From:
Roy Hanson
Child and Family Protection Association, California
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We are very concerned about the Emergency Health Powers Act (MEHPA).

The purpose of this document is to ensure that as many people as possible have access to important background information which is vital to understanding and explaining the magnitude of the problems with not only the Model Emergency Health Powers Act, but also with state legislation.

California's Act is based on the Model State Emergency Health Powers Act, which was written by the Center for Law and the Public Health at Georgetown and Johns Hopkins Universities for the Centers for Disease Control and Prevention (CDC).

California's Emergency Health Powers Act, AB 1763, as introduced 1/8/02, follows the national model (MEHPA) fairly closely.  We have drafted extensive specific amendments to address what appear to us to be the more significant problems with AB 1763.  Our proposed amendments include input from some national health and legislative organizations who were already very familiar with this proposed legislation.  While these amendments are specific to California's bill, they should be generally useful in most states.

We have placed our amendments as a separate document on this web site for your review and use as you see fit.  That document has a link to California's bill, AB 1763 for your reference.  Our proposed amendments are still in draft form - they continue to be worked on.  However, when you receive them, you are free to use our draft amendments as you see fit.
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We would strongly prefer that this legislation (state Emergency Health Powers Acts) be defeated, especially in states like California, which already have laws, programs, and experienced agencies in place to deal with emergencies that could affect public health.

Some states, such as Texas, have prudently decided to review current law in order to identify whether anything needs to be changed.  In most cases, passage of laws based on the MEHPA will be overreaching and intrusive, as well as duplicative and contradictory of current law.  However, outright defeat could prove to be very difficult given some important factors such as:

*  the number of very powerful groups which have already endorsed the MEHPA
*  the political makeup of various legislatures
*  the complexities of the issues, which most legislators will not understand, such as interaction with current laws
*  the general popular concern about doing something regarding terrorism
*  the millions of federal dollars being made available to the states on condition of having specified programs in place at the state level
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For your information, the following documents are available as pdf files:
1. the Model State Emergency Health Powers Act - dated 10/23/01  (http://www.childandfamilyprotection.org/MEHPA/MSEHPA_102301.pdf)
2. the Model State Emergency Health Powers Act - dated 12/21/01  (http://www.childandfamilyprotection.org/MEHPA/MSEHPA_122101.pdf)
3. the American Legislative Exchange Council (ALEC) analysis of the most recent (12/21/01) version of the Model Act  (http://www.childandfamilyprotection.org/MEHPA/MEHPA_%232_ALEC_analysis.pdf)
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The articles and the documents listed below provide vital background information concerning this legislation.  We have included web links to make it easier for you to retrieve these documents.  In most cases these links should take you directly to the specific document.  We have included at least a brief excerpt (identified by italics) from each document to give you an idea what each document is about.  This is not an exhaustive listing of documents or information resources.
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AAPS (American Academy of Physicians and Surgeons) ANALYSIS
MODEL EMERGENCY HEALTH POWERS ACT (MEHPA) TURNS GOVERNORS INTO DICTATORS
12/3/2001

This Act grants unprecedented and unchecked powers to the Governors of the 50 States.

AAPS ANALYSIS
REVISED DRAFT OF MODEL STATE EMERGENCY HEALTH POWERS ACT (DEC. 21) STILL A PRESCRIPTION FOR TYRANNY

The "new" Model State Emergency Health Powers Act (December 21 version) has apparently been modified to remove those provisions that attracted the most dissension.... This appears to be a disingenuous effort to mute criticism while making little substantial change in the proposal.
URL: http://www.aapsonline.org/testimony/emerpower.htm
 See
http://www.aapsonline.org/testimony/emerpind.htm for additional information on the emergency powers legislation.
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AAPS December 2, 2001 Action Notice

To State, Local, and Specialty Medical Society Officers and Staff:

Under pressure from the U.S. Department of Health and Human Services, your state legislature will probably be considering the Model Emergency Health Powers Act (MEHPA), which would give the Governor unprecedented, dictatorial powers in the event that he decided to declare a "public health emergency."

