# Notice: NEW MEXICO Dog Owners



## Kris L. Christine (Mar 25, 2009)

*NEW MEXICO: Rabies Medical Exemption Action Alert* -- New Mexico pet owners have launched an effort to get a rabies medical exemption clause inserted into the Rabies Code. Below is a copy of the letter I have faxed to the New Mexico State Veterinarian and below that is a copy of New Mexico resident Chryssa Charalambides's letter.

*What You Can Do to Help*

Contact your legislator and ask them to file a rabies medical exemption bill on your behalf. You can find your legislators' contact information at this link http://www.nmlegis.gov/lcs/legislatorsearch.aspx , and please ask everyone you know who may concerned about this issue to do the same. E-mails for the entire New Mexico Legislature are listed at the bottom of this message.

*PERMISSION IS GRANTED TO CROSS-POST*

July 23, 2010

Dr. Dave E. Fly, State Veterinarian
New Mexico Livestock Board
300 San Mateo NE
Albuquerque, NM 87109

*RE:  Rabies Medical Exemption for New Mexico Code Title 7 Chapter 4 Part 2 §7.4.2.8*

Greetings Dr. Fly: 

 New Mexico’s Code requiring rabies vaccinations for dogs and cats, Title 7 Chapter 4 Part 2 §7.4.2.8, does not contain a provision to exempt unhealthy animals whose veterinarians have determined their medical conditions should 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 laws, and a bill is currently pending in the California legislature to include a waiver in its 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. Passage of a medical exemption clause would allow New Mexico’s veterinarians to write waivers for animals -- such as those who have had anaphylactic reactions to vaccination, or suffer from cancer, kidney/liver failure, hemolytic anemia, thrombocytopenia, grand mal seizures, and chronic autoimmune disorders -- whose medical conditions would be exacerbated by rabies vaccination. 

 The State of Maine inserted the following medical exemption into their 3 year rabies protocol, 7 M.R.S.A., Sec. 3922(3), which became effective in April 2005:

_ “5 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.”_

 In the more than 5 years since Maine’s medical exemption 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 in the state since passage of their medical exemption in July 2008. 

 Without a provision for medical exemptions in Title 7 Chapter 4 Part 2 §7.4.2.8, New Mexico’s rabies immunization code thrusts an ethical quandary on veterinarians with seriously ill patients -- they must either violate their Veterinarian’s Oath and administer a rabies vaccine contrary to sound medical practice and against the vaccine manufacturer’s labeled instructions, or recommend their clients break the law by not immunizing their unhealthy pets against rabies. Being compelled by law to vaccinate sick dogs and cats against rabies in order for their clients to comply with the code also puts New Mexico’s veterinarians at risk of being held liable for any adverse reactions the animals may suffer after administering a vaccine inconsistently with the labeled directions. Owners of critically ill dogs may choose not to comply with the law rather than jeopardize the lives of their pets and then fail to license their dogs to avoid detection.

 On behalf of The Rabies Challenge Fund Charitable Trust and the New Mexico pet owners who have contacted us for assistance, we urge you to initiate legislation to insert a medical exemption clause in Title 7 Chapter 4 Part 2 §7.4.2.8 of the state code. You may contact me at the number below if you would like any scientific data on the rabies vaccine or if you have any questions.

Sincerely,

Kris L. Christine
Founder, Co-Trustee
THE RABIES CHALLENGE FUND
www.RabiesChallengeFund.org 
ledgespr[email protected]

cc: Dr. W. Jean Dodds
Dr. Ronald Schultz
New Mexico Legislature
Dr. Tamara Spooner – Executive Director, New Mexico Veterinary Medical Association


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## Kris L. Christine (Mar 25, 2009)

*Letter from Chryssa Charalambides*

Mark Boitano Representative Gail Chasey
3615 Horacio Court NE 1206 Las Lomas Road NE
Albuquerque, NM 87111 Albuquerque, NM 87106

Dear Senator Boitano and Representative Chasey, 
Legislation is needed to provide an exemption from rabies vaccination for pets with existing medical conditions.

