This is your chance to get a rabies medical exemption bill passed in New Mexico! I urge all New Mexico residents to contact the two Representatives above to voice support for HB 341. If you can, please attend Friday's hearing. This bill faces stiff opposition from the Department of Health, the NM Veterinary Medical Association, and the NM Livestock Board -- it is up to the public to get this bill passed, and it will if you take a couple of minutes to call or e-mail Representative Dodge and Representative Madalena. Please ask your friends in New Mexico to do the same.
Below is a copy of my letter on behalf of The Rabies Challenge Fund in support of HB 341.
PERMISSION GRANTED TO CROSS-POST
February 18, 2011
Representative George Dodge, Jr. Representative James Roger Madalena, Chair
House of Representatives Agriculture & Water Resources Committee
Room 203 CAN, State Capitol Room 314 A, State Capitol
Santa Fe, NM 87501 Santa Fe, NM 87501
RE: HB 341 Exemption from the Requirement for Rabies Vaccination
Greetings Representatives Dodge and Madalena:
The Rabies Challenge Fund Charitable Trust fully supports the rabies medical exemption language contained in HB 341 and strongly urges the Agriculture & Water Resources Committee to vote that this important legislation “ought to pass.”
The Centers for Disease Control’s National Association of State Public Health Veterinarians[1], the American Animal Hospital Association[2] (AAHA), the American Veterinary Medical Association[3], and the American Association of Feline Practitioners[4] all recommend that rabies vaccines be administered in accordance with the manufacturer’s labeled directions, which clearly specify their use in “healthy” animals. This explicit specification counters the New Mexico Livestock Board’s (NMLB) contention, expressed in the Fiscal Impact Report, that there are no known contraindications for the rabies vaccine – rather, the vaccine manufacturers’ labels specifically instruct veterinarians to limit their products’ use to the healthy population of the animal species. Furthermore, the Pfizer Defensor 3 rabies label warns that “
protective immune response may not be elicited if animals are incubating an infectious disease, are malnourished or parasitized, are stressed due to shipment or environmental conditions, are otherwise immunocompromised.”
In concurrence with rabies vaccine manufacturers’ precisely labeled directions that they are for “healthy” animals, the American Association of Feline Practitioners advises that “
ats with acute illness, debilitation, or high fevers should not be vaccinated.”[5] A Certificate of Exemption from Rabies Vaccination in Appendix 1 of their Vaccine Advisory Panel Report is published for veterinarians to use as a model for exempting sick animals.
Passage of this bill would give veterinarians the option, not the mandate, to write waivers for the small number of sick pets diagnosed as being too ill to be vaccinated and for whom vaccination may not elicit a proper immune response. It would also enable responsible pet owners with ill animals to comply with New Mexico’s rabies laws instead of being forced to jeopardize their pet’s health with a mandated vaccination or to break the law to avoid a medically unsound immunization.
Several concerns have been raised in the Significant Issues section of HB 341’s Fiscal Impact Report which need to be addressed. The NMLVB stated that the rabies vaccine “is considered worldwide to be among the safest…vaccines” -- this statement is false. A special report published in 2008 in the Journal of the American Veterinary Medical Association announced that the "[r]abies vaccines are the most common group of biological products identified in adverse event reports received by the CVB [Center for Veterinary Biologics]." 
Immunologically, the rabies vaccine is the most potent of the veterinary vaccines and associated with significant adverse reactions such as polyneuropathy “resulting in muscular atrophy, inhibition or interruption of neuronal control of tissue and organ function, incoordination, and weakness,” [7] auto-immune hemolytic anemia,
autoimmune diseases affecting the thyroid, joints, blood, eyes, skin, kidney, liver, bowel and central nervous system; anaphylactic shock; aggression; seizures; epilepsy; and fibrosarcomas at injection sites.[9] [10]
A “killed” vaccine, the rabies vaccine contains adjuvants to enhance the immunological response. In 1999, the World Health Organization “classified veterinary vaccine adjuvants as Class III/IV carcinogens with Class IV being the highest risk,"[11] and the results of a study published in the August 2003 Journal of Veterinary Medicine documenting fibrosarcomas at the presumed injection sites of rabies vaccines stated, “In both dogs and cats, the development of necrotizing panniculitis at sites of rabies vaccine administration was first observed by Hendrick & Dunagan (1992).” [12] According to the 2003 AAHA Guidelines, "...killed vaccines are much more likely to cause hypersensitivity reactions (e.g., immune-mediated disease)."[13]
The NMLVB stated that “this bill could result in a large number of exemption requests” that could weaken the current level of rabies control. In the 13 states with rabies medical exemptions (Alabama, Colorado, Connecticut, Florida, Maine, Massachusetts, New Hampshire, New Jersey, New York, Oregon, Vermont, Virginia, and Wisconsin), this has not been the case. In the more than 5 years since Maine’s medical exemption for dogs went into effect, not one rabid dog has been reported in the state. Colorado’s data reflect the same – there have been no rabid dogs reported since passage of their medical exemption in July 2008.