URL: http://www.aapsonline.org/legis/medsocemer.htm
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Emergency Measures
States grapple with methods for dealing with bioterrorism

The suspension of traditional American civil liberties, no matter how necessary or temporary, is a serious issue. So is the prospect, no matter how unlikely, of thousands of Americans suffering from a deadly epidemic. The reform of state public-health laws is under way. How well those reforms balance these two issues may one day affect our lives, health and freedoms in a profound way.
URL: http://www.sfgate.com/cgi-bin/article.cgi?file=/gate/archive/2002/01/14/healthwatch.DTL
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Health bill endangers civil rights
Bush pushes plan to expand control in bioweapon attack

The administration wants all 50 states to adopt a law allowing public health authorities to take over hospitals, seize drug supplies, quarantine people exposed to infectious pathogens, draft doctors to treat them, force patients to be vaccinated, and order police to restrain residents from leaving contaminated areas.
URL: http://www.sfgate.com/cgi-bin/article.cgi?file=/chronicle/archive/2001/11/25/MN232750.DTL
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NUREMBERG CODE

The voluntary consent of the human subject is absolutely essential.  This means that the person involved should have legal capacity to give consent; should be so situated as to be able to exercise free power of choice, without the intervention of any element of force, fraud, deceit, duress, over-reaching, or other ulterior form of constraint or coercion; and should have sufficient knowledge and comprehension of the elements of the subject matter involved as to enable him to make an understanding and enlightened decision.
URL: http://ohsr.od.nih.gov/nuremberg.php3
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AAPS Resolution Concerning Mandatory Vaccinations
Association of American Physicians and Surgeons

"BE IT THEREFORE RESOLVED: That AAPS calls for a moratorium on vaccine mandates and for physicians to insist upon truly informed consent for the use of vaccines."
URL: http://www.aapsonline.org/testimony/vacresol.htm
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The Vaccine Reaction
Special report - Winter 2002

SMALLPOX AND FORCED VACCINATION:
WHAT EVERY AMERICAN NEEDS TO KNOW 
In this time of great sadness, fear and confusion, Americans have a choice to make: either we defend the individual freedoms our forefathers fought and died to give us, or we sacrifice those freedoms and let the terrorists win.  What we choose to do will define who we are as a nation for many years to come.

The terrorist attacks on New York City and Washington, D.C. on September 11, 2001 and the subsequent threats of biological warfare against US citizens have prompted calls by public health officials to prepare for mass vaccination campaigns for anthrax and smallpox.  National vaccination programs targeting civilians, including children, are being proposed in model state legislation that would give public health officials the power to use the state militia to enforce vaccination during state-declared health emergencies. While it is critical for the US to have a sound, workable plan to respond to an act of bioterrorism, as well as enough safe and effective vaccines stockpiled for every American who wants to use them, there are legitimate concerns about a plan which forces citizens to use vaccines without their voluntary, informed consent.
Barbara Loe Fisher  
URL: http://www.909shot.com/smallpoxspecialrpt.htm
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U.S. Department of Health and Human Services
January 25, 2002
Contact: HHS Press Office (202) 690-6343

BIOTERROR FUNDING PROVIDES BLUEPRINT TO BUILD A STRONG NEW PUBLIC HEALTH INFRASTRUCTURE

On Jan. 10, President Bush signed appropriations legislation providing $2.9 billion for HHS, a ten-fold increase in the department's funding for bioterrorism preparedness. As the lead federal agency in preparing for the bioterrorism threat, HHS will work closely with states, local government and the private sector to build the needed new public health infrastructure, and to accelerate research into likely bioterror diseases.

HHS Secretary Tommy G. Thompson has committed to providing funds rapidly, while ensuring full accountability for the new spending. He announced a first installment of more than $200 million in funding for state and local resources, to be made available by Jan. 31.
URL: http://www.hhs.gov/news/press/2002pres/20020125.html
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U.S. Department of Health and Human Services
Friday, Jan. 25, 2002
Contact: HHS Press Office (202) 690-6343

FEDERAL FUNDS FOR PUBLIC HEALTH INFRASTRUCTURE BEGINS TO FLOW TO STATES

HHS Secretary Tommy G. Thompson announced today plans for the release of the first installment of more than $200 million in funds from the more than $1 billion in bioterrorism money designated for states to help prepare their public health infrastructures to respond in the event of a bioterrorism attack.
URL: http://www.hhs.gov/news/press/2002pres/20020125a.html
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U.S. Department of Health and Human Services
Thursday, Jan. 31, 2002
Contact: HHS Press Office (202) 690-6343

HHS ANNOUNCES $1.1 BILLION IN FUNDING TO STATES FOR BIOTERRORISM PREPAREDNESS

HHS Secretary Tommy G. Thompson today sent letters to governors detailing how much each state will receive of the $1.1 billion to help them strengthen their capacity to respond to bioterrorism and other public health emergencies resulting from terrorism. The money will allow states to begin planning and building the public health systems necessary to respond.

