2024 amendments to the International Health regulations 2005
Feedback to Joint standing committee on treaties
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We have a number of concerns about what the WHO is proposing under the 2024 amendments to the International Health Regulation 2005 (2024 IHRs). The most concerning can be summarised into 5 topics:
- Choice – the right to make choices for you and your family
- Censorship – the right to be able to speak freely and receive information
- Surveillance – in the form of tracking and tracing
- Control – countries will have to implement the changes into their domestic legislation
- Cost – both financial and social
The Joint Standing Committee on Treaties (JSCT) is an Australian government committee that has asked for your feedback on the 2024 IHRs.
It’s easy and we encourage you to give your feedback, which closes 23 January 2025.
- Copy and paste the template into a Word document:
- Head up the document 2024 amendments to International Health Regulations 2005.
- Choose 3+ points from the bullet points below and add them to your Word document. It’s important to use your own selection (and words if you can) so that your feedback is unique to you – so it gets counted!
- Add any other points you wish.
- PDF your Word document and submit your feedback via any of the following options:
a. the government’s Lodge Your submission portal
c. if you’d like to go to the pleasure of posting your feedback:
Committee Secretary
Joint Standing Committee on Treaties
PO Box 6021
Parliament House
Canberra ACT 2600
These are the 2024 International Health Regulations that feedback is being sought on.
Bullet points below cross reference to the relevant Article in the 2024 IHRs.
Joint Standing Committee on Treaties Invitation to make a submission
Good afternoon,
The Joint Standing Committee on Treaties (JSCT) is undertaking an inquiry into the following major treaty action:
Amendments to the International Health Regulations
The Committee welcomes your views on any or all aspects of this treaty, depending on your areas of interest and expertise. Further information about the treaty is available on the JSCT website.
You are also welcome to extend this invitation to any colleagues, individuals, or organisations that may have an interest in this issue and may wish to prepare a submission for the Committee’s consideration.
Submissions should be sent to the Committee by Thursday, 23 January 2025. It is preferred that submissions are uploaded electronically through this page.
Once a document is received, the Committee decides whether to accept the document as a submission and publish it on its website. Please note that making a submission constitutes giving evidence and attracts parliamentary privilege. Once you have provided a submission to the Committee you cannot withdraw it or alter it without the Committee’s permission. Please note that your document should not be disclosed to any other person until its publication has been authorised by the Committee.
While the Committee generally prefers submissions be made public, you may request that part or all your submission be kept confidential. Any request for confidentiality should include reasons for the request and be provided in writing for the Committee to consider.
Please refer to the following brochure for helpful information on preparing a submission, including information about parliamentary privilege and requests for confidentiality here.
If you require further information, please contact the Secretariat on (02) 6277 4002.
Template response
Re: 2024 amendments to the International Health Regulations 2005
I oppose the 2024 International Health Regulations for the reasons given in this feedback.
[reason one]
[reason two]
[reason three]
[reason two]
[reason three]
No convincing case for these reforms has been proposed. The proposals should be abandoned.
Australia must expressly reject the 2024 IHRs by or before 19 July 2025 and I trust that JSCT will make that recommendation.
Yours sincerely
[name]
Bullet Points To Choose From
Choice - Maintain my right to choose what is right for me and my family
- The principle of informed consent and the right to access safe and effective medical products cannot be denied, nor can the right not to be subjected to medical or scientific experimentation without free consent, which is inconsistent with Article 7 of the ICCPR. Articles 1, 3, 13.
- How can my individual human rights sit beside equity and solidarity? The additions in Article 3.1 to promote ‘equity and solidarity’, concerns me. Equity means ‘the quality of being fair and impartial’; Solidarity means ‘unity or agreement of feeling or action, especially among individuals with a common interest; mutual support within a group.’. What is suggested by the inclusion of these words is that decision makers will treat humanity as one mass organism. How can this consistently sit beside the “full respect for the dignity, human rights and fundamental freedoms of persons” in Article 3 and clearly relates to ‘relevant health products’? Articles 3 and 13.
