Response to Emergency Rulemaking

ICWA’s Public Policy Director sent the following in an email comment to the WA State Board of Health, Secretary of Health Wiesman, and Chief Science Officer Lofy in response to their July 30 meeting to discuss Emergency Rulemaking – chapter 246-101 WAC, Notification of Novel Coronavirus (SARS-CoV-2). Agenda and meeting materials available here:

Dear Board Members:

I understand the reasons for adding COVID-19 to the list of Notifiable Conditions in order to better gather needed data, however without accurate testing capability, and by confusing the virus (Sars-CoV-2) with the disease (COVID-19) this action will only further confuse the situation now, and during any future outbreaks.

Secretary Wiesman wrote in the background and summary section of his letter regarding today’s meeting:

Novel Coronavirus (SARS-CoV-2), also known as Coronavirus Disease 2019 (COVID- 19), is a respiratory illness caused by a new or “novel” coronavirus that was not identified in humans before December 2019. 

SARS-CoV-2 is not synonymous with COVID-19. The virus is not the disease that it can cause. This distinction is very important. A person testing “positive” may simply have remnants of the virus in or on their body, but not have clinical disease. At anytime, anyone can be swabbed and found to be happily harboring all sorts of viruses without being ill and without being a source of transmission to others. Clinical cases of viral disease require a symptomatic basis.

To continue to conflate the mere presence of the virus with a diagnosis of disease will consistently lead to an exaggeration of the size of any outbreak, epidemic or pandemic, and would be irresponsible, causing unnecessary lockdowns, closures, and fear. Does DOH equate all positive tests with cases in the data they supply to the public?

Additionally, we continue to learn of flaws with the PCR tests. There are false positives and negatives and numerous other issues being reported. This most recent one was published on July 17 in the International Journal of Geriatrics and Rehabilitation 2(1):69- 96 and is of great concern.

“Abstract: Currently, molecular tests for SARS-CoV-2 infection are primarily based on reverse transcription- quantitative polymerase chain reaction (RT-qPCR) on cell-free fluid samples of respiratory tract specimens. These tests measure the rate of fluorescent signal accumulation as a surrogate for direct DNA sequence determination and are known to generate false-negative and false-positive results. The author has developed a routine protocol to test the cellular components of respiratory tract specimens instead of cell-free fluids only and to use conventional nested RT-PCR to amplify the target nucleic acid for high detection sensitivity. A 398-bp heminested PCR amplicon is used as the template for direct DNA sequencing to ensure no false-positive test results. Using this protocol to re-test 20 reference samples prepared by the Connecticut State Department of Public Health, the author found 2 positives among 10 samples classified as negative by RT-qPCR assays. One of these two positive samples contained a mutant with a novel single nucleotide insertion in the N gene and a wild-type parental SARS-CoV-2. Of the 10 samples classified as positive by RT-qPCR assays, only 7 (7/10) were confirmed to contain SARS-CoV-2 by heminested PCR and DNA sequencing of a 398-bp amplicon of the N gene. One of the latter 7 positive SARS-CoV-2 isolates belongs to a newly discovered mutant first isolated from a specimen collected in the State of New York on March 17, 2020, according to information retrieved from the GenBank database. Routine sequencing of a 398-bp PCR amplicon can categorize any isolate into one of 6 clades of SARS-CoV-2 strains known to circulate in the United States. The author proposes that extremely accurate routine laboratory tests for SARS-CoV-2 be implemented as businesses attempt to return to normal operation in order to avoid raising false alarms of a re-emerging outbreak. False-positive laboratory test reports can easily create unnecessary panic resulting in negative impacts on local economies.”

We do need to know who is susceptible to the DISEASE, and the reasons for that susceptibility must be addressed. Low Vitamin D levels is the most common factor of all who are experience severe disease. All of the identified susceptibility factors—age, chronic health issue, smoking, low Vitamin D, A, C, zinc  levels, etc. — lead to one shared nutritional deficiency at the root of symptoms: glutathione depletion. Not only do chronic nutritional and health issues lead to glutathione depletion, but the immune system uses glutathione to fight viral infection, leading to further depletion. Add Tylenol to the mix, which depletes glutathione so rapidly as little as one extra dose can lead to hospitalization and liver failure—and you can see the huge problem. Hospitals administer NAC, a key amino acid needed to form glutathione, in order to reverse the Tylenol damage. NAC can address all cases of depleted glutathione, no matter what the cause.

