Bridging TERA and TSCA: Exposing Gaps in VA Policy on "Vaccine" Injuries

How Leveraging Toxic Substances Control Act Principles Could Uncover Cumulative Risks and Protect Our Troops

A Critical Examination of Legal and Regulatory Gaps in VA Policy on “Vaccine”-Related Injuries

BLUF (Bottom Line Up Front):
At the end of the day, the issue with TERA (Toxic Exposure Risk Activity) boils down to the need to revoke the VA's fraudulent Standard Operating Procedure (SOP) policy. This policy disregards the acknowledgment of vaccine - and so-called vaccines - mRNA platforms-related injuries in the context of risk exposure. The VA's claim that vaccines are excluded from consideration under TERA is an administrative maneuver, a form of warfare designed to suppress the recognition of real risks to our troops.

It’s crucial not to get distracted by legal jargon or "tobacco science" when considering the implications of the Toxic Substances Control Act (TSCA). While the TSCA is important in regulating chemical exposures, it is not the same as recognizing the deliberate exclusion of vaccine injuries in the TERA provisions. The TSCA’s focus on cumulative risk and chemical toxicity can serve as a strong framework to argue that vaccine-related injuries should be included under TERA, challenging the VA’s resistance and pushing for a more honest, protective stance for those who served.

The issue is not the need to expand the TERA provisions but to remove the fraudulent SOP that prevents the law from functioning as intended. This SOP unjustly excludes vaccine-related injuries and other potential toxic exposures from being considered under TERA, which is a clear administrative failure. The VA’s practice of presuming toxic exposure risk for veterans, even those who merely fly over the Southwest Asia theater of operations, demonstrates the egregious nature of this policy.

It’s critical to distinguish between definitively labeling something as a toxin (such as a gene therapy injection) and acknowledging the potential risk of toxic exposure. The law should allow veterans to obtain medical opinions for unexplained disabilities that could be linked to these risks, including those from vaccines and other exposures. The VA's fraudulent SOP is the real barrier here, not the need for expanded provisions under TERA. By revoking this fraudulent SOP, the VA would align with the law's intent to provide proper recognition and care for all veterans impacted by toxic exposure risks.

The key action is to revoke the VA's policy that wrongfully excludes vaccines from TERA risk exposure assessments, ensuring that vaccine injuries are recognized and addressed like any other toxic exposure. With that said…

A Growing Concern for National Security: Toxic Exposures and Regulatory Gaps

As we face an evolving landscape of toxic exposures, particularly related to the COVID-19 so-called vaccines, the need for a more comprehensive and transparent approach to evaluating the risks posed to our service members is critical. This discussion explores how the Toxic Substances Control Act (TSCA) and the PACT Act’s Toxic Exposure Risk Activity (TERA) provisions intersect to address growing concerns over vaccine-related injuries, particularly those caused by the mRNA treatments, often referred to as "vaccines" or experimental gene therapies. Specifically, this analysis examines how TSCA’s framework for cumulative risk assessment of synthetic chemicals aligns with the TERA provisions and provides a compelling basis for recognizing and addressing the injuries caused by novel synthetic substances, such as those used in COVID-19 treatments. By applying these regulatory approaches, a pathway can be created to challenge the Department of Veterans Affairs’ ongoing resistance to acknowledging vaccine-related injuries, ultimately contributing to the strengthening of national security and the health of military personnel. EPA TSCA

Leveraging TSCA and TERA to Challenge the VA's Exclusion of “Vaccine”-Related Injuries

The core issue in this article is to tease out another possible legal framework surrounding how the Department of Veterans Affairs (VA) addresses vaccine-related injuries, by incorporating principles from the Toxic Substances Control Act (TSCA) and the Toxic Exposure Risk Activity (TERA) provisions of the PACT Act. The goal is to expose the deficiencies in the VA’s current policy and demonstrate, through scientific and regulatory analysis, that the synthetic substances found in COVID-19 “vaccines”—particularly mRNA technology, lipid nanoparticles, and excipients—pose cumulative risks that warrant recognition under TERA. Additionally, CFR Title 40, Part 710 (Chemical Substances Inventory Reporting) and Section 8(e) of TSCA, which require the reporting of new chemicals that may present an unreasonable risk to health or the environment, underscore the need for a reevaluation of vaccine components. And - yes we already have plenty of evidence of toxicity but…

for image credit: TSCA Substance Inventory

The failure to apply these standards within the Department of Defense (DOD) and VA constitutes a potential violation of regulatory responsibilities, putting military personnel and veterans at risk. Below is a more structured summary that integrates the key points of this argument:

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1. Aligning TSCA and TERA: A Regulatory and Toxicological Bridge

• TSCA and TERA Connection:
  TSCA regulates synthetic chemicals, including new and engineered substances with potential toxicological risks. Examples from COVID-19 "vaccines" — like lipid nanoparticles (LNPs), polyethylene glycol (PEG), and synthetic nucleosides (like N1-methyl-pseudouridine) — fall under this category due to their potential for bioaccumulation and long-term effects.