My Great Dane, Dalia, has been diagnosed with two autoimmune conditions within the last year and half, vaccine induced Immune Mediated Polyarthritis, diagnosed on 01/11/2009, and Addison’s disease, diagnosed on 11/04/2009. Her veterinarian, Dr. Jennifer Strasser, ACVIM of Veterinary Specialists of NM at the Albuquerque Emergency Clinic, feels strongly that further rabies vaccinations would pose serious risk to her health. I have a letter from Dr. Strasser to that effect. 

Dog and cat owners in other states with animals suffering from similar autoimmune conditions can have their veterinarian fill out an annual exemption form. The form protects the animal’s life by legally exempting it from rabies vaccination upon the examination of a veterinarian. 

The vaccine manufacturers as well as the USDA state the vaccines should be given only to healthy cats and dogs. 

Those of us in New Mexico who own dogs or cats consider them an important member of our families. They are a treasured and extremely important part of our lives. No animal owner in NM should be forced by our state to risk their pet’s life if a veterinarian has determined that a vaccination would put it in jeopardy.

When I contacted the city of Albuquerque Animal Licensing Services, I was informed that medical exemption is possible in the state of New Mexico, if I submit a letter from my veterinarian stating why the pet cannot be vaccinated. Regardless, New Mexico rabies law does not include a medical exemption clause. Would you please introduce legislation on my behalf that would add a medical exemption clause into our existing state rabies law?

I would be more than happy to speak to you via telephone, email or meet with you in person. Your help in this cause is desperately needed. Thank you for your attention and efforts in advance. 

Sincerely 
Chryssa Charalambides


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## Kris L. Christine (Mar 25, 2009)

*New Mexico Legislators *http://www.nmlegis.gov/lcs/legislatorsearch.aspx
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## Kris L. Christine (Mar 25, 2009)

[email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; be[email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]


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## Connie Sutherland (Mar 27, 2006)

Lists of legislators' email addresses could be linked to (for future posts), I think, rather than embedded here. 

Thank you for the information, which I've moved to the Health forum.


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## Kris L. Christine (Mar 25, 2009)

*NEW MEXICO Rabies Waivers Action Alert*

*NEW MEXICO--Rabies Medical Exemptions, Urgent Action Alert: *In order to get a rabies medical exemption bill filed this session, legislators must hear from the public in force. 

*What You Can Do to Help*

Please find your legislators' contact information here http://www.nmlegis.gov/lcs/legislatorsearch.aspx and ask them to file a rabies medical exemption bill on your behalf and ask all the pet owners in New Mexico you know to do the same. Despite the survey results showing that the majority (55%) of New Mexico's veterinarians do NOT OPPOSE rabies waivers, the New Mexico Veterinary Medical Association's Board voted to oppose any such legislation that may be filed (see letter below from The Rabies Challenge Fund). If your pet suffers from lymphoma, auto-immune hemolytic anemia, metasticized cancer, grand-mal seizures or is undergoing chemotherapy, they are required under the law to have a rabies booster despite their medical condition, and the NMVMA's Board voted to maintain the status quo refusing such critically ill animals waivers. You may want to call your veterinarian's office to find out if they voted for or against rabies waivers.

If you wish to express your concern to the* Executive Director of the NMVMA *and ask the Board to reverse its decision to oppose rabies exemption legislation, contact* Tamara Spooner at (505) 867-6373 [email protected]. *You can also contact the two New Mexico State veterinarians and tell them to support rabies exemption legislation. Their contact information is *Dr. Paul Ettestad (505) 827-0006 [email protected] *and *Dr. Dave Fly [email protected] (505) 841-6163.*

The time to act on your pet's behalf is now. 

*PERMISSION IS GRANTED TO POST THIS ACTION ALERT*

January 25, 2011

Dr. Dave E. Fly, State Veterinarian Dr. Paul Ettestad, State Public Health Veterinarian
New Mexico Livestock Board New Mexico Department of Health
300 San Mateo NE P.O. Box 26110 
Albuquerque, NM 87109 Santa Fe, NM 87502-6110

RE: Rabies Medical Waivers Survey of New Mexico Veterinarians 

Greetings Drs. Fly and Ettestad:

After reviewing the results of the statewide rabies vaccine waivers survey, designed in conjunction with the New Mexico Veterinary Medical Association (NMVMA), which was sent to New Mexico veterinarians, The Rabies Challenge Fund Charitable Trust would like to address, clarify, and elaborate on several points in the report. 

