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Notice: California dog owners
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The following is Dr. W. Jean Dodds' letter of support for "Molly's Bill", AB 2000, and her refutation of the California Department of Public Health's opposition:
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June 14, 2010
The Honorable Curt Hagman
California State Assembly
State Capitol, Room 4116
Sacramento, CA 95814Re: CA Assembly Bill AB2000
Dear Assembly Member Hagman:
I learned today from your staff person, Saulo Londono, that the California Department of Public Health (CDPH) has officially opposed your sponsored bill AB 2000. This decision by the CDPH is a huge step backwards for veterinary health care professionals, like myself, who need to be able to justify exemption from rabies vaccine boosters on a case-by-case basis. Your bill AB 2000 would permit a safe alternative for dogs whose illnesses were caused by a rabies vaccine, as well as those too sick to tolerate the rabies vaccine because of terminal cancer, kidney/liver failure, grand mal seizures, and other chronic diseases.
The CDPH letter of June 8, 2010 states that ?there is no scientific evidence that rabies vaccines are associated with severe or a high rate of vaccination reactions.? This statement is just false. The letter goes on to state that ?Modern rabies vaccines are safe and effective?, and that ? A recent study published by the U.S. Department of Agriculture (USDA) found that rabies vaccines used for dogs –-- do not result in a high frequency or unexpected pattern of adverse events.? On the contrary, this same cited study found:
Rabies Vaccines and the USDA/CVB
Rabies vaccines are the most common group of biological products identified in adverse event reports received by the USDA?s Center for Veterinary Biologics (CVB). Currently, 14 rabies vaccines are labeled for use in dogs. Before licensure, a product must be shown to be safe through a combination of safety evaluations. The field safety trial is the most comprehensive evaluation and has the objective of assessing the safety of the product in its target population under the conditions of its intended use. However, safety studies before licensure may not detect all safety concerns for a number of reasons, as follows: insufficient number of animals for low frequency events, insufficient duration of observation, sensitivities of subpopulations (e.g. breed, reproductive status, and unintended species), or interactions with concomitantly administered products.
Reporting Adverse Vaccine Reaction to Manufacturer and the Government
There is no mandatory reporting of adverse reactions in veterinary medicine. The 2007 World Small Animal Veterinary Association (WSAVA) Vaccine Guidelines states that there is: "gross under-reporting of vaccine-associated adverse events which impedes knowledge of the ongoing safety of these products." WSAVA 2007 Vaccine Guidelines http://www.wsava.org/SAC.htm,
Despite the serious under-reporting of vaccine-associated adverse reactions, the 2008 Report from the USDA?s CVB [JAVMA 232:1000-1002, 2008], states that between April 1, 2004 and March 31, 2007, they "requested manufacturers of rabies vaccines to provide adverse event report summaries for their products. During this period, nearly 10,000 adverse event reports (all animal species) were received by manufacturers of rabies vaccines. Approximately 65% of the manufacturer's reports involved dogs."
The USDA/CVB 2008 Report further states that "Rabies vaccines are the most common group of biological products identified in adverse event reports received by the CVB." During the 3-year period covered in this report, the CVB received 246 adverse event reports for dogs in which a rabies vaccine was identified as one of the products administered.
The following clinical terms were listed ?to describe possibly related adverse events in dogs vaccinated against rabies ? and reported to the USDA/CVB between April 1, 2004-March 31, 2007. For 217 adverse event reports ? the clinical term is followed by the % of dogs affected:
Vomiting-28.1%; facial swelling-26.3%; injection site swelling or lump-19.4%; lethargy-12%; urticaria-10.1%; circulatory shock-8.3%; injection site pain-7.4%; pruritus-7.4%; injection site alopecia or hair loss-6.9%; death-5.5%; lack of consciousness-5.5; diarrhea-4.6%; hypersensitivity (not specified)-4.6%; fever-4.1%;, anaphylaxis-2.8%; ataxia-2.8%; lameness-2.8%; general signs of pain-2.3%; hyperactivity-2.3%; injection site scab or crust-2.3%;, muscle tremor-2.3%; tachycardia-2.3%; and thrombocytopenia-2.3%.
The overall adverse report rate for rabies vaccines was determined to be 8.3 reports/100,000 doses sold. Adverse events considered possibly related to vaccination included acute hypersensitivity (59%); local reactions (27%); systemic reactions, which refers to short-term lethargy, fever, general pain, anorexia, or behavioral changes, with or without gastrointestinal disturbances starting within 3 days after vaccination (9%); autoimmune disorders (3%); and other (2%).
While there may be no contraindications listed on the label for canine rabies vaccines, the labeling instructions on vaccine products clearly instruct veterinarians to only vaccinate healthy dogs. I submit that the dogs for which medically justified exemptions from rabies boosters are sought are not healthy.
The CDPH ?believes that passage of AB 2000 could increase the risk to the public health by allowing dogs to be exempted from current rabies vaccination requirements.? This statement lacks credibility, as the number of dogs eligible for exemptions statewide would be small and such exemptions require that a primary care veterinarian justify them on a case-by-case basis. To deny these animals the opportunity to avoid serious or even fatal adverse events from rabies vaccines just encourages pet owners to break the law to save their pets from harm. They would then join the approximate 50% of pet owners in our State that fail to vaccinate their dogs at all. It is those that flaunt the law and never comply that we should seek out, rather than penalizing the few unfortunate pets and owners whose dogs cannot tolerate rabies boosters.
Finally, the CDPH letter states ? Standard veterinary immunization protocols already exist to prevent vaccine adverse reactions.? I know of no such standard protocols, and further, one often cannot predict which animals will react adversely without a prior history of reaction or family predisposition.
Sincerely,
W. Jean Dodds, DVM
Co -Trustee, Rabies Challenge Fund Charitable Trust;
President, Hemopet -
Below is the letter I just faxed to the Senate Health Committee.
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June 16, 2010
Senator Elaine Alquist, Chair
Senate Health Committee
State Capitol, Room 5080
Sacramento, CA 95814**RE: Support for Mollys Bill, AB2000
Greetings Senator Alquist:
The Rabies Challenge Fund, a California-registered charitable trust of which Co-Trustee Dr. W. Jean is a California resident, strongly supports Mollys Bill, AB 2000.
For years, many states have had medical exemptions in rabies laws without experiencing an increase in rabies for the species of domestic animals covered by the laws, and there is no epidemiological or scientific data indicating that California residents will be at an elevated risk of contracting rabies if ?Molly?s Bill? is passed.
Maine is a rabies endemic state, yet the Department of Health passed a medical exemption clause into the rabies regulations, which became effective in April 2005 (DHS Chapter 260 http://www.maine.gov/sos/cec/rules/10/144/144c260.doc). Dr. Donald E. Hoenig, Maine?s State Veterinarian (207) 287-7615, confirmed today that there have been no rabid dogs reported in the state since the passage of the rabies medical exemption clause more than five years ago.
Within the last year, the states of Alabama, Rhode Island, and Virginia have all passed rabies medical exemption clauses into their laws and regulations. The Rabies Challenge Fund Charitable Trust urges the Senate Health Committee to support Mollys Bill.
Sincerely,
Kris L. Christine
Founder, Co-Trustee
THE RABIES CHALLENGE FUND CHARITABLE TRUST
www.RabiesChallengeFund.org
ledgespring@lincoln.midcoast.comcc: W. Jean Dodds, DVM
Ronald D. Schultz, PhD
Assembly Member Curt Hagman** -
Humane Society Veterinary Medical Association's Letter of Support for "Molly's Bill," AB 2000 California Rabies Medical Exemption
June 16, 2010
Senator Elaine Alquist, Chairperson
CA State Senate Health Committee
State Capitol Building, Room 2191
Sacramento, CA 95814
FAX: (916) 324‐0384RE: Follow‐up Veterinary Support Letter for AB 2000 (Medical Exemption from Rabies Vaccination), including Response to California Department of Public Health (CDPH) Objections
Dear Senator Alquist and Committee Members:
I am writing on behalf of the Humane Society Veterinary Medical Association (HSVMA), an organization representing approximately 2,000 veterinary professionals nationwide with a focus on the health and welfare of all animals, including companion dogs and cats, to reiterate our support for AB 2000 and to counter objections voiced in the California Department of Public Health?s opposition letter, dated June 8. (Our original letter, dated May 7, in support of the bill, is attached for your reference.)
