CCHF to FDA: Seven Reasons NOT to Give Full Approval to COVID-19 Vaccines

June 7, 2021


CCHF letter opposes approval requests from Moderna and Pfizer


ST. PAUL, Minn. — In the past few weeks, Moderna and Pfizer have asked the Food and Drug Administration to give full approval to their investigational mRNA vaccines for COVID-19.

A rush to approval would be dangerous to Americans, wrote the Citizens’ Council for Health Freedom (CCHF) in a letter to Janet Woodcock, Acting Commissioner of the FDA, dated June 2, 2021.

“Our organization is writing to express our deep concern regarding the recent approval requests from Moderna and Pfizer. Both have asked the FDA to give full approval to their Covid-19 vaccines, which to date only have Emergency Use Authority (EUA),” wrote Twila Brase, RN, PHN, president and co-founder of CCHF. She shared seven reasons the requests should be “promptly and fully denied”:

  1. This is the first-ever mRNA vaccine. It’s never been used before and should not be rushed into approval. Long term effects are not known.
  2. These vaccines are still in clinical trials and will be until late 2022 and 2023. The current vaccination program is a global experiment on the human population, including on those who were not part of the phases of the pre-distribution clinical trials.
  3. The mRNA vaccines do not fit the CDC’s definition of “vaccine” (provide immunity) or give CDC-defined “immunity” (prevent the disease).
  4. By being called a “vaccine,” the manufacturers are exempt from liability for the already more than 200,000 injuries and at least 4,863 deaths reported from the injection.
  5. Employers, corporations, schools, and colleges are looking for such approval to mandate that their employees, students, and others be injected with this investigational drug despite the dangers.
  6. A mandate will lead to compulsion, coercion, and additional fear, forcing Americans to make an untenable decision. Those facing a mandate would be required to choose between the risks and dangers of the injection and the loss of education and income.
  7. Already, OSHA reversed their decision to protect employees, removing the requirement that employers that require employees to take the coronavirus injection must report vaccine injuries as work injuries available for worker compensation. That requirement was removed on May 21.

“The FDA should recognize publicly the right of Americans to make a real choice, not a coercive choice,” said Brase. “The FDA must recognize the dangers such an approval would cause many Americans to face in a nation where employers, colleges, schools, and businesses just want to “get back to normal.” Vaccine choice is an important American right. The FDA should not act in a way that directly or indirectly eliminates that right.


CCHF maintains a patient-centered, privacy-focused, free-market perspective. CCHF has worked in its home state of Minnesota and at the national level for more than 20 years to protect health care choices, individualized patient care, and medical and genetic privacy rights. In 2016, CCHF launched The Wedge of Health Freedom, an online directory of direct-pay practices (

Twila Brase, RN, PHN has been named by Modern Healthcare as one of the “100 Most Powerful People in Health Care.” She is the host of the daily Health Freedom Minute radio program heard by over 5 million weekly listeners on more than 850 radio stations nationwide, and the author of the eight-time award-winning book, Big Brother in the Exam Room: The Dangerous Truth About Electronic Health Records.

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