The Studies Not Run
Abstract
Licensure trials of schedule vaccines compared each product against another vaccine or an adjuvant control, followed children for days or weeks, and never compared the schedule as a whole against no vaccination. The Institute of Medicine identified that gap in 2013. In the years since, the one institutional study to make the comparison went unpublished, two harm signals were left unresolved, HHS had no record in 2018 of any of the periodic safety reports Congress required, and in 2026 FDA replaced a placebo-controlled postmarketing commitment on Pfizer's COVID-19 vaccine with a biodistribution study and a retrospective analysis. No study has yet compared the full schedule with no vaccination.
3.1 What counts as a control
A vaccine trial measures harm by comparing the people who received the product with people who did not. What the comparison group receives determines what the trial can detect. Three kinds of control appear in the vaccine record, and public statements routinely treat them as one.
| Control | What the comparison group receives | What it can detect |
|---|---|---|
| Inert placebo | Saline, with no active ingredient | Any harm caused by the product as a whole |
| Adjuvant or excipient "placebo" | Everything in the vaccine except the antigen, often including aluminum | Only harms caused by the antigen; harms from shared ingredients cancel out |
| Active comparator | Another licensed vaccine | Only harms greater than those of the comparator |
In the second and third designs, any harm common to both arms cancels out of the comparison. A trial that gives both groups aluminum cannot find a harm caused by aluminum.
3.2 The schedule has never been studied as a whole
No study has compared children who received the full childhood schedule with children who received none.
In 2013 the Institute of Medicine reviewed the safety of the schedule at the request of HHS. It found no study of the schedule's cumulative effect and no comparison with fully unvaccinated children. Children receive the vaccines together from the day of birth, and the vaccines were studied one product at a time.
Evidence: Exhibit 001
Mechanism: The study not run
The Institute recommended that the comparison be made using records the government already held, through the Vaccine Safety Datalink. It ruled out a randomized trial as unethical. The Datalink studies that followed examined single vaccines, single outcomes, or partly vaccinated children. None compared the full schedule with no vaccination across chronic disease.
In a letter of 29 July 2020 answering a request for all CDC documents comparing the health outcomes of children who received vaccines with children who never received any, CDC stated that it "has not conducted a study of health outcomes in vaccinated vs unvaccinated populations."
The request came from counsel for the Informed Consent Action Network and asked for all CDC documents comparing the health outcomes of children who received vaccines with children who never received any. A CDC FOIA officer replied that the search found no responsive documents. The sentence quoted above is from the letter's second paragraph.
Evidence: Exhibit 938
Mechanism: The study not run
The letter is the agency's own statement of what it has done. The Institute of Medicine had named the comparison in 2013 and pointed to the data CDC already held. The letter is about studies CDC itself conducted and does not address studies by others, such as the Henry Ford manuscript in section 3.5.
Exhibit 938 · Correspondence
CDC/ATSDR final response to FOIA request #20-02002-FOIA for documents comparing health outcomes of vaccinated and unvaccinated children
The CDC has not conducted a study of health outcomes in vaccinated vs unvaccinated populations.
The CDC FOIA officer answers a request from counsel for the Informed Consent Action Network, dated 13 July 2020, for all CDC documents comparing health outcomes of children who received vaccines with children who never received any. The search found no responsive documents. The letter states that the CDC has not conducted a study of health outcomes in vaccinated versus unvaccinated populations.
- Source
- Centers for Disease Control and Prevention (CDC/ATSDR FOIA Office)
- Date
- 29 July 2020
- Quoted from
- Letter of 29 July 2020, p. 1, second paragraph
- Grade
- Primary record
- Document
- https://icandecide.org/wp-content/uploads/2020/08/2020_08_03-20-02002-Final-Response-No-Records1.pdf
- Accessed
- 2026-11-10
- Cited by
- Findings citing this exhibit
- Note
- The letter is dated 29 July 2020 on its face and carries file number 20-02002-FOIA; the ICAN-hosted PDF is named 2020_08_03 and ICAN's article gives 3 August 2020 for the response. ICAN's article places the original submission on 26 June 2020 and the narrowed wording on 13 July 2020. No copy on a CDC or court site was found; the copy is the one ICAN published.
