133 Molesworth Street
PO Box 5013
Wellington 6140
New Zealand
T+64 4 496 2000
By email: [FYI request #18184 email]
Ref:
H202200228
Tēnā koe John,
Response to your request for official information
Thank you for your request under the Official Information Act 1982 (the Act) to the Ministry of
Health (the Ministry) on 13 January 2022 regarding COVID-19 vaccine exemptions. Please find
a response to each part of your request below.
Where a subsequent dose of Comirnaty is contraindicated by medical experts due to the
severity of an adverse reaction what medical data or evidence does the Exemption Panel
have to prove that a different vaccine wil be suitable for that patient.
The temporary medical exemption panel (the Panel) was established by the Ministry to receive
and consider applications for temporary medical exemption from being vaccinated against
COVID-19. When someone’s application for a temporary medical exemption is declined, they
are advised of this in writing by the Ministry. This letter informs people to consult with their
preferred health professional to assess the best vaccination options for them, which may
include the use of an alternate approved COVID-19 vaccine.
Every vaccine has some differences, and as such, the Pfizer vaccination has some
contraindications which are unique to this vaccine. This means that many individuals who are
unable to receive the Pfizer vaccine, may be able to safely receive the AstraZeneca (AZ) or
Novavax vaccine.
The criteria for temporary medical exemptions were formed on the advice of the COVID-19
Vaccine Technical Advisory Group (CV-TAG). A copy of this advice is attached and has been
released to you in full.
… how many people, who have had serious adverse reactions after having been
vaccinated with Comirnaty as the primary dose, then gone on to have the AstraZeneca as
the secondary dose in New Zealand and have they all been adverse free
As of 21 January 2022, the COVID Immunisation Register showed that 474 individuals had
received one dose of the Pfizer vaccine, and a subsequent dose of the AZ Vaccine.
As of 21 January a total of 13 patients reported events after having the Pfizer vaccine that
required emergency care or were serious, and then also went on to report a reaction with the AZ
vaccine that was either non-serious or serious.
Further details regarding adverse events following vaccination with the AZ vaccine are included
in the vaccine safety reports published by Medsafe. These reports can be found at
www.medsafe.govt.nz/COVID-19/vaccine-report-overview.asp. It should also be noted that not
all individuals who experience an adverse event following vaccination wil report it.
How does all of this compare to other Western Countries as surely the Exemption Panel
must be looking at more than local data to base their decisions on what is suitable.
As stated earlier, CV-TAG developed the advice on clinical criteria for medical exemptions from
vaccination. CV-TAG monitor international trends, research and developments relating to Covid-
19 Vaccines and take this into account when forming their advice.
Recommendations made by the Panel are based on the individual clinical information presented
to it.
Under section 28(3) of the Act you have the right to ask the Ombudsman to review any
decisions made under this request. The Ombudsman may be contacted by email at:
[email address] or by calling 0800 802 602.
Please note that this response, with your personal details removed, may be published on the
Ministry of Health website at:
www.health.govt.nz/about-ministry/information-releases.
Nāku noa, nā
Astrid Koornneef
Director
National Immunisation Programme
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