- I am concerned about the new definition of relevant health products: “means those health products needed to respond to public health emergencies of international concern, including pandemic emergencies, which may include medicines, vaccines, diagnostics, medical devices, vector control products, personal protective equipment, decontamination products, assistive products, antidotes, cell- and gene-based therapies, and other health technologies;” only lists products produced by pharmaceutical companies, many of whom are in private public partnerships with the WHO. The definition fails to list vitamins, minerals, herbs or lifestyle recommendations. This is a concern where “the WHO shall facilitate, and work to remove barriers to, timely and equitable access by States Parties to relevant health products after the determination of and during a public health emergency of international concern , including a pandemic emergency, based on public health risks and needs.” Articles 1 and 13.
Censorship - who gets to say whether it's misinformation?
- The 2024 IHRs outlines countries censor their citizens by “addressing mis and disinformation”. This will be extended to censoring scientific debate. Annex 1.
- We have already seen attempts this year by the Australian government to introduce the Combatting Mis and Dis-information Bill, which did not pass. Australian’s do not consent to being censored in any way.
- It is not for the WHO to collect and share information it feels appropriate. All information should be available for the benefit of humanity. Article 11.
- The WHO proposes to control research and development. Article 11.
- The United Nation’s own Special Special Rapporteur highlighted areas of concern during the COVID-19 pandemic, showing that access to information, independent media and other free expression rights are critical to meeting the challenges of pandemic. April 2020 Report of the Special Rapporteur on the promotion and protection of the right to freedom of opinion and expression.
Surveillance
- Surveillance is a core requirement in the 2024 IHRs and will likely be through digital means, I am concerned that this additional surveillance and tracking through digital identification goes against my right to freedom of movement and my right to privacy.
- The Australian government can not agree to give away our personal medical information or allow the WHO to conduct surveillance over its people. Article 5 Surveillance, Annex 1 (Part A) and Article 11 Exchange of information.
- The Australian government cannot agree to provide the WHO microbial, genomic sequencing data and/or genetic material and samples from its people. Articles 6 Notification and Annex 1 (Part A).
- I am concerned about the Surveillance that is proposed. A global digital identification system of health certificates or vaccine passports as a condition for travelling across borders is inconsistent with the internationally respected human rights of health, freedom of movement, and the International Rights Australia has signed up to. Articles 5, 18, 23, 31, 35, 36. This is clearly intended with work on an international health certificate which is already well advanced, for more see here, here, here and here.
- The restriction on travel and implementation of vaccine passes is not ethical and will lead to discrimination. Articles 18, 23, 31, 35, 36.
- Propose universal implementation of health/vaccine passports will be a burden and raises ethical and discrimination-related concerns. Articles 23, 35, 36, and 37.
Control - the WHO is acting outside its remit
- Is this necessary? Two peer-reviewed studies, recently published by the University of Leeds, confirms that: the risk of naturally occurring pandemics is low; Covid-19 is an outlier, likely because of its questionable origin; and proposed pandemic treaty changes will cost Australians billions of dollars, drawing valuable money and resources from Australians in real need.
- The WHO can’t even be trusted to follow its own rules now, so how can we expect it to comply with the new ones it is making? The 2024 IHR amendments were due for delivery 4 months before May 2024. They were not supplied in accordance with Decision WHA75(9) and Article 55 IHRs. So how can the WHO be trusted to follow any of the rules that relate to its new powers it is establishing for itself?
- The WHO is already a law unto its own, whereby we, as citizens of Australia, have no recourse to the WHO. It goes against our inherent constitution that the WHO has any say in Australia. Sovereignty means the authority of a state to govern itself (or another state). The 2024 IHR amendments do raise concerns with respect to Member States ceding sovereignty to the WHO, namely:
– With the removal of key consultative steps with the State Party when an ‘event’ occurs, Articles 1, 12, 42 and 43.
– The obligation for State Parties to accept or justify rejecting WHO’s offer of assistance underlines Member State sovereignty. Article 13.3.
– The requirement for Australia to establish an entity that is responsible for the overall implementation of the Regulations (not only the health measures) is a matter of sovereignty. Article 4.