3.3 Licensed against other products
The pivotal trials of the Gardasil vaccines were not compared with an inert placebo. According to ICAN's 2018 reply to HHS, most other vaccines on the current childhood schedule were also licensed against other vaccines or adjuvant-containing controls.
The Gardasil labels record their controls. Gardasil's controls mostly received its aluminum adjuvant. The pivotal efficacy trial of Gardasil 9 compared it with Gardasil and had no placebo arm. The label reports one saline-placebo safety study, in girls and women previously given Gardasil. According to ICAN's 2018 reply to HHS, pneumococcal, combination and other schedule vaccines were licensed against earlier vaccines or adjuvant-containing controls, with safety monitored for days or weeks. Chronic conditions such as asthma, autoimmune disease and developmental disorders appear over years.
Evidence: Exhibit 006, Exhibit 005, Exhibit 007
Mechanism: The study not run
| Product | Control in licensure trials |
|---|---|
| Gardasil (HPV) | Aluminum adjuvant (AAHS) for most controls |
| Gardasil 9 (HPV) | Gardasil in the pivotal efficacy trial; saline placebo in one safety study of previously vaccinated participants |
| Cervarix (HPV) | Aluminum-adjuvanted hepatitis A vaccine |
| Prevnar 13 (pneumococcal) | Prevnar 7 |
| Hepatitis B (infant) | No placebo arm in pivotal pediatric safety trials |
| Combination vaccines | Component vaccines given separately |
| Rotavirus (RotaTeq, Rotarix) | Formulation without antigen; all infants also received routine vaccines |
Inert-placebo trials do exist in the record. The 1954 Salk polio trial randomized more than 600,000 children to vaccine or saline, and later placebo-controlled trials exist for some newer products. According to ICAN's 2018 reply to HHS, few products on the current schedule were licensed that way.
3.4 Why the trial cannot be run
The official position
Once a vaccine is the standard of care, withholding it from a control group exposes children to preventable disease. The Declaration of Helsinki requires new products to be tested against the best proven intervention. A saline-controlled trial of the schedule is therefore unethical.
What the record shows
Under this rule, a saline-controlled trial of an established vaccine can never be run. Each new product is tested against the one before it, and that one was tested against an earlier product. No trial in the sequence includes a group that received nothing.
The Institute of Medicine resolved this by pointing to observational data the government already held. An observational study of existing records requires no child to go unvaccinated, so the ethical objection does not apply to it. No Datalink study of that kind has been published.
3.5 The comparison that was made
The one institutional study to compare vaccinated and unvaccinated children found more chronic disease in the vaccinated, and it was not published.
Researchers at Henry Ford Health studied 18,468 children born between 2000 and 2016, of whom 1,957 had received no vaccines. They cited the Institute of Medicine's 2013 report as their reason for doing so. Vaccinated children had two and a half times the rate of any chronic condition, four times the rate of asthma, and five times the rates of autoimmune and neurodevelopmental disorders.
Evidence: Exhibit 010, Exhibit 011, Exhibit 012
Mechanism: The study not run, The filtered record
| Outcome | Hazard ratio | 95% CI |
|---|---|---|
| Any chronic condition | 2.53 | 2.16–2.96 |
| Asthma | 4.25 | 3.23–5.59 |
| Atopic disease | 3.03 | 2.01–4.57 |
| Autoimmune disease | 4.79 | 1.36–16.94 |
| Neurodevelopmental disorder | 5.53 | 2.91–10.51 |
| Autism | not significant | — |
| Cancer | not significant | — |
The study was completed around 2020. It entered the public record only on 9 September 2025, when it was submitted to a Senate subcommittee. Siri testified that the authors regarded the study as well done and declined to submit it for publication for stated personal reasons. Henry Ford Health said its senior scientists had found fatal flaws, and that the vaccinated and unvaccinated groups differed. The study was not submitted for peer review, where those objections could have been tested, and the institution sent a cease-and-desist letter to filmmakers who covered it.
