Humane Society Veterinary Medical Association's Letter of Support for "Molly's Bill," AB 2000 California Rabies Medical Exemption
June 16, 2010
Senator Elaine Alquist, Chairperson
CA State Senate Health Committee
State Capitol Building, Room 2191
Sacramento, CA 95814
FAX: (916) 324‐0384
RE: Follow‐up Veterinary Support Letter for AB 2000 (Medical Exemption from Rabies Vaccination), including Response to California Department of Public Health (CDPH) Objections
Dear Senator Alquist and Committee Members:
I am writing on behalf of the Humane Society Veterinary Medical Association (HSVMA), an organization representing approximately 2,000 veterinary professionals nationwide with a focus on the health and welfare of all animals, including companion dogs and cats, to reiterate our support for AB 2000 and to counter objections voiced in the California Department of Public Health’s opposition letter, dated June 8. (Our original letter, dated May 7, in support of the bill, is attached for your reference.)
The CDPH statement that “there is no scientific evidence that rabies vaccines are associated with severe or a high rate of vaccination reactions,” is simply incorrect. The USDA Center for Veterinary Biologics (CVB) reports that rabies vaccines are the most common group of biological products named in the adverse event reports they receive. Adverse vaccine‐associated reactions are not required to be reported in veterinary medicine. Even in the face of what is probably gross underreporting, the USDA/CVB Report, published in the April 1, 2008 issue of the Journal of the American Medical Association (pages 1000‐1002), states that from April 2004 through March 2007 nearly 10,000 adverse event reports were received by rabies vaccine manufacturers, and that about 65% of these concerned dogs. The overall rate of such adverse rabies vaccine reactions during the report period was 8.3 reports/100,000 doses of vaccine. These are by no means trivial findings nor is the magnitude of the numbers insignificant. Although canine rabies vaccine labels may not enumerate contraindications, the labeling instructions on vaccine products clearly instruct veterinarians to vaccinate only healthy dogs. A small number of companion animals have medical conditions for which vaccination is life‐ or health‐threatening and thus, inappropriate. In these cases, a dog’s particular exemption from rabies vaccination would be individually substantiated by a veterinarian, and under these stringent circumstances, we do not foresee the submission of illegitimate or frivolous requests.
Veterinarians are well trained in immunology and develop a great respect for both the powerful positive and potential negative consequence of vaccinating their patients. Veterinary schools require detailed study of those zoonotic diseases, like rabies, that are transmissible from animals to humans. State and national veterinary board exams rigorously test this understanding. Veterinary schools and professional advisory bodies regularly update vaccination protocols as new findings emerge. Vaccinology is one of the most active areas of research and discussion in the professional literature, at continuing education venues, and among clinicians around the country and throughout the world.
The Veterinarian’s Oath states, “I solemnly swear to use my scientific knowledge and skills for the benefit of society through the protection of animal health, the relief of animal suffering… (and) the promotion of public health…” As veterinarians we continuously safeguard the public health by protecting the health and welfare of our patients within the context of their families and our communities. Disallowing veterinary medical exemption from rabies vaccination impugns this professional commitment and puts the public at greater potential risk by those who, concerned
about their dogs’ health and deprived of a vaccination exemption option, may choose to fly ‘under the radar,’ eluding both licensing and vaccination entirely.
A number of states, including Alabama, Florida, Colorado, Connecticut, Maine, Massachusetts, New Jersey, New York, Virginia and Wisconsin, successfully provide medical exemption from rabies vaccination without quarantine provisions. Once again, we encourage your support of this important state legislation, similarly safeguarding the health and welfare of the companion canines of Californians.
Please contact me if you have any questions or if you would like more details about our perspective on these issues. Thank you for your consideration.
Barbara Hodges, DVM, MBA
Humane Society Veterinary Medical Association (HSVMA)