– The amendment requiring on-site assessments. Article 13.4 and 5. - The amendments go beyond what the WHO is entitled to do, Article 21 of the WHO Constitution limits the Health Assembly’s authority to only adopt regulations concerning:
“a) sanitary and quarantine requirements and other procedures designed to prevent the international spread of disease;
(b) nomenclatures with respect to diseases, causes of death and public health practices;
(c) standards with respect to diagnostic procedures for international use;
(d) standards with respect to the safety, purity and potency of biological, pharmaceutical and similar products moving in international commerce;
(e) advertising and labelling of biological, pharmaceutical and similar products moving in international commerce.”
- The amendments could extend the power to the WHO to declare potential health emergencies related to climate!
- The WHO is identifying new roles and groups that we will have to engage or use. These roles are not elected. e.g., the expansion of the National IHR Focal Point and introduction of a National Competent Authority responsible for the implementation of the Regulations. Article 4.
Cost - financial and social
- Has JSCT looked into how much is this going to cost Australia? In a cost of living crisis, Australia has already voluntarily gave the WHO $100 million in September 2023 on top of Australia’s core contribution of $75 million for 2022-2027.
- The WHO will have the power to determine whether Australia should give money to a developing nations. Article 44A. A peer reviewed paper from the University of Leeds outlines the proposed pandemic treaty changes will cost Australians billions of dollars, drawing valuable money and resources from Australians in real need.
- There has been no review or commission of inquiry about the social costs of Covid-19 lockdowns but we certainly know that our children’s education has been effected, elderly are scared and still wear masks, and the social division caused by vaccine mandates created medical apartheid.
- The public health response of the last 4 years was able to be conducted under the 2005 International Health Regulations, which are currently binding on Australia. Those 2005 IHRs allowed the WHO to make recommendations only. Australia voluntarily cooperated with the recommendations of the WHO. Australia does not need a version of the regulations which removes from it the power to make decisions in the best interests of its people.
- No time has been taken or inquiry completed to assess Australia’s response to the international public health emergency. Therefore, there has been no time to review or make findings of what we got right and what we could improve upon. An outcome from an inquiry is required before we run headlong into a set of regulations that will only strengthen the WHO’s power to make decisions with respect to health emergencies of international concern.
The WHO must reform itself to remove conflicts and remain an advisory body only
- I am concerned that the definition of “pandemic emergency” in Article 1 is vague that it could be anything and leaves the decision to the Director-General of the WHO. Articles 1, 12.
- I do not consent to Australia giving away its power to make decisions about any public health emergency that occurs within its borders and with respect to its citizens. Article 1, 12, 42 and 43.
- The WHO must remain an advisory body only. Articles 1, 12, 42 and 43.
- During COVID-19 pandemic, the World Health Organization failed to uphold its mission and caved to Chinese Communist Party pressure. United States’ Select Subcommittee on Coronavirus Pandemic.
- A public health emergency of international concern needs to be an actual public health emergency, not a potential health emergency. Articles 2, 5, and 12.
- It is for Australia to retain its decision-making power on whether health measures are suitable for its citizens. It is not for some unelected organisation to dictate what Australia must implement, it must be Australia’s decision to decide what is suitable and appropriate to Australia. See Article 42 related to Articles 15 and 16 (re Temporary and Standing Recommendations Respectively).
- The WHO should have no power over health products or health technologies and know-how, including defining what a person or country is required to take, receive or use, or what they can’t take, receive or use. Article 1.
- The WHO is no longer solely funded by the member states from which it is formed. Significant funding (at least 80%) comes from voluntary contributions from public/private partnerships. This funding undermines the independence of the WHO and creates an inherent bias and pressure from the private outside interests that fund it. It is, therefore, not surprising that as private funding has increased, so has the number of declared pandemics.
It is so important that we all engage and participate in democracy so we can maintain the freedoms we so value.
Thank you for taking the time to give your feedback. Every bit helps.
You might like to also share your feedback with your MP to keep them up to date on your concerns about what is posed by the World Health Organisation.