• TERA, within the PACT Act, assesses toxic exposures related to military service, including substances like burn pit toxins, heavy metals, and PFAS. When combined with synthetic components from vaccines, and the mRNA platform that developed the so-called vaccines, veterans face a cumulative risk that warrants attention under both TSCA’s regulatory framework and TERA’s toxic exposure assessments.

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2. Lessons from TSCA Applied to mRNA Technology and Vaccine Components

• Synthetic mRNA and Proteins:
  mRNA vaccines instruct cells to produce proteins (e.g., the SARS-CoV-2 spike protein), but these engineered mRNA molecules, when stabilized by lipid nanoparticles, present novel toxicological concerns

  

• Spike Protein Persistence:

  • The spike protein produced by the mRNA platform that develops the so-called “vaccine” can persist in certain tissues longer than anticipated, potentially causing unintended toxic or autoimmune responses.

  • In veterans, the persistence of spike proteins could amplify adverse effects when interacting with pre-existing systemic toxins (e.g., those from burn pits or heavy metals), compounding health risks.

• Spike Proteins as Toxins:
  Some studies have shown that spike proteins could have cytotoxic properties, damaging blood vessels or the immune system—both of which are critical areas of concern under TERA for service members.

  • In February, 2023, a whistleblower within the VA submitted yet another demand for transparency – see Conclusion 6. In part – the conclusion states – “…Given the toxic pathways activated by the spike protein, LNPs, and DNA contamination, there is a strong scientific and ethical basis to consider COVID-19 mRNA injections as a toxic exposure risk activity [TERA]”

    

• N1-Methyl-Pseudouridine (N1-MuP) and Its Role:

  • Definition: N1-Methyl-Pseudouridine is a modified nucleoside that replaces uridine in mRNA vaccines. It stabilizes the mRNA, reduces degradation, and helps avoid excessive immune response, allowing for more efficient protein translation.

  • Novel Substance Under TSCA: As a synthetic modification not naturally occurring in human biology, N1-MuP is a novel substance that falls under TSCA’s purview. Its long-term effects and persistence in tissues are still emerging, raising significant concerns about its toxicological risks.

• Lipid Nanoparticles (LNPs) and TSCA Concerns:

  • LNPs as Delivery Vehicles:
    The mRNA vaccines rely on lipid nanoparticles (LNPs) to encapsulate and deliver mRNA into human cells. LNP formulations often include polyethylene glycol (PEG)-lipid conjugates—substances that have already raised concerns for potential toxicity.

  • TSCA Relevance:
    PEG and other synthetic lipids are industrial chemicals regulated under TSCA. Their inclusion in LNPs creates a hybrid toxicological scenario that combines pharmaceutical and chemical exposure concerns, which are particularly relevant for cumulative risk assessments under both TSCA and TERA.

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3. The VA’s Policy Gap and Legal Precedent

• TSCA’s Cumulative Risk Framework:
  TSCA evaluates the combined effects of synthetic chemicals and their interactions. Veterans are frequently exposed to multiple toxic agents during service, which creates a compounded health burden. By including synthetic vaccine components in the assessment, we can make the case and align with TSCA’s focus on cumulative risk.

• VA’s Oversight of Vaccine Toxicity:
  The VA currently excludes injuries related to vaccines, including so-called mRNA "vaccines," from its TERA evaluations, among other critical concerns. This exclusion disregards the cumulative toxicological burden faced by veterans. By incorporating TSCA principles into the argument, the goal is to demonstrate that the VA’s stance is scientifically flawed and inconsistent with established toxicological practices.

  

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4. Advocacy Strategy Moving Forward

• Highlight Novelty and Persistence of Synthetic Vaccine Components:
  TSCA’s framework is well-suited to address the long-term biological persistence and novel nature of synthetic materials in vaccines, including N1-methyl-pseudouridine and LNPs.

