Throughout the 19th century, much of the legislation and oversight of vaccinations fell to the states and local jurisdictions. This included production and distribution of vaccines, enforcement (including penal outcomes) of regulation, and final adjudication of any disputes (Gostin, 2008). In 1902, however the U.S. Congress passed the “Biologics Control Act” (BCA) which set the standards for the first legislation of drugs. This meant that guidance on the production, distribution, and research on vaccines came from the federal level. From 1870-1905, conflict between state health organizations and the anti-vaccine groups picked up. Prior to this, while there was still objection to compulsory vaccination, lower disease incidence meant that