Project 2025 vs. The Public’s Health, Part II

Part II: The FDA

In 2023, the Heritage Foundation published a 900-page document titled Project 2025: Mandate for Leadership: The Conservative Promise. The introduction states, “The 2025 Presidential Transition Project is the conservative movement’s unified effort to be ready for the next conservative Administration to govern at 12:00 noon, January 20, 2025.” Should Donald Trump be elected president, this document provides a blueprint for government agencies, including those involving public health. In the second part of this three-part series, we will examine Project 2025’s prescriptions for the Food and Drug Administration (FDA).

The authors of Project 2025 state, “Thousands of Americans of faith and conscience wish to receive various childhood vaccinations for themselves and their families but are not allowed to receive vaccines that are derived through or tested on aborted fetal cells. For example, the chickenpox, Hepatitis, and MMR vaccines in the U.S. are all linked to abortion in this way. There are ethically derived alternatives abroad that have been used safely there for decades, but the FDA makes it exceedingly difficult for Americans to import them.”

In the early 1960s, two cell lines were derived from elective abortions; one in Sweden (WI-38), the other in England (MRC-5). These two cell lines have been used to make the rubella (German measles), hepatitis A, and varicella (chickenpox) vaccines for more than 30 years. The authors of Project 2025 argue that the use of fetal cells is morally reprehensible, especially for Catholics, for whom abortion is a sin worthy of excommunication. Project 2025 claims that the FDA has made it virtually impossible to obtain vaccines made outside the United States that don’t use fetal cells. But have they?

First, vaccines to prevent hepatitis A and varicella that are not grown in fetal cells don’t exist anywhere in the world. There are, however, three rubella vaccines made in Japan that don’t use fetal cells. Two of those vaccines, which are produced by the Kitasato Institute and Takeda Chemical Industries, use rabbit kidney cells; one, made by Biken, uses quail embryo fibroblast cells. The FDA would never allow importation of these vaccines for American children without first testing them in American children. Because rubella was eliminated from the United States in 2005, tests of efficacy would be impossible. Only safety and immunogenicity studies could be performed. The cost to obtain a license in the United States for use of these rubella vaccines—which would include not only licensing the product, but the building in which the vaccines are made, and the protocols used for production—would be hundreds of millions of dollars for at best a very small market product. This isn’t financially viable.

Second, vaccines aren’t interchangeable. We can’t just import foreign-made vaccines and assume they are equally safe and effective. For example, the Jeryl Lynn strain of mumps vaccine is used in the United States. The Urabe strain of mumps vaccine, which is used in Japan, has a much higher rate of side effects including viral meningitis. For that reason, the Urabe strain of mumps vaccine would never be used in the United States.

Third, the authors of Project 2025 state that Americans of faith are “not allowed” to receive vaccines derived from aborted fetal cells. This isn’t true. The morality of these vaccines has been addressed by the Pontifical Academy for Life, the major policy making body of the Catholic Church. In 2005, Joseph Ratzinger, then head of the Pontifical Academy for Life—who would later become Pope Benedict XVI—stated that rubella vaccines can be given to children of Catholic parents “insomuch as is necessary in order to avoid a serious risk not only for one’s own children but also, and perhaps more specifically, for the health conditions of the population as a whole—especially for pregnant women.” In other words, like all religions, the Catholic Church views the health of the child, the family, and the community as paramount. The Pontifical Academy for Life further noted that not everyone who is vulnerable to infections can be vaccinated, stating, “the moral obligation to guarantee the vaccination coverage necessary for the safety of others is no less urgent, especially the safety of more vulnerable subjects such as pregnant women and those affected by immunodeficiency who cannot be vaccinated against these diseases.” In other words, every choice is a moral choice.

The authors of Project 2025 have failed to show an understanding of how vaccines are made, tested, supervised, and licensed. Nor have they provided a moral path forward for vaccines they consider to be immoral.

Here is the video version from Vincent Racaniello’s MicrobeTV: