Indiana Medical Exemption for Rabies

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This petition by responsible pet owners requests the Indiana State Board of Animal Health to include a medical exemption clause in the Rabies Immunization Rule 5 Section 345 IAC 1-5-1 for unhealthy animals whose medical conditions have been deemed by a veterinarian to preclude immunization against rabies. A medical exemption clause would allow Indiana’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. Fifteen states currently have medical exemptions: Alabama, California, Colorado, Connecticut, Florida, Illinois, Maine, Massachusetts, New Hampshire, New Jersey, New York, Oregon, Vermont, Virginia, and Wisconsin.

The Centers for Disease Control's National Association of State Public Health Veterinarians Rabies Compendium of Animal Rabies Prevention and Control, as well as the American Veterinary Medical Association and the American Animal Hospital Association, specifically recommend that "All vaccines must be administered in accordance with the specifications of the product label or package insert." Rabies vaccines labeled instructions limit their use to "healthy" animals, and some rabies vaccine labels further caution 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 or the vaccine is not administered in accordance with label directions."

Without a provision for medical exemptions in Rabies Immunization Rule 5 Section 345 IAC 1-5-1 of the 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 regulation to vaccinate sick dogs and cats against rabies in order for their clients to comply with the code also puts Indiana’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.

We strongly urge the Board to include a rabies medical exemption in Rabies Immunization Rule 5 Section 345 IAC 1-5-1.

Thank you for your consideration.