The principal objection is that unvaccinated children visit doctors less often and so receive fewer diagnoses. The authors tested this. Restricting the analysis to children who had at least one clinical visit reduced the hazard ratio for any chronic condition from 2.53 to 1.87, which remained elevated. The authors wrote that their findings could not prove causation and warranted further investigation. No follow-up study has been published.
3.6 The asthma signal
A CDC-funded study found an association between vaccine aluminum and childhood asthma. It remains unresolved.
In 2023, researchers using the government's own Vaccine Safety Datalink reported that children with higher cumulative aluminum exposure from vaccines before age two had more persistent asthma between ages two and five. They called it a signal requiring further study. The Henry Ford cohort found asthma four times as common in vaccinated children.
Evidence: Exhibit 013, Exhibit 014, Exhibit 010
Mechanism: The study not run
The largest study cited against the signal, a 2025 Danish registry of 1.2 million children, compared children who received more aluminum with children who received less. It contained no group that received none. It could not detect a harm present at every level of exposure, which is the question the asthma signal raises.
3.7 Forty years of an open mortality question
Studies of 1980s data from Guinea-Bissau found higher infant mortality after DTP vaccination, and no randomized trial has tested the finding.
Researchers studying 1980s data found that DTP-vaccinated infants died at about twice, and in one natural experiment five times, the rate of infants not yet vaccinated. A 2014 review commissioned by the WHO found a pooled 38 percent higher mortality associated with DTP (95% CI 0.92–2.08), judged every study at high risk of bias, and recommended trials. It recommended no change to the schedule.
Evidence: Exhibit 015, Exhibit 016, Exhibit 017
Mechanism: The study not run
The evidence on both sides is thin. The five-fold estimate rests on sixteen deaths. A 2025 reanalysis found that the same research group's own randomized trials mostly failed to show the effects they were designed to detect, and a 2026 audit listed ten of the group's registered trials with primary outcomes partly or wholly unpublished, one of them a DTP-related trial reported to have enrolled 6,534 children. No one has run the randomized trial the WHO review called for, so the question remains open.
Exhibit 018 · Reanalysis
Independent reanalysis of Bandim randomized trials of non-specific vaccine effects
only one of the 13 randomized trials demonstrated the effect it was designed to detect
Re-examined 13 Bandim randomized trials reported across 26 articles.
- Source
- Støvring et al., Vaccine; Aarhus University
- Date
- 2025
- Quoted from
- Aarhus University press release
- Grade
- Peer-reviewed
- Document
- https://clin.au.dk/display/artikel/randomized-trials-show-no-evidence-of-non-specific-vaccine-effects
- Accessed
- 2026-11-09
- Cited by
- Findings citing this exhibit
3.8 The reports Congress required
The 1986 Act required HHS to report to Congress periodically, each report covering the preceding two years, on its work toward safer childhood vaccines. In 2018 HHS had no record of any such report.
The 1986 National Childhood Vaccine Injury Act gave manufacturers protection from most injury lawsuits. In the same Act, Congress directed the Secretary of Health and Human Services to work toward safer vaccines and to report to Congress periodically, each report covering the preceding two years. The first was due within two years after 22 December 1987. In 2018, after a Freedom of Information request and a federal lawsuit, a court order recorded that the department had no such reports. According to the plaintiffs' 2021 complaint in a later suit, the statutory task force on safer vaccines was disbanded in 1998.