The survey highlights on the first page that 45% of the respondents were against, 37% were in favor, and 18% undecided on the issue of rabies vaccine waivers, demonstrating that *the majority (55%) of New Mexico’s veterinarians are not opposed to rabies waivers. *In light of the 55% majority of New Mexico’s veterinarians who are not opposed to rabies waivers for sick animals, it was surprising to hear from NMVMA’s Executive Director, Tamara Spooner, that the Board voted to oppose any proposed medical exemption legislation.

Between 1984 and 2010, your survey cites 6 dogs and 10 cats being diagnosed with rabies in New Mexico; however, the report failed to mention that during that same period, 147 bats, 92 skunks, and 37 fox were also confirmed rabid in the state. This is important in light of the fact that the Centers for Disease Control (CDC) data documents bats as the primary vector for human rabies transmission in the United States, not dogs or cats.

Your survey states that_ “Worldwide, dogs are the source of 99% of human rabies deaths.” _This is absolutely not the case in the United States. According to the CDC’s _Cases of Rabies in Human Beings in the United States, by Circumstances of Exposure and Rabies Virus Variant, 1995-2009,_ of the 46 human cases of rabies reported from 1995 through 2009, not one was transmitted by a dog or cat in the United States and not one of those cases was in New Mexico. Out of those human cases, rabies was transmitted by 34 bats, 1 fox, 1 raccoon, and 1 mongoose --- the others were contracted outside U.S. borders. 

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 non-compliance with rabies vaccination requirements compromises the concept of herd immunity existing in New Mexico. Concern was noted in the survey that legalizing rabies vaccine waivers may result in “decreasing herd immunity.” According to Dr. Ronald Schultz of the University of Wisconsin’s School of Veterinary Medicine, a member of the World Small Animal Veterinary Association’s Task Force and the American Animal Hospital Association’s Canine Vaccine Guidelines Task Force, herd immunity is achieved when 75% or more of an animal population is vaccinated. Given the small percentage of animals that would qualify for exemptions, it is highly unlikely that they would pose a real threat to the current level of herd immunity in New Mexico. 

_“[M]any veterinarians had concerns about animals with certain medical conditions receiving vaccine…” _according to your survey, and the following conditions were specified: anaphylactic reaction, lymphoma, neoplasia, immune-mediated disease, immunosuppression, age, neurologic conditions, and pets undergoing chemotherapy. These animals may not respond to rabies vaccination as required by law (noted in the report, these pets _“might lack the ability to develop an appropriate immune response”),_ and their health may be jeopardized if they are not allowed waivers. The_ Postmarketing Surveillance of Rabies Vaccines for Dogs to Evaluate Safety and Efficacy_ published in *The Journal of the American Veterinary Medical Association* April 1, 2008 issue Vol. 232, No. 7, claims that _"[r]abies vaccines are the most common group of biological products identified in adverse event reports received by the CVB [Center for Veterinary Biologics]." _

Rabies vaccine labels state that they are for* healthy *animals, and some elaborate further 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.” _Veterinarians immunizing unhealthy pets, as New Mexico’s rabies code requires, are forced to do so contrary to vaccine manufacturers’ labeled instructions, against the recommendations of the CDC’s National Association of State Public Health Veterinarians’ (of which Dr. Ettestad is a member) Rabies Compendium, counter to sound veterinary medical practice, and possibly in violation of the veterinary oath. 

It is clear from your survey results that the veterinarians polled would not abuse the right to exempt sick animals, and the 13 states that currently do have medical exemptions have found no grounds to repeal them. The rabies endemic State of Maine included a medical exemption clause in their canine rabies regulations in April 2005. The Maine State Veterinarian, Dr. Donald Hoenig (207) 287-7615, confirmed today that no rabid dogs have been reported in the nearly 6 years since the clause went into effect.

As in our July 23, 2010 letter, The Rabies Challenge Fund Charitable Trust respectfully requests that your departments submit legislation to include a medical exemption clause in New Mexico’s current rabies code, Title 7 Chapter 4 Part 2, and that you consider medical exemption language such as that contained in Florida’s statutes, Title XLVI Chapter 828 as follows: 

“A dog, cat, or ferret is exempt from vaccination against rabies if a licensed veterinarian has examined the animal and has certified in writing that at the time vaccination would endanger the animal's health because of its age, infirmity, disability, illness, or other medical considerations. An exempt animal must be vaccinated against rabies as soon as its health permits.”

