PENNSYLVANIA Action Alert– Rabies Medical Exemption SB 1454 Regular Session 2009-2010 Senate Bill 1454 P.N. 2164  just introduced by Senator Stewart Greenleaf has been referred to the Agriculture & Rural Affairs Committee. Please contact Committee members and ask them to vote "Do Pass." At the bottom of the page is my letter to the Pennsyvlania State Veterinarian.

Senator Mike Brubaker, Chair (717) 787-4420 mbrubaker@pasen.gov
Senator Michael Waugh, Vice-Chair (717) 787-3817 mwaugh@pasen.gov
Senator Michael O’Pake, Minority Chair (717) 787-8925 opake@pasenate.com
Senator Joseph Scarnati (717) 787-7084 jscarnati@pasen.gov
Senator John Eichelberger (717) 787-5490 jeichelberger@pasen.gov
Senator Robert Robbins (717) 787-1322
Senator Elder Vogel (717) 787-3076 evogel@pasen.gov
Senator Gene Yaw (717) 787-3280 gyaw@pasen.gov
Senator Andrew Dinniman (717) 787-5709 andy@pasenate.com
Senator Shirley Kitchen (717) 787-6735 kitchen@pasenate.com
Senator John Wozniak (717) 787-5400 wozniak@pasenate.com

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June 29, 2010

Dr. Craig E. Shultz
State Veterinarian
Department of Agriculture
2301 N. Cameron Street, Room 410
Harrisburg, PA 17110

RE: Medical Exemption Clause for Pennsylvania’s Rabies Prevention and Control Code

Greetings Dr. Shultz:

On behalf of The Rabies Challenge Fund and the Pennsylvania pet owners who have contacted us requesting assistance, we respectfully request that you, in your capacity as State Veterinarian, initiate medical exemption legislation waiving the rabies immunization requirement in Chapter 16, Subchapter C., §16.43 of the Pennsylvania Code for the small number of animals whose veterinarians have determined their medical conditions preclude vaccination.

The states of Alabama, Colorado, Connecticut, Florida, Maine, Massachusetts, New Hampshire, New Jersey, New York, Oregon, Vermont, Virginia, and Wisconsin all have medical exemption clauses for sick animals in their rabies immunization laws, and a bill is currently pending in the California legislature to include a waiver in their statutes.

The labels on rabies vaccines state that they are for “the vaccination of healthy cats, dogs…,” and there are medical conditions for which vaccination can jeopardize the life or well-being of an animal. A medical exemption clause would allow Pennsylvania veterinarians to write waivers for animals whose medical conditions (such as those with cancer, kidney/liver failure, hemolytic anemia, thrombocytopenia, grand mal seizures, and chronic autoimmune disorders) would be exacerbated by rabies vaccination. The State of Maine inserted such an exemption into their 3 year rabies protocol, 7 M.R.S.A., Sec. 3922(3), which became effective in April 2005 — not one rabid dog has been reported in the more than 5 years since that date. Colorado’s data reflect the same — there have been no rabid dogs reported in the state since passage of their medical exemption clause in July 2008.

Maine’s exemption language is as follows:

A. A letter of exemption from vaccination may be submitted for licensure, if a medical reason exists that precludes the vaccination of the dog. Qualifying letters must be in the form of a written statement, signed by a licensed veterinarian, that includes a description of the dog, and the medical reason that precludes vaccination. If the medical reason is temporary, the letter shall indicate a time of expiration of the exemption.

B. A dog exempted under the provisions of paragraph 5 A, above, shall be considered unvaccinated, for the purposes of 10-144 C.M.R. Ch.251, Section 7(B)(1), (Rules Governing Rabies Management) in the case of said dog’s exposure to a confirmed or suspect rabid animal.

The Rabies Challenge Fund strongly urges you to request legislation be submitted on behalf of the Department of Agriculture amending Chapter 16, Subchapter C., §16.43 of the Pennsylvania Code to include medical exemption language for unhealthy animals for which rabies vaccination would compromise their well-being.

Sincerely,

Kris L. Christine
Founder, Co-Trustee
THE RABIES CHALLENGE FUND
Duration of Immunity Study for Rabies Vaccine – Rabies Challenge Fund
ledgespring@lincoln.midcoast.com

cc: Dr. W. Jean Dodds
Dr. Ronald Schultz
Pennsylvania General Assembly