidence-based meta-analysis of case-control and cohort studies’, Vaccine 2014, https://autismoevaccini.files.wordpress.com/2014/05/vaccines-are-not-associated-with-autism.pdf
 Canada Diseases Weekly Report, 15 December 1990, https://gsg.uottawa.ca/gov/Docs/CDWR%20RHMC%20Vol.16-50.pdf
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 John Stone, ‘Re: Evidence is not bullying’ 18 September 2009, https://www.bmj.com/rapid-response/2011/11/02/re-evidence-not-bullying
 Iam Sample, ‘Ministers lose fight to stop payouts over swine flu jab narcolepsy cases’ Guardian 9 February 2017, www.theguardian.com/science/2017/feb/09/ministers-lose-fight-to-stop-payouts-in-swine-flu-jab-narcolepsy-cases
 Annex A - Vaccine Damage Payments claims received and award statistics, https://www.whatdotheyknow.com/request/242813/response/599844/attach/3/Annex%20A.pdf?cookie_passthrough=1
Letters of Wendy E Stephen and Clifford G Miller, ‘Responses to Godlee, ‘A tale of two vaccines’, https://www.bmj.com/content/363/bmj.k4152/rapid-responses
 Jørgensen L, Gøtzsche PC, Jefferson T.'The Cochrane HPV vaccine review was incomplete and ignored important evidence of bias', BMJ Evid Based Med. 2018 Oct;23(5):165-168. doi: 10.1136/bmjebm-2018-111012. Epub 2018 Jul 27
 Nigel Hawkes, 'Cochrane director’s expulsion results in four board members resigning', BMJ 2018; 362 doi: https://doi.org/10.1136/bmj.k3945 (Published 17 September 2018)
 Lars Jørgensen, Peter Doshi, Peter Gøtzsche, Tom Jefferson, 'Challenges of independent assessment of potential harms of HPV vaccines', BMJ 2018; 362 doi: https://doi.org/10.1136/bmj.k3694 (Published 24 September 2018)
 Mental Health of Children and Young People in England, 2017 https://digital.nhs.uk/data-and-information/publications/statistical/mental-health-of-children-and-young-people-in-england/2017/2017
 Information Analysis Directorate 'The Prevalence of Autism (including Asperger Syndrome) in School Age Children in Northern Ireland 2018', published 10 May 2018, https://www.health-ni.gov.uk/sites/default/files/publications/health/asd-children-ni-2018.pdf
 John Stone, ‘Scepticism regarding the NHS survey 'Mental Health of Children and Young People, 2017' and ASD/PDD’, BMJ Rapid Responses 28 November 2018, https://www.bmj.com/content/363/bmj.k4953/rr-0
 Responses to Viner RM, 'NHS must prioritise health of children and young people', https://www.bmj.com/content/360/bmj.k1116/rapid-responses
 Carl Gavaghan, 'Number of North Yorkshire children being homeschooled has increased by over 800%' , Scarborough News, 3 December 2018, https://www.thescarboroughnews.co.uk/news/number-of-north-yorkshire-children-being-homeschooled-has-increased-by-over-800-1-9474423
 Josh Thomas, ‘County council “can’t carry on like this” amid concern over funding for special needs education’, 21 December 2018, https://www.huntspost.co.uk/news/county-council-can-t-carry-on-like-this-amid-concern-over-funding-for-special-needs-education-1-5827930
 Sophie Grubb, ‘Hundreds of special school places needed in Oxfordshire’, 3 January 2018, https://www.oxfordmail.co.uk/news/17332636.hundreds-of-special-school-places-needed-in-oxfordshire/
 Ian Birrell, 'Scandal of the autistic youngsters locked in solitary confinement: Hundreds of children are being held in appalling conditions and routinely abused in secluded padded cells', Mail on Sunday, 27 Ocober 2018, https://www.dailymail.co.uk/news/article-6324515/Hundreds-children-held-appalling-conditions-routinely-abused-secluded-cells.html
 Haringey, London 2018-19 Budget, Budget proposals consultation January 2018 [Slide 9].
 Metzler et al, 'The mental health of children and adolescents in Great Britain' National Statistics 1999, p.33 Table 4.1 'Prevalence of Mental Disorders', Pervasive development disorder is listed under 'less common disorders', http://www.dawba.com/abstracts/B-CAMHS99_original_survey_report.pdf
 Green et al, ‘Mental health of children and young people in Great Britain, 2004’, National Statistics 2005, p.35 Table 4.1, https://sp.ukdataservice.ac.uk/doc/5269/mrdoc/pdf/5269technicalreport.pdf
 Gillberg & Wing, ‘Autism: not an extremely rare disorder’, Acta Psychiatr Scand. 1999 Jun;99(6):399-406., https://www.ncbi.nlm.nih.gov/pubmed/10408260
 Eric Fombonne, 'The epidemiology of autism: a review', Psychol Med. 1999 Jul;29(4):769-86, https://www.ncbi.nlm.nih.gov/pubmed/10473304
 Freedom of Information request 2014-722, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/661155/foi-722-2014.pdf
 Brugha et al, 'Adult psychiatric morbidity survey 2014: Chapter 6 Autistic Spectrum Disorders' https://files.digital.nhs.uk/pdf/1/o/adult_psychiatric_study_ch6_web.pdf
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