Evidence: Exhibit 002, Exhibit 003, Exhibit 004
Mechanism: The study not run
The Act's liability protection has applied since 1988. In 2018 HHS had no record of any report under the same Act's reporting requirement, and the public learned of the gap through a private group's lawsuit.
3.9 Two placebo-controlled commitments
In 2025 Pfizer committed to FDA to run a randomized, double-blind, placebo-controlled study of its COVID-19 vaccine in healthy adults aged 50 to 64. In 2026 FDA released Pfizer from a different placebo-controlled commitment from the same approval, a study of post-vaccination syndrome and Long COVID symptoms, and replaced it with a biodistribution study and a retrospective analysis.
The 2025 approval letter for Pfizer's COVID-19 vaccine records Pfizer's written commitment to run a randomized, double-blind, placebo-controlled study in healthy adults aged 50 to 64. In 2026 an FDA letter released Pfizer from a different commitment from the same approval, an exploratory randomized placebo-controlled study of circulating spike antigen and self-reported symptoms of post-COVID-19 vaccination syndrome or Long COVID. The letter replaced it with a nonclinical biodistribution study and a retrospective integrated analysis. It does not mention the study in adults 50 to 64.
Evidence: Exhibit 020, Exhibit 021
Mechanism: The study not run
The same year, the FDA approved Moderna's mRNA influenza vaccine on the strength of a 26.6 percent efficacy advantage over an existing flu vaccine. The trial had no unvaccinated arm, so its efficacy figure is relative to the licensed comparator.
Exhibit 022 · Regulatory action
Moderna mRNA influenza vaccine: advisory committee review and relative efficacy
A prospective influenza vaccine passed an FDA advisory committee meeting last month with a Prescription Drug User Fee Act goal date of August 5, 2026, after the committee initially refused to review the vaccine application in early February.
AJMC reported that a prospective influenza vaccine passed an FDA advisory committee meeting with a Prescription Drug User Fee Act goal date of 5 August 2026, after the committee initially refused to review the application in early February. In a randomized trial of 40,703 participants, Moderna's mRNA influenza vaccine had 26.6 percent relative efficacy (95% CI 16.7–35.4) against a licensed standard-dose influenza vaccine. The comparator was a licensed vaccine.
- Source
- U.S. Food and Drug Administration; VRBPAC; reported by AJMC and CIDRAP
- Date
- February 2026
- Quoted from
- AJMC article, first paragraph
- Grade
- Reported
- Document
- https://www.ajmc.com/view/fda-advisory-committee-supports-moderna-mrna-flu-vaccine-review
- Accessed
- 2026-11-09
- Cited by
- Findings citing this exhibit
3.10 Gaps named and left open
Each gap described above was identified by a responsible body or by the researchers themselves. In 2013 the Institute of Medicine named the missing schedule comparison and the data system that could make it. The Henry Ford authors and the CDC-funded asthma authors called for further study, the WHO review called for trials, and Congress required periodic reports.
The bodies that hold the authority and the data have not produced these studies or reports. The schedule's safety record therefore contains no comparison capable of detecting a harm shared across vaccines or one that appears years after vaccination.
Key findings
- No study has compared the full childhood schedule with no vaccination (3.2). In 2020 CDC wrote that it has not conducted such a study (3.10).
- The Gardasil vaccines were licensed against adjuvant or active controls, and ICAN's 2018 reply to HHS describes most other schedule vaccines the same way; such controls cannot detect shared harms (3.3).
- The one institutional vaccinated-versus-unvaccinated comparison found more chronic disease in vaccinated children and was not published (3.5).
- A CDC-funded aluminum–asthma signal and a forty-year-old DTP mortality signal remain unresolved (3.6, 3.7).
- In 2018 HHS had no record of any of the periodic safety reports Congress required in 1986 (3.8).
- In 2026 FDA released Pfizer from a placebo-controlled commitment on its COVID-19 vaccine and replaced it with a biodistribution study and a retrospective analysis (3.9).