• Focus on Cumulative Exposures:
  Veterans with pre-existing toxic exposures are at an increased risk of compounded health effects from synthetic substances in vaccines. This cumulative burden strengthens the argument for including vaccine-related injuries in TERA evaluations.

• Path Forward:

  • Data-Driven Advocacy:
    Develop compelling narratives using data that highlight the interplay between synthetic vaccine components and pre-existing toxic exposures. This will engage policymakers and VA decision-makers to reconsider their current stance.

  • Align VA Policy with TSCA Principles:
    Advocate for policy changes that incorporate cumulative risk evaluations inspired by TSCA, ensuring veterans receive comprehensive care and recognition for all toxic exposures, including those from vaccines.

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Conclusion: Integrating TSCA, TERA, and National Security Vulnerabilities

As we confront the evolving landscape of modern warfare, the need for transparency and accountability within our military and governmental institutions has never been more pressing. The systemic failure to recognize and address vaccine-related injuries—particularly those resulting from mRNA technology—poses a significant threat to the health of our service members and the overall readiness of our armed forces. Whistleblower advocacy has been critical in bringing these issues to light, but the true urgency lies in integrating established regulatory frameworks like the Toxic Substances Control Act (TSCA) and the Toxic Exposure Risk Activity (TERA) provisions of the PACT Act into our defense strategy.

TSCA's focus on cumulative chemical risk assessment and its regulatory oversight of synthetic substances provides a critical lens through which we can evaluate the toxicological risks of mRNA “vaccines”, lipid nanoparticles, and other synthetic components. The TERA provisions within the PACT Act further strengthen the case for recognizing these novel exposures as toxic risks that must be addressed—especially for veterans who are already burdened by pre-existing exposures such as burn pits, heavy metals, and PFAS.

The failure to incorporate TSCA’s cumulative risk assessment framework and TERA’s toxic exposure evaluation into the Department of Veterans Affairs’ (VA) policies creates a dangerous gap in how we assess and respond to the health impacts on our service members.

The Department of Defense’s reluctance to acknowledge the compounded risk posed by synthetic vaccine components, coupled with its failure to adapt policies that account for the long-term biological persistence of these substances, leaves our military vulnerable. The cumulative health burden faced by veterans, who are often exposed to multiple toxic agents during service, should be a central concern of any policy related to their medical care and readiness. By leveraging TSCA’s regulatory framework and the PACT Act’s TERA provisions, we can build a compelling case for a reevaluation of the VA’s stance, ensuring that veterans are not only recognized for the risks they face but also afforded the care and support they deserve.

In addition to the scientific and regulatory challenges, the misinformation surrounding the risks of COVID-19 so-called vaccines and the mRNA technology only further exacerbates the vulnerabilities of our military personnel. The DOD's complicity in the ongoing denial of these risks not only undermines service members' health but also compromises our national defense posture. Adversaries, skilled in exploiting weaknesses and manipulating information, could easily capitalize on our vulnerabilities, threatening both military readiness and national security.

This brings us to a critical juncture: was the Department of Defense complicit in mandating a toxic exposure through the COVID-19 “vaccines”? What are the far-reaching implications of these policies on our readiness and national security? The failure to address mRNA “vaccines” and synthetic components as part of a broader toxic exposure risk is a serious oversight that must be corrected.

By integrating TSCA’s cumulative risk framework and TERA’s toxic exposure assessments, we can demand a shift in policy that acknowledges the full scope of toxic risks facing our service members and veterans. Transparency, accountability, and evidence-based decision-making must guide our response to these challenges. As we navigate the complexities of modern conflict and evolving warfare strategies, it is essential that we ensure our military remains resilient, ready, and able to defend against both external threats and the internal vulnerabilities created by systemic failures.

In conclusion, we must confront the question: How can we safeguard the health of our military personnel and our nation’s future if we fail to recognize and address these hidden toxic threats? By holding the Department of Defense and the VA accountable, integrating TSCA and TERA principles into policy, and prioritizing the health of our service members, we can build a stronger, more resilient defense posture. This is not just about the health of our veterans; it's about the security of our nation and the readiness of our Armed Forces to confront the threats of tomorrow.

BLUF (Bottom Line Up Front):
To restate the issues: At the core of the issue with TERA (Toxic Exposure Risk Activity) is the need to revoke the VA’s fraudulent Standard Operating Procedure (SOP) policy that unjustly excludes vaccine-related injuries, including those from mRNA platforms, from risk exposure assessments. This policy serves as an administrative maneuver designed to suppress the acknowledgment of real risks to our troops. The solution is not expanding TERA provisions but eliminating this flawed SOP, which prevents the law from functioning as intended.