Please contact me at the number or e-mail below if you have any questions.

Sincerely,

Kris L. Christine
Founder, Co-Trustee
THE RABIES CHALLENGE FUND
www.RabiesChallengeFund.org 
[email protected]

cc: Dr. W. Jean Dodds
Dr. Ronald Schultz
Representative Gail Chasey
Senator Steve Fischmann
New Mexico Legislature

Tamara Spooner – Executive Director, New Mexico Veterinary Medical Association ([email protected])


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## Faisal Khan (Apr 16, 2009)

That's a lot of work for a rabies shot!


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## Kris L. Christine (Mar 25, 2009)

Faisal Khan said:


> That's a lot of work for a rabies shot!


We're working on getting a medical exemption clause put into the rabies regulations.


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## Kris L. Christine (Mar 25, 2009)

*Las Cruces Sun-News* 2/12/11 http://www.lcsun-news.com/las_cruces-news/ci_17374067  *On the Positive Side: Clairification of Rabies Vaccination Sought *

"There is serious concern that vaccination of a dog and cat with medical conditions may jeopardize the life and well being of the cat or dog. There is also a possibility that the vaccine may fail to elicit the appropriate immune response in an unhealthy animal, and that appropriate immune response is necessary for pubic safety. 

For these reasons, pet owners across the state are seeking official clarification to the regulation so that exemption waivers can be provided by licensed veterinarians for ill dogs and cats until such time as they can be declared healthy enough to be vaccinated. "


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## Kris L. Christine (Mar 25, 2009)

*New mexico petition*

*NEW MEXICO:  Rabies Waiver Petition -- please sign and cross-post!* http://www.change.org/petitions/new-mexico-take-action-to-help-pets-too-sick-to-receive-rabies-vaccines?share_id=KBUouGvFmk&pe=pce


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## Kris L. Christine (Mar 25, 2009)

*Urgent!!*

*NEW MEXICO Rabies Medical Exemption Bill HB 341* has been filed by Representative George Dodge http://www.nmlegis.gov/Sessions/11%20Regular/bills/house/HB0341.html and will be heard by the Agriculture & Water Resources Committee this *Friday, February 18th. * It is urgent that all concerned New Mexico pet owners *immediately* contact the Committee as the rabies medical exemption bill is being opposed by the New Mexico Veterinary Medical Association.

*What You Can Do to Help*

Contact the Chair and other members of the Committee (members and contact information below) and ask that the committee vote HB 341 OUGHT TO PASS. Please post this action alert and ask others to share and post it as well.
 
Representative James Roger Madalena, *Chair *[email protected] (505) 986-4417 
Representative Ray Begaye, Vice-Chair [email protected] (505) 986-4435
Representative Cathrynn N. Brown [email protected] (505) 986-4211
Representative Joseph Cervantes [email protected] (505) 986-4234
Representative Zachary J. Cook [email protected] (505) 986-4454
Representative Joni Marie Gutierrez [email protected] (505) 986-4436
Representative Dona G. Irwin [email protected] (505) 986-4234
Representative Larry A. Larrañaga [email protected] (505) 986-4215
Representative Terry H. McMillan [email protected] (505) 986-4220
Representative Don L. Tripp [email protected] (505) 986-4220

*PERMISSION GRANTED TO CROSS-POST**

HB 341*
BE IT ENACTED BY THE LEGISLATURE OF THE STATE OF NEW MEXICO:
 *SECTION 1.* A new section of Chapter 77, Article 1 NMSA 1978 is enacted to read:
 "[NEW MATERIAL] EXEMPTION FROM THE REQUIREMENT FOR RABIES VACCINATION.--
 A. An animal that would otherwise be required to be vaccinated against rabies pursuant to the provisions of Chapter 77, Article 1 or 1A NMSA 1978 may be exempted from such requirement if that animal is the subject of a letter of exemption as provided in Subsection B of this section.
 B. A letter of exemption from the requirement for rabies vaccination may be issued if a medical reason exists that precludes the vaccination of an animal. A letter of exemption shall be in the form of a written statement, signed by a licensed veterinarian, that includes a description of the animal and the medical reason that precludes vaccination against rabies. If the medical reason is temporary, the letter of exemption shall indicate a time of expiration of exemption."


