As we have long feared, and as has already happened in other countries, COVID-19 vaccination requirements are being used to impose unrelated ID requirements.

There’s a difference between “unvaccinated” and “undocumented” — a difference that’s  gotten lost in some recent regulations and orders imposing “vaccination mandates”.

Case in point: the San Francisco Department of Public Health.

An order from the SFDPH  purports to require people entering indoor businesses or other indoor venues including anywhere food or beverages are served, gyms, and other “large indoor events”  to show “proof” of having been fully vaccinated against COVID-19.

But proof of vaccination is not what the order actually mandates. Its only real mandate is a an ID mandate, and in practice its effects would be felt primarily by undocumented people (including vaccinated but undocumented people) who don’t have or don’t choose to show ID, not by unvaccinated people.

Regardless of whether you’ve been vaccinated or whether you think other people should be vaccinated, the ID mandate hidden in this order, like similar ID mandates lurking in other “vaccination” regulations and directives, is a step backward for civil liberties. It is vulnerable to, and deserving of, Constitutional challenge.

Here’s what the SFDPH order would actually require:

The SFDPH order defines several acceptable forms of “proof” of vaccination including, among others, a paper vaccination card printed in blank by the Centers for Disease Control (CDC) and filled in by hand at a vaccination site, a photocopy of such a card, an image of such a card displayed on a smartphone, a QR code displayed on a smartphone, or “a written self-attestation of vaccination signed… under penalty of perjury.”

None of these, with the possible exception of a declaration under penalty of perjury, provides more than the flimsiest evidence that someone (not necessary the person presenting the card or paper copy or showing the image or QR code) was vaccinated. None of them provides “proof”.

Anyone could write anything on a blank CDC card, photocopy such a card, copy an image or QR code, create a QR code, borrow a smartphone on which an image or QR code is already stored, or edit such an image to fill in the blanks or change the name or other information.

The most secure of these forms of evidence, at least in terms of the risk taken by someone using it to support a false claim to have been vaccinated, would appear to be a self-certification under penalty of perjury. It’s not clear what law would be violated by changing the name in an image of a vaccination card. And whatever might be said — in seriousness or in jest — about the possible penalties for misuse of Photoshop, the penalties for perjury are probably quite a bit more serious than those for altering an image of a vaccination card.

But while the SFDPH order defines a self-certification as “proof” of having been vaccinated, Appendix B to the order defines a variety of venues and events for which a self-certification of having been vaccinated will not be accepted, but other trivially produced forms of evidence of having been vaccinated will be accepted.

There are other inexplicable quirks in which forms of evidence of vaccination are and aren’t acceptable under the SFDPH order.

The most “official” and widely-recognized record of vaccination is the International Certificate of Vaccination or Prophylaxis (“yellow book”), a longstanding global standard adopted by the World Health Organization (WHO) pursuant to international treaties. These can be used to record vaccinations against COVID-19, and in some countries including Germany they are the primary vaccination records being issued to individuals. In the US, WHO-standard blank “yellow books”  are issued by the CDC and distributed to health care providers and the public by the US Government Printing Office.

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