LETTER FROM THE RABIES CHALLENGE FUND January 28, 2018   Representative Tom McCall, Chairman                Representative Matt Gurtler, Sponsor House Agriculture & Consumer Affairs Com.     House Agriculture & Consumer Affairs Com. 228 State Capitol                                                     504-D Coverdell Legislative Office Building Atlanta, GA  30334                                                 Atlanta, GA  30334 Fax:  (404) 656-6897 e-mail:  tom.mccall@house.ga.gov                            e-mail:  matt.gurtler@house.ga.gov   RE:     Georgia Rabies Medical Exemption Bill HB742   Greetings Representatives McCall and Gurtler:               The Rabies Challenge Fund strongly supports and endorses passage of Ruby’s Law, HB742, which would create a medical exemption option for Georgia’s animals determined by a licensed veterinarian to be too ill to be vaccinated against rabies.               The 18 states of Alabama, California, Colorado, Connecticut, Florida, Illinois, Maine, Massachusetts, Maryland, New Hampshire, New Jersey, Nevada, New York, Oregon, Pennsylvania, Vermont, Virginia, and Wisconsin have medical exemption clauses in their rabies laws, and the veterinary medical associations setting the national standard of professional veterinary care have officially recognized the need for rabies immunization exemptions in medically warranted cases.               Posted on the American Veterinary Medical Association’s (AVMA) website is the following policy statement on rabies medical exemptions: “…[the] AVMA recognizes some animals might require a waiver from rabies vaccination because the vaccination poses an unacceptably high risk to the health of the individual animal….[and] recommends that such animals be granted a waiver from mandatory rabies vaccination, upon recommendation of a licensed veterinarian.”[1]               In addition, the National Association of State Public Health Veterinarians (NASPH) asserts in their Compendium of Animal Rabies Prevention and Control 2016 that:  “…ill animals may not have a full immunologic response to vaccination.”[2]               The American Animal Hospital Association (AAHA) cautioned in their Canine Vaccine Guidelines that:  "It is reasonable to avoid administration of any vaccine to patients with a history of systemic disease suspected to be associated with previous vaccination (e.g., immune- mediated hemolytic anemia, immune-mediated thrombocytopenia) or known to be caused by vaccine (vaccination-site cutaneous ischemic vasculitis after administration of rabies vaccine),”[3] and that “…veterinary medicine has advised against vaccination during illness, due to concerns about suboptimal protection, or worse, vaccine- induced illness.”[4]  They further advise veterinarians "...to avoid administration of any vaccine to patients with a history of systemic disease suspected to be associated with previous vaccination (e.g., immune-mediated hemolytic anemia, immune-mediated thrombocytopenia) or known to be caused by vaccine (vaccination-site cutaneous ischemic vasculitis after administration of rabies vaccine),” [5] and that “[d]ogs receiving immunosuppressive chemotherapy should not be vaccinated.” [6]               Rabies vaccine labels affirm that they are for “the vaccination of healthy cats, [and] dogs.” Zoetis Defensor 1 and Defensor 3 rabies vaccine labels warn that: "[a] 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…."[7]  Passage of HB742 would enable Georgia’s veterinarians to write medical exemptions for animals whose lives would be jeopardized by or whose medical conditions would be exacerbated by rabies vaccination, including those with past anaphylactic reactions to the vaccine or those suffering from cancer, kidney/liver failure, hemolytic anemia, thrombocytopenia, lymphoma, grand mal seizures, and chronic autoimmune disorders.               Without a provision for medical exemptions in Chapter 19, Title 31, Section 2 of the Official Code of Georgia, the state’s rabies immunization requirement poses an ethical dilemma for veterinarians with seriously ill patients.  They must either violate their Veterinarian’s Oath by administering a rabies vaccine contrary to the manufacturer’s labeled instructions and contrary to the principles of sound medical care established by the national veterinary medical associations noted above, or recommend that clients not comply with the law to vaccinate their sick animals.  Veterinarians also face potential liability for adverse reactions suffered when immunizing against rabies in a manner inconsistent with the vaccine’s labeled instructions.  Pet owners may choose not to comply with the law rather than risk pets’ lives and subsequently fail to license them to avoid detection.               The Rabies Challenge Fund urges you to pass HB742, Ruby’s Law, to include a medical exemption clause in Georgia’s rabies law.   Please contact us if you have any questions.   Sincerely,     Kris L. Christine                                                                   Founder,Co-Trustee W. Jean Dodds, DVM, Co-Trustee                                                     THE RABIES CHALLENGE FUND         www.RabiesChallengeFund.org                                                                                   cc:        Maureen Harper             HB742 Sponsors House Agriculture & Consumer Affairs Committee   [1] American Veterinary Medical Association (AVMA) Annual Rabies Vaccination Waiver.  Retrieved from https://www.avma.org/KB/Policies/Pages/Annual-Rabies- Vaccination-Waiver.aspx [2] National Association of State Public Health Veterinarians (NASPHV) Brown, C., et al., Journal of the American Veterinary Medical Association (JAMA) 2016, March 1.  Compendium of Animal Rabies Prevention and Control, 2016.  Retrieved from http://www.nasphv.org/Documents/NASPHVRabiesCompen dium.pdf [3] American Animal Hospital Association (AAHA) Canine Vaccination Task Force:  Welborn, L.V. et al., 2011 AAHA Canine Vaccination Guidelines p. 21 [4] AAHA 2011 Vaccine Guidelines p. 28 [5] AAHA 2011 Vaccine Guidelines p. 21 [6] AAHA 2011 Vaccine Guidelines p. 29 [7] Zoetis Defensor 1 and Defensor 3 rabies vaccine labels.  Retrieved from https://www.zoetisus.com/products/dogs/defensor1.aspx and https://www.zoetisus.com/products/dogs/defensor3.aspx June 29, 2015 The first trial in the final challenge phase of The Rabies Challenge Fund research has been completed.  The data yielded mixed results, which are not applicable to our goals of determining the long-term duration of immunity of the rabies vaccine in dogs and establishing a canine rabies titer.   Our challenge was conducted in a USDA-approved facility by a group of research scientists using the USDA Title 9 standard for rabies vaccine licensing, upon which The National Association of State Public Health Veterinarian’s Rabies Compendium and state laws are based.  That standard requires that 80% of the control dogs test positive for rabies disease.  Only one (10%) of the 5 control dogs tested positive for disease, while another tested positive for infection.  None of the ten vaccinates tested positive for rabies disease or infection.   These results show that the challenge virus used by the investigators in this first trial was not virulent enough to cause disease in 80% of the control dogs.   It is our intention to conduct another challenge using a new highly virulent challenge virus from the USDA, which has been successfully used in recent canine rabies trials.   www.RabiesChallengeFund.org