States will be permitted to begin immediately spending up to 20 percent of their allotments, so as to avoid delay in starting preparedness measures.  The remaining 80 percent of the $1.1 billion in state funds will be released once complete plans have been received and approved.
URL: http://www.hhs.gov/news/press/2002pres/20020131b.html
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American Legislative Exchange Council (ALEC)
URL: http://www.alec.org/
[The status of the Emergency Health Powers Act in each State is also available on this web site.]

ISSUE ALERT

To: ALEC Environmental Health Academy Attendees
From:    Sandy Liddy Bourne, EENRA Task Force Director
Jennifer King, HHS Task Force Director
Date:    November 8, 2001
Re:    Model State Emergency Health Powers Act

In the aftermath of the tragic September 11 attacks on our nation, many organizations and levels of government are developing plans to address future threats, particularly biological and chemical attacks against our public health.

It has come to ALECıs attention that The Centers for Disease Control and Prevention (CDC), in conjunction with the CDC-funded Center for Law and the Public Health, has drafted model legislation to provide a framework for addressing future attacks. This model legislation, on which CDC collaborated with the National Conference of State Legislatures (NCSL), the National Governors Association (NGA), the National Association of Attorneys General (NAAG), the Association of State and Territorial Health Officials, and the National Association of City and County Health Offices, has a number of provisions which raise some concern.

Below is a brief synopsis of the Model State Emergency Health Powers Act (MEHPA)

Synopsis of the Model State Emergency Health Powers Act (MEHPA):

Grants governors broad authority to declare a state of emergency given an occurrence or imminent threat of an illness or health condition caused by Bioterrorism, epidemic, or biological toxins

Allows public health officials, among others, broad, unfettered access to personal health information without patient consent

Requires pharmacists and physicians to report ³unusual² health patterns, including personal information about persons exhibiting ³unusual² patterns

Grants public health officials broad quarantine powers and allows public health officials to require medical examinations or vaccinations, under penalty of committing a misdemeanor offense

Allows public health officials to seize and control personal property and access to communications, and to engage in any necessary rationing, quota-setting, or price-fixing

Grants governors exclusive power over the expenditure of funds appropriated for emergencies

Requires the development of a comprehensive plan to coordinate attack response

ALEC Concerns about the MEHPA:

Strips individuals and families of their rights and liberties at the expense of government

Represents unnecessary and duplicative legislation given existing state natural disaster statutes

Provides a number of potential legal loopholes for trial lawyers to extort

Grants overly sweeping takings rights to the government

Fails to consider individual state needs

Consolidates broad power to Public Health Officials, most of whom are unelected

Erects barriers to statesı ability to respond, slowing down response times

Utilizes vague language to define key concepts, including when an emergency can be declared

Grants additional, duplicative due process rights for quarantined persons

Allows public health authorities to ration drugs and other items, but does not specify the manner in which these items would be rationed

Ignores potential costs, both dollar and human.

For additional information please contact:
Sandy Bourne at (202) 466-3800 ext. 245 or
Jennifer King at (202) 466-3800 ext. 229
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Selected Laws currently in the California Emergency Services Act
Except as noted, all sections below are from the California Government Code
California's laws (Codes and Regulations which implement the Codes) can be accessed at the following web sites:
Codes:  http://www.leginfo.ca.gov/calaw.html
Regulations:  http://ccr.oal.ca.gov/

8566.  The Governor is empowered to expend any appropriation for support of the California Emergency Services Act to carry out the provisions of this chapter.

8567.  (a) The Governor may make, amend, and rescind orders and regulations necessary to carry out the provisions of this chapter. The orders and regulations shall have the force and effect of law.  Due consideration shall be given to the plans of the federal government in preparing the orders and regulations.  The Governor shall cause widespread publicity and notice to be given to all such orders and regulations, or amendments or rescissions thereof.
(b) Orders and regulations, or amendments or rescissions thereof, issued during a state of war emergency or state of emergency shall be in writing and shall take effect immediately upon their issuance. Whenever the state of war emergency or state of emergency has been terminated, the orders and regulations shall be of no further force or effect.
(c) All orders and regulations relating to the use of funds pursuant to Article 16 (commencing with Section 8645) shall be prepared in advance of any commitment or expenditure of the funds.
Other orders and regulations needed to carry out the provisions of this chapter shall, whenever practicable, be prepared in advance of a state of war emergency or state of emergency.
(d) All orders and regulations made in advance of a state of war emergency or state of emergency shall be in writing, shall be exempt from Chapter 3.5 (commencing with Section 11340) of Part 1 of Division 3 of Title 2, but shall be subject to the approval of the Emergency Council.  As soon thereafter as possible they shall be filed in the office of the Secretary of State and with the county clerk of each county.

