The qualification follows: “Risk that this will happen is low due to low level of DNA. Risk if does happen, low as integration events have low probability.” Note that “low probability” is a different thing to “not possible”.
There is no further discussion among TGA personnel about the implications of the SV40 enhancer/promoter dragging vaccine elements into the cell nucleus of vaccine recipients, which, as shown above, officials publicly insist cannot happen.
SV40 enhancer/promoter not disclosed to TGA by Pfizer
We already know that Pfizer did not annotate the SV40 enhancer/promoter on its DNA plasmid map submitted to regulators. In Health Canada emails (ER: please find the LINK to this article in the original posting by Rebekah Barnett) released under an Access to Information and Privacy (ATIP) request, an official admitted:
Pfizer has communicated to us recently, that they apparently chose not to mention this information to EMA, FDA or HC at the time of their initial or subsequent submissions.
Now we have confirmation that Pfizer didn’t mention this gene therapy sequence to the TGA either.
From the emails:
The plasmid for expression of the Pfizer mRNA was based on a pCMV-TAG vector (I used BLAST analysis of sequence from Mod3 as not all info was placed in the plasmid map provided by the Sponsor).
and,
The plasmid also contains a SV40 promoter and f1 ori region (not shown in plasmid map presented by Sponsor but found in BLAST and reported in Speicher & McKernan papers).
Discussion of risks
Conspicuously absent from the internal TGA discussion of plasmid DNA risks is the difference between naked DNA and DNA encased in lipid nanoparticles (LNPs).
As detailed in my recent Substack article, ‘No evidence for TGA’s mRNA safety claim,’ in traditional vaccines, residual DNA is ‘naked’ and can be expected to be mostly eliminated fairly quickly.
But in modified mRNA vaccines, LNPs travel to every major organ system in the body where they dump their contents into cells. Therefore, the DNA is not being destroyed before it makes it into cells.
In the case of the Pfizer vaccine, the presence of the SV40 enhancer/promoter increases the risk that this DNA, once in the cell, will be dragged into the nucleus.
The LNPs and the SV40 enhancer/promoter obviously change the risk calculation for residual DNA in mRNA vaccines.
However, while TGA staff indicate the need to address “misinformation” including the claim that, “The mRNA is different from recombinant proteins because the DNA is encapsulated in the LNPs”, at no point does anyone in the communication chain actually offer a scientific argument to refute this supposed misinformation.
Indeed, the only time the matter is directly addressed in over 200 pages of documentation is in a single paragraph:
The TGA does not hold any evidence that the residual DNA is encapsulated in lipid nanoparticles. However, if it were, there is a low safety concern with the levels present as there is a sufficient safety margin.
Previously, the TGA advised in email communications with me that, “There is no significance to minute amounts of residual DNA being encapsulated in the LNPs.”
It appears that the TGA is assuming that residual DNA, which was not successfully filtered out of the mRNA component before its packaging in LNPs, was somehow completely separated from the mRNA during the packaging process, with only mRNA being encased in the LNPs while the residual DNA just floats around naked in the rest of the vaccine mixture.
How the TGA could have arrived at such a fantastical conclusion is anyone’s guess, seeing as it was unable to provide any evidence for its stance on the insignificance of the LNPs when requested under FOI.
However, elsewhere, a TGA staffer does hint at the possibility that LNPs will contain residual DNA.
Likening the mRNA vaccines to “viral gene therapies” due to their use of high levels of DNA starting material, this person notes that, “They also have the potential to package non-target sequences and be administered to patients.”
In the risk assessment of the residual plasmid DNA provided by TGA personnel, cancer and genomic risks are acknowledged but determined to be highly unlikely. This breaks with official messaging which presents the picture of ‘no risk at all, ever’.
From the Senior Toxicologist:
There are several published papers that describe an improbable risk of oncogenicity from integration of host cell DNA from biological products, but they are considerably old (e.g. Krause & Lewis, 1998; Yang et al., 2010).
Indeed, both references are too old to have assessed the risks of modified mRNA vaccine plasmid DNA, including a nuclear-targeting SV40 enhancer/promoter, being deposited directly into cells in their LNP packaging.
Another TGA staff person, in the most comprehensive email on plasmid DNA risks, acknowledged that residual DNA can result in the inactivation of tumour-suppressor genes (leading to cancer formation), but only in high amounts.
Additionally, this staffer asserts that the smaller the DNA fragments, the lower the risk.
Once again, TGA staff seem to have forgotten that the scientific references they are referring to relate to naked DNA, not DNA packaged in LNPs and delivered straight into cells all over the body.
Note also the use of the word “contaminant” above to refer to the residual DNA, per the nomenclature of the referenced WHO Technical Report. This suggests that when the TGA says the Covid mRNA vaccines are “not contaminated“, the regulator is either playing semantics or is not sufficiently familiar with the literature on the topic.
The risk assessment summary, as below:
- Risk of expression of genes from residual DNA low due to fragmented nature of DNA
- Risk of oncogene expression [cancer risk] is negligible
- Risk of replication of DNA is negligible due to fragmented DNA (no intact plasmid) and lack of recognition of ori
- Risk of insertion is extremely low based on levels and probability indicated in datapublished by WHO, Yang etc. (still to get info re. direct injection into cells)
On the issue of DNA replication, the above mentioned email states that because the plasmid is of “bacterial origin”, this “ori” would not be recognised in human cells and so does not present a problem.