The Department of Health (DOH) expressed concern that passage of this bill would create an“area of low rabies vaccine coverage in dogs and cats,” however, the World Small Animal Veterinary Association’s 2010 Vaccine Guidelines estimates that in “developed” nations such as the U.S., 50%-70% of the pet animal population is unvaccinated. This large estimated percentage of domestic animals in non-compliance with rabies vaccination requirements is what creates the“area of low rabies vaccine coverage in dogs and cats,” not the minimal number of sick pets whose medical conditions should exempt them from the requirement.
Potential overuse or misuse of exemptions was also raised by the DOH, yet passage of this bill would give veterinarians the option, not the mandate, to issue waivers based on their assessment of an animal’s medical condition.
The Results of the Statewide Survey of New Mexico Veterinarians on rabies waivers conducted by the state indicated that a 55% majority of veterinarians were not opposed to medical exemptions.
In addition to HB 341, medical exemption bills are currently pending in the states of California and Pennsylvania.
On behalf of The Rabies Challenge Fund Charitable Trust, I again express our full support of HB 341 and urge the Agriculture & Resources Committee to vote that it “ought to pass.”
Sincerely,
cc: Dr. W. Jean Dodds
Dr. Ronald Schultz
Representative James Roger Madalena
Senator Steve Fischmann
Representative Richard C. Martinez
Representative Gail Chasey
New Mexico Legislature
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[1] CDC's National Association of State Public Health Veterinarian's 2008 Compendium of Animal Rabies Prevention and Control
[2] American Animal Hospital Association Canine Vaccine Task Force. 2003 Canine Vaccine Guidelines, Recommendations, and Supporting Literature, and ibid. 2006 AAHA Canine Vaccine Guidelines, Revised,
[3] American Veterinary Medical Association 2007 RABIES VACCINATION PROCEDURES
[4] American Association of Feline Practitioners, Vaccine Advisory Panel Report, Journal of the American Veterinary Medical Association Vol. 229, No. 9 Nov. 1, 2006
[5] American Association of Feline Practitioners, Vaccine Advisory Panel Report, Journal of the American Veterinary Medical Association Vol. 229, No. 9 Nov. 1, 2006 p. 1412
Frana, T.S. et als, Postmarketing Surveillance of Rabies Vaccines for Dogs to Evaluate Safety and Efficacy, Journal of the American Veterinary Medical Association Vol. 232, No. 7 April 1, 2008
[7] Dodds, W. Jean Vaccination Protocols for Dogs Predisposed to Vaccine Reactions, The Journal of the American Animal Hospital Association, May/June 2001, Vol. 37, pp. 211-214
Duval D., Giger U.Vaccine-Associated Immune-Mediated Hemolytic Anemia in the Dog, Journal of Veterinary Internal Medicine 1996; 10:290-295
[9] American Veterinary Medical Association (AVMA) Executive Board, April 2001, Principles of Vaccination, Journal of the American Veterinary Medical Association, Volume 219, No. 5, September 1, 2001.
[10] Vascelleri, M. Fibrosarcomas at Presumed Sites of Injection in Dogs: Characteristics and Comparison with Non-vaccination Site Fibrosarcomas and Feline Post-vaccinal Fibrosarcomas; Journal of Veterinary Medicine, Series A August 2003, vol. 50, no. 6, pp. 286-291.
[11] IARC Monographs on the Evaluation of Carcinogenic Risks to Humans: Volume 74, World Health Organization, International Agency for Research on Cancer, Feb. 23-Mar. 2, 1999, p. 24, 305, 310.
[12] Vascelleri, M. Fibrosarcomas at Presumed Sites of Injection in Dogs: Characteristics and Comparison with Non-vaccination Site Fibrosarcomas and Feline Post-vaccinal Fibrosarcomas; Journal of Veterinary Medicine, Series A August 2003, vol. 50, no. 6, pp. 286-291.
[13] American Animal Hospital Association Canine Vaccine Task Force. 2003 Canine Vaccine Guidelines, Recommendations, and Supporting Literature, 28pp. and ibid. 2006 AAHA Canine Vaccine Guidelines, Revised, 28 pp.