GC 8571.  During a state of war emergency or a state of emergency the Governor may suspend any regulatory statute, or statute prescribing the procedure for conduct of state business, or the orders, rules, or regulations of any state agency, including subdivision (d) of Section 1253 of the Unemployment Insurance Code, where the Governor determines and declares that strict compliance with any statute, order, rule, or regulation would in any way prevent, hinder, or delay the mitigation of the effects of the emergency.

[for reference:  UIC §1253.  An unemployed individual is eligible to receive unemployment
compensation benefits with respect to any week only if the director finds that:
(d) He has been unemployed for a waiting period of one week as defined in Section 1254, unless this waiting period has been waived pursuant to Section 8571 of the Government Code.]

GC 8572.  In the exercise of the emergency powers hereby vested in him during a state of war emergency or state of emergency, the Governor is authorized to commandeer or utilize any private property or personnel deemed by him necessary in carrying out the responsibilities hereby vested in him as Chief Executive of the state and the state shall pay the reasonable value thereof.  Notwithstanding the provisions of this section, the Governor is not authorized to commandeer any newspaper, newspaper wire service, or radio or television station, but may, during a state of war emergency or state of emergency, and if no other means of communication are available, utilize any news wire services, and the state shall pay the reasonable value of such use.  In so utilizing any such facilities, the Governor shall interfere as little as possible with their use for the transmission of news.

8586.  The Governor shall assign all or part of his powers and duties under this chapter to the Office of Emergency Services. The Director of the Office of Emergency Services shall appoint pursuant to the State Civil Service Act such employees as are needed.

8587.  During a state of war emergency, a state of emergency, or a local emergency, the director shall coordinate the emergency activities of all state agencies in connection with such emergency, and every state agency and officer shall cooperate with the director in rendering all possible assistance in carrying out the provisions of this chapter.
In addition to the powers herein designated, the Governor may delegate any of the powers vested in him under this chapter to the Director of the Office of Emergency Services except the power to make, amend, and rescind orders and regulations, and the power to proclaim a state of emergency.

Art. 13. State of Emergency

8625.  The Governor is hereby empowered to proclaim a state of emergency in an area affected or likely to be affected thereby when:
(a) He finds that circumstances described in subdivision (b) of Section 8558 [[see below]] exist; and either
(b) He is requested to do so (1) in the case of a city by the mayor or chief executive, (2) in the case of a county by the chairman of the board of supervisors or the county administrative officer; or
(c) He finds that local authority is inadequate to cope with the emergency.

8626.  Such proclamation shall be in writing and shall take effect immediately upon its issuance.  As soon thereafter as possible such proclamation shall be filed in the office of the Secretary of State. The Governor shall cause widespread publicity and notice to be given such proclamation.

8627.  During a state of emergency the Governor shall, to the extent he deems necessary, have complete authority over all agencies of the state government and the right to exercise within the area designated all police power vested in the state by the Constitution and laws of the State of California in order to effectuate the purposes of this chapter.  In exercise thereof, he shall promulgate, issue, and enforce such orders and regulations as he deems necessary, in accordance with the provisions of Section 8567.

8627.5.  (a) The Governor may make, amend, or rescind orders and regulations during a state of emergency that temporarily suspend any state, county, city, or special district statute, ordinance, regulation, or rule imposing nonsafety related restrictions on the delivery of food products, pharmaceuticals, and other emergency necessities distributed through retail or institutional channels, including, but not limited to, hospitals, jails, restaurants, and schools.  The Governor shall cause widespread publicity and notice to be given to all of these orders and regulations, or amendments and rescissions thereof.
(b) The orders and regulations shall be in writing and take effect immediately on issuance.  The temporary suspension of any statute, ordinance, regulation, or rule shall remain in effect until the order or regulation is rescinded by the Governor, the Governor proclaims the termination of the state of emergency, or for a period of 60 days, whichever occurs first.

8628.  During a state of emergency the Governor may direct all agencies of the state government to utilize and employ state personnel, equipment, and facilities for the performance of any and all activities designed to prevent or alleviate actual and threatened damage due to the emergency; and he may direct such agencies to provide supplemental services and equipment to political subdivisions to restore any services which must be restored in order to provide for the health and safety of the citizens of the affected area.  Any agency so directed by the Governor may expend any of the moneys which have been appropriated to it in performing such activities, irrespective of the particular purpose for which the money was appropriated.