Published May 28 in the American Chemical Society, Public Health Emergency Collection:

Endogenous Deficiency of Glutathione as the Most Likely Cause of Serious Manifestations and Death in COVID-19 Patients

“Glutathione deficiency is an acquired condition attributable to decreased biosynthesis and/or increased depletion of the endogenous GSH pool influenced by risk factors such as aging, male sex, comorbidity, and smoking alone or in combinations. Glutathione deficiency in COVID-19 patients with serious illness may also be a result of decreased consumption of fresh vegetables and fruits (especially during winter and spring seasons), which contributes to over 50% of dietary glutathione intake. The hypothesis suggests that SARS-CoV-2 virus poses a danger only for people with endogenous glutathione deficiency, regardless which of the factors aging, chronic disease comorbidity, smoking or some others were responsible for this deficit. The hypothesis provides novel insights into the etiology and mechanisms responsible for serious manifestations of COVID-19 infection and justifies promising opportunities for effective treatment and prevention of the illness through glutathione recovering with N-acetylcysteine and reduced glutathione.

Since the antiviral effect of glutathione is nonspecific, there is reason to believe that glutathione is also active against SARS-CoV-2. Therefore, restoration of glutathione levels in COVID-19 patients would be a promising approach for the management of the novel coronavirus SARS-CoV-2. Notably, long-term oral administration of N-acetylcysteine has already been tested as an effective preventive measure against respiratory viral infections.1 N-Acetylcysteine is widely available, safe, and cheap and could be used in an “off-label” manner. Moreover, parenteral injection of NAC or reduced glutathione (GSH is more bioavailable than NAC) could be an efficient therapy for COVID-19 patients with serious illness. Horowitz et al.18 just published a paper confirming this hypothesis: the authors reported the efficacy of glutathione therapy in relieving dyspnea associated with COVID-19 pneumonia.”

I have previously sent several of the existing effective treatments that are preventing severe disease and recovered patients from all stages of disease that range from the MATH+ Protocol to HBOT (hyperbaric oxygen treatment) to Dr. Brownstein’s recently published case series of 107 patients successfully recovered by the use of nutritional and oxygen therapies. All of these treatments work in some manner to increase glutathione levels.

And while extremely political, HCQ (hydroxychloroquine) with zinc is being used effectively around the world, and even here in the U.S., to prevent infection as well as recover patients in the early stages. Dosage, timing, and zinc are critical. This is an existing and inexpensive treatment that now appears to have been maligned though false and fraudulent papers (now retracted), with possible involvement by Gilead in order for their Remdesivir to win the coveted recommendation as the leading drug treatment. The clinical trials of Remdesivir are being questioned.

The hardest hit in Washington have been those in nursing care facilities and Hispanics. Getting these populations the building blocks of glutathione and immune system health, including Vitamin D, could go a long ways in reducing fatalities as well as reducing severity of cases. And the underlying reasons for their unique susceptibility must be addressed going forward. What environmental factors are causing the susceptibility in these populations? If those are not addressed, they will remain vulnerable to future infections.

Human beings and our immune systems are not made of the molecules created by man in labs. We are made of the molecules found in nature. We become depleted in those molecules and they must be replaced in order for our immune systems to function well and properly.

In the U.S., the CDC reports there are at least 380,000 deaths annually in Long Term Care Facilities due to preventable infections. Add the 90,000 annual deaths in hospitals due to preventable hospital acquired infections, and you get a whopping 470,000 preventable deaths in the very same populations hit hardest by Covid 19. It’s time for an integrated approach to care in hospitals and long term facilities. Nutritional status does matter, in fact, it makes the critical difference between infection and disease, between life or death.

We need accurate testing, and we immediately need ALL effective preventive and treatment protocols to be brought on board the state’s response.


Bernadette Pajer

Public Policy Director


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