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## Gerry Grimwood (Apr 2, 2007)

I emailed all those people a picture of my junk, I hope it helps.


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## Kris L. Christine (Mar 25, 2009)

Gerry Grimwood said:


> I emailed all those people a picture of my junk, I hope it helps.


 If you're referring to what my son means by that term, you will probably be hearing from law enforcement, not sure if that will help you.


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## Gerry Grimwood (Apr 2, 2007)

Kris L. Christine said:


> If you're referring to what my son means by that term, you will probably be hearing from law enforcement, not sure if that will help you.


Oh no, what have I done ](*,)

If I blow up some needle factories will you get them to drop charges ??


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## Kris L. Christine (Mar 25, 2009)

The hearing on HB 341 has been postponed until *Friday, February 25th*, so there is still time to register your support for a rabies medical exemption for New Mexico's dogs and cats who have been diagnosed by a veterinarian as being too ill to be vaccinated.

The New Mexico Veterinary Medical Association Board http://www.nmvma.org/ABOUT_board.html is lobbying against this medical exemption bill despite the fact that a minority of their members oppose medical exemptions, so it is crucial that the Agriculture Committee http://www.nmlegis.gov/lcs/committeedisplay.aspx?CommitteeCode=HAGC has overwhelming public support for HB 341 in order to pass it (committee member contact information can be found at link or in my previous post).

The following vets comprise the *NMVMA Board*: Linda Locklar, T. “Murt” Byrne, Manuel Garcia, Kathy Dobesh, Charles Lange, Craig Walker, Emily Walker, Rick Miller, Bonnie Snyder, Heidi Hamlen, Terry Jantzen, Don Dykhouse. If your vet is a board member, call & ask them to support the rabies medical exemption bill.


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## Gerry Grimwood (Apr 2, 2007)

I think you are just as bad as the people that come on here and ask how to stop their dog from shitting on the carpet.

You have nothing but your own agenda, and you ..in my opinion..just spew your shit exactly like a PETA person but from a different angle and for the life of me I don't understand why some Mod hasn't said anything to you about it.

Did you really screw up on the Spotted Owl campaign or what ??


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## Kris L. Christine (Mar 25, 2009)

Gerry Grimwood said:


> You have nothing but your own agenda, and you ..in my opinion..just spew your shit exactly like a PETA person but from a different angle and for the life of me I don't understand why some Mod hasn't said anything to you about it.
> 
> Did you really screw up on the Spotted Owl campaign or what ??


PETA launched a public campaign against The Rabies Challenge Fund http://www.peta.org/features/rabies-challenge-fund.aspx and its 3 principals, so if you are trying to portray me as a PETA member, you are way off base. 

If you are not concerned about rabies vaccination protocols, as some members of this forum are, and you find my posts offensive, simply ignore them.


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## Gerry Grimwood (Apr 2, 2007)

Kris L. Christine said:


> If you are not concerned about rabies vaccination protocols, as some members of this forum are, and you find my posts offensive, simply ignore them.


You could ignore my posts as well.

Would you like to have rabies shots taken off the menu entirely and maybe replaced with crystals or hot yoga ??


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## Kris L. Christine (Mar 25, 2009)

*NEW MEXICO Waivers Hearing Friday 2/25/11*

*NEW MEXICO: HB 341 Rabies Waivers Bill--Hearing this Friday, 2/25/11 ACTION ALERT * http://www.nmlegis.gov/Sessions/11%20Regular/bills/house/HB0341.html Contact Representative Dodge (505) 986-4255 [email protected] and Representative Madalena [email protected] (505) 986-4417 in support of bill ATTEND HEARING if you can.

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 *“[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.” *

In concurrence with rabies vaccine manufacturers’ precisely labeled directions that they are for *“healthy” *animals, the American Association of Feline Practitioners advises that *“[c]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].*" [6] 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,[8] 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,

Kris L. Christine
Founder, Co-Trustee
THE RABIES CHALLENGE FUND
http://www.RabiesChallengeFund.org 
[email protected]

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

[6] 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

[8] 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.


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