8629.  The Governor shall proclaim the termination of a state of emergency at the earliest possible date that conditions warrant.  All of the powers granted the Governor by this chapter with respect to a state of emergency shall terminate when the state of emergency has been terminated by proclamation of the Governor or by concurrent resolution of the Legislature declaring it at an end.

Circumstances describing an emergency referenced in GC 8625

8558.  Three conditions or degrees of emergency are established by this chapter:
(a) "State of war emergency" means the condition which exists immediately, with or without a proclamation thereof by the Governor, whenever this state or nation is attacked by an enemy of the United States, or upon receipt by the state of a warning from the federal government indicating that such an enemy attack is probable or imminent.
(b) "State of emergency" means the duly proclaimed existence of conditions of disaster or of extreme peril to the safety of persons and property within the state caused by such conditions as air
pollution, fire, flood, storm, epidemic, riot, drought, sudden and severe energy shortage, plant or animal infestation or disease, the Governor's warning of an earthquake or volcanic prediction, or an earthquake, complications resulting from the Year 2000 Problem, or other conditions, other than conditions resulting from a labor controversy or conditions causing a "state of war emergency," which, by reason of their magnitude, are or are likely to be beyond the control of the services, personnel, equipment, and facilities of any single county, city and county, or city and require the combined forces of a mutual aid region or regions to combat, or with respect to regulated energy utilities, a sudden and severe energy shortage requires extraordinary measures beyond the authority vested in the California Public Utilities Commission.
(c) "Local emergency" means the duly proclaimed existence of conditions of disaster or of extreme peril to the safety of persons and property within the territorial limits of a county, city and county, or city, caused by such conditions as air pollution, fire, flood, storm, epidemic, riot, drought, sudden and severe energy shortage, plant or animal infestation or disease, the Governor's warning of an earthquake or volcanic prediction, or an earthquake, complications resulting from the Year 2000 Problem, or other conditions, other than conditions resulting from a labor controversy,
which are or are likely to be beyond the control of the services, personnel, equipment, and facilities of that political subdivision and require the combined forces of other political subdivisions to combat, or with respect to regulated energy utilities, a sudden and severe energy shortage requires extraordinary measures beyond the authority vested in the California Public Utilities Commission.

Art. 17. Privileges and Immunities

8655.  The state or its political subdivisions shall not be liable for any claim based upon the exercise or performance, or the failure to exercise or perform, a discretionary function or duty on the part of a state or local agency or any employee of the state or its political subdivisions in carrying out the provisions of this chapter.

8659.  Any physician or surgeon (whether licensed in this state or any other state), hospital, pharmacist, nurse, or dentist who renders services during any state of war emergency, a state of emergency, or a local emergency at the express or implied request of any responsible state or local official or agency shall have no liability for any injury sustained by any person by reason of such services, regardless of how or under what circumstances or by what cause such injuries are sustained; provided, however, that the immunity herein granted shall not apply in the event of a willful act or omission.

8660.  No other state or its officers or employees rendering aid in this state pursuant to any interstate arrangement, agreement, or compact shall be liable on account of any act or omission in good faith on the part of such state or its officers or employees while so engaged, or on account of the maintenance or use of any equipment or supplies in connection with an emergency.
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Excerpts from the California Health and Safety Code
The following references in the California Health and Safety Code are indicative of the fact that California laws currently deal with most of the same issues as the proposed new Emergency Health Powers Act, such as:

*  contagious, infectious, and communicable diseases
*  acquisition and disposition of contaminated property
*  isolation and quarantine of individuals and groups of individuals
*  identification reporting of contagious, infectious, and communicable diseases

Section 120130 requires the establishment of a listing of reportable diseases, requires prompt reporting and allows isolation or quarantine for any case of contagious, infectious, or communicable disease.

Section 120135 allows the Department of Health Services to establish and maintain places of quarantine or isolation.

Section 120145 allows the Department of Health Services to quarantine, isolate, inspect, and disinfect persons, animals, houses, rooms, other property, etc.

Section 120150 allows the Department of Health Services to destroy such household goods, furnishings, materials, clothing, or animals.

Section 120190 requires each health officer to immediately report every case of a disease designated for immediate reporting by the department.

Section 120250 requires all physicians, nurses, clergymen, attendants, owners, proprietors, managers, employees, and persons living with, or visiting any sick person who is ill of any infectious, contagious, or communicable disease, to promptly report that fact.