It’s essential not to be sidetracked by legal jargon or “tobacco science” when considering the implications of the Toxic Substances Control Act (TSCA). While TSCA is crucial in regulating chemical exposures, it should not be conflated with the deliberate exclusion of vaccine injuries under TERA. TSCA’s focus on cumulative risks and chemical toxicity offers a compelling framework to argue that vaccine-related injuries should be included under TERA, challenging the VA’s resistance and advocating for a more honest, protective approach for our veterans.

The issue is clear: it’s not the expansion of TERA that’s needed, but the removal of the fraudulent SOP that unjustly excludes vaccine-related injuries from consideration. This policy is a clear administrative failure. The VA’s presumption of toxic exposure risk for veterans, even those who merely fly over areas like Southwest Asia, demonstrates the egregious nature of this oversight.

While it’s critical to differentiate between definitively labeling something as a toxin (such as a gene therapy injection) and acknowledging the potential risk of toxic exposure, the law should allow veterans to seek medical opinions for unexplained disabilities potentially linked to such risks, including those from vaccines. The real barrier to fair recognition of these risks is the fraudulent SOP, not the lack of expanded TERA provisions. By revoking this SOP, the VA can align with the original intent of TERA, ensuring that all veterans impacted by toxic exposures, including vaccine injuries, are properly recognized and cared for.

The key action is clear: revoke the VA's policy that unjustly excludes vaccines from TERA risk exposure assessments, ensuring vaccine injuries are treated like any other toxic exposure.

In sum, the VA’s stance suggests that “facts and circumstances” conveniently don’t apply when it comes to “vaccines,” effectively positioning them as the only toxic risk activity exempt from TERA screening. This glaring legal inconsistency undermines the law’s core intent, and correcting it is imperative to ensure that those who served receive the recognition and care they deserve.

Clarification on Terminology and Legal Implications in the Context of VA and DoD Actions

It’s important to note that the COVID-19 mRNA "vaccine," while often referred to as such, does not meet the traditional definition of a vaccine. Vaccines are generally designed to prevent infection or disease transmission, but the mRNA treatment primarily functions as a therapeutic aimed at managing symptoms, not preventing infection or the spread of the virus.

This distinction is critical, particularly when evaluating the regulatory landscape under TSCA and TERA. If the mRNA treatments are categorized inaccurately as vaccines, rather than therapeutics, it complicates the application of legal frameworks designed to assess and mitigate the cumulative risks of toxic exposures. Under TSCA, the classification of a substance is pivotal in determining its regulatory oversight, and under TERA, the risks associated with exposure to these substances in the context of military service must be transparently evaluated.

The misclassification of these mRNA treatments raises concerns about informed consent, medical autonomy, and the ethical use of government power. Veterans and service members may be unknowingly coerced into receiving a symptom-managing treatment rather than a preventive vaccine, compromising their ability to make informed decisions regarding their health. From a legal perspective, mandating a treatment under the guise of a vaccine—without proper classification and informed consent—may violate both constitutional rights and regulatory standards outlined in frameworks such as TSCA and TERA.

This misclassification has profound legal and ethical implications. The government’s use of power to mandate a treatment misrepresented as a vaccine brings into question the legitimacy of such mandates. Given the regulatory frameworks of TSCA and TERA, the failure to accurately categorize and assess these treatments as therapeutics could exacerbate existing vulnerabilities in military health policy. The actions of the VA and DoD must ensure clarity and transparency in how such treatments are classified, particularly when considering the cumulative risks that arise from repeated or mandated exposure to potentially toxic substances.

Addressing this issue—accurately classifying mRNA products and recognizing their implications under TSCA and TERA—is essential to ensuring that any mandates imposed on veterans or service members are legally sound, ethically justified, and aligned with both health autonomy and regulatory principles.

Thank you for taking the time to read this important discussion. For more insights on veterans' rights, toxic exposure, and the ongoing efforts to address vaccine-related injuries, follow me for updates and advocacy. I encourage you to share this with others who may benefit from this critical information. Together, we can continue to raise awareness and drive meaningful change.

Dr. Crisanna Shackelford
As a leading voice in advocating for veterans' rights and addressing toxic exposure issues, I am committed to highlighting the systemic challenges veterans face.
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