However, another staffer is less certain:
Not sure if f1 ori not recognised. May be required for replication in mammalian cells (vector appears to be dual expression vector). Does it require other components? (just thoughts)
Regardless, this person says, “the DNA is fragmented and this would be inconsequential”.
Scientists respond
“This is just overt smoke screening,” says Kevin McKernan, the genomics scientist who discovered the DNA contamination in the Covid mRNA vaccines.
McKernan, who is CSO and Founder of Medicinal Genomics, and who previously managed the R&D for the Human Genome Project at Whitehead Institute/MIT, set a few things straight in short order over email.
First, the TGA is “still not understanding the risk of LNPs and how these make the 10 ng [regulatory limit] irrelevant. All their citations are in reference to naked DNA.”
Second, the TGA is not up to date on peer-reviewed science showing DNA contamination in the mRNA vaccines over the regulatory limit (König & Kirchner 2024, and Kämmerer et al. 2024).
Third, on the assertion that smaller fragments of DNA result in lower risk, McKernan again emphasised that this is assumed for naked DNA, but not DNA wrapped in LNPs.
“When it’s naked DNA the smaller material will degrade faster. It’s not naked,” he explained. In fact, the risk increases when the DNA fragments are smaller but more plentiful.
“The smaller the DNA gets, the lower the [safety] limit needs to be as the copy number goes up,” said McKernan, pointing to a peer-reviewed article by Sheng-Fowler et al. (2009) for the Food and Drug Administration (FDA) explaining exactly this.
Fourth, the chance that there is no residual DNA in the LNPs is zero. “The DNA is negatively charged and will be wrapped in LNPs for the same reason the RNA is. The cationic lipids wrap themselves around negatively charged polymers,” said McKernan.
“Kämmerer et al. demonstrate that the DNA is in the LNPs as they find it in the cells post-transfection,” McKernan added.
Persistence of the residual DNA in human cells has also been documented informally by McKernan, and by genomics scientist Dr. Phillip Buckhaults. And, most recently, plasmid DNA from the Covid vaccines was detected in blood samples from a South Australian study – this would not be possible if the residual DNA had been destroyed before making it into recipients’ cells.
Fifth, the plasmid is not just bacterial as claimed in the TGA emails, but has “mammalian origins of replication and viral elements”, McKernan clarified. This nullifies the assertion that the plasmid cannot replicate because of its apparent bacterial origin.
“The SV40 Ori is active in mammalian cells when coupled with an F1 Ori and ColE1. Both exist in the Pfizer sequence.” This is science-speak for ‘yes, this plasmid presents a replication risk in human cells’.
The regulations of 10 ng of residual DNA per vaccine dose “are now irrelevant as you can drive a truck through that regulation with LNPs containing DNA that has active mammalian origins of replication,” said McKernan in a Substack diving deeper into the ori issue.
Dr. David Speicher, the virologist who detected excessive levels of DNA contamination in both Australian and Canadian vials of the mRNA vaccines, echoes McKernan’s concerns.
“They admit that integration [of synthetic plasmid DNA] is theoretically possible,” Dr. Speicher said after reading the emails, noting the comment from one TGA staffer that the LNPs “have the potential to package non-target sequences and be administered to patients”.
Yet, “they are still applying the rules for naked DNA. While the plasmid may not have an integrase they rightly point out that ‘other mechanisms of DNA integration are possible’”.
Dr. Speicher expressed alarm that these TGA emails from as recent as October 2024 raise basic questions like whether the levels of residual DNA meet the quantity and size limits, whether there are any data on residual DNA being encapsulated in LNPs (or not), and seeking to confirm what SV40 sequences are contained in the Pfizer plasmid vector.
“They should have had those answers when Pfizer submitted for regulatory approval,” said Dr. Speicher, emphasising that the Australian data alone answered these questions, showing:
- The levels of residual DNA in the Covid mRNA vaccines are higher by both qPCR and fluorometry testing methods,
- The residual DNA is encapsulated in the LNPs, and,
- The presence of the SV40 enhancer/promoter.
“What strikes me is that their messaging is severe gaslighting and they are more concerned with maintaining the mantra of ‘safe and effective,’” said Dr. Speicher.
Indeed, Dr. Lisa Kerr, Assistant Secretary of the Laboratories Branch, who co-ordinated the internal communications to develop the TGA’s statement on DNA contamination ‘misinformation’ said as much.
“I’m primarily concerned with allaying fears in the public that this is actually something to worry about when it isn’t,” wrote Dr. Kerr (she/her) in the thread discussing theoretical risks that have not been clinically investigated.
Dr. Mel McCann, whose FOI request unearthed these emails, expressed dismay at what they reveal about the internal priorities of the TGA.
“Rather than contemplate the catastrophic consequence of DNA integration into the human genome or oncogenicity, the email trails focus on sanitising the public statement,” she said.
Dr. McCann said she was not surprised, but felt the emails showed “disgraceful disregard for the risk to public”.
Of course Dr. McCann should not be surprised, as lawyers representing the TGA recently argued for dismissal of the Covid vaccine injury class action she is leading on the basis that TGA officials (among others) did not owe a duty of care to Australian citizens who were injured by the medical products they approved and promoted.
Find out more about the Covid vaccine injury class action, representing over 2,000 injured Australians. If you have the means, you may consider making a donation.
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