The CDPH statement that ?there is no scientific evidence that rabies vaccines are associated with severe or a high rate of vaccination reactions,? is simply incorrect. The USDA Center for Veterinary Biologics (CVB) reports that rabies vaccines are the most common group of biological products named in the adverse event reports they receive. Adverse vaccine‐associated reactions are not required to be reported in veterinary medicine. Even in the face of what is probably gross underreporting, the USDA/CVB Report, published in the April 1, 2008 issue of the Journal of the American Medical Association (pages 1000‐1002), states that from April 2004 through March 2007 nearly 10,000 adverse event reports were received by rabies vaccine manufacturers, and that about 65% of these concerned dogs. The overall rate of such adverse rabies vaccine reactions during the report period was 8.3 reports/100,000 doses of vaccine. These are by no means trivial findings nor is the magnitude of the numbers insignificant. Although canine rabies vaccine labels may not enumerate contraindications, the labeling instructions on vaccine products clearly instruct veterinarians to vaccinate only healthy dogs. A small number of companion animals have medical conditions for which vaccination is life‐ or health‐threatening and thus, inappropriate. In these cases, a dog?s particular exemption from rabies vaccination would be individually substantiated by a veterinarian, and under these stringent circumstances, we do not foresee the submission of illegitimate or frivolous requests.
Veterinarians are well trained in immunology and develop a great respect for both the powerful positive and potential negative consequence of vaccinating their patients. Veterinary schools require detailed study of those zoonotic diseases, like rabies, that are transmissible from animals to humans. State and national veterinary board exams rigorously test this understanding. Veterinary schools and professional advisory bodies regularly update vaccination protocols as new findings emerge. Vaccinology is one of the most active areas of research and discussion in the professional literature, at continuing education venues, and among clinicians around the country and throughout the world.
The Veterinarian?s Oath states, ?I solemnly swear to use my scientific knowledge and skills for the benefit of society through the protection of animal health, the relief of animal suffering? (and) the promotion of public health?? As veterinarians we continuously safeguard the public health by protecting the health and welfare of our patients within the context of their families and our communities. Disallowing veterinary medical exemption from rabies vaccination impugns this professional commitment and puts the public at greater potential risk by those who, concerned
about their dogs? health and deprived of a vaccination exemption option, may choose to fly ?under the radar,? eluding both licensing and vaccination entirely.A number of states, including Alabama, Florida, Colorado, Connecticut, Maine, Massachusetts, New Jersey, New York, Virginia and Wisconsin, successfully provide medical exemption from rabies vaccination without quarantine provisions. Once again, we encourage your support of this important state legislation, similarly safeguarding the health and welfare of the companion canines of Californians.
Please contact me if you have any questions or if you would like more details about our perspective on these issues. Thank you for your consideration.
Sincerely,
Barbara Hodges, DVM, MBA
Veterinary Consultant
Humane Society Veterinary Medical Association (HSVMA) -
Statement from Dr. Margo Roman sent in Support of AB 2000, "Molly's Bill"
As a California licensed veterinarian who has been practicing for 32 years, I am concerned about the health and well-being of my patients and protection of my clients. I am very concerned about the rabies vaccine. I have seen very serious reactions from the vaccine. My own personal dog, a 17 month old Standard Poodle ?Wailea? was given a second rabies vaccine at 17 months and went into liver failure and facial myositis. She eventually lost all the muscles in her head as her eyes were sinking into their sockets and she eventually died.
I had taken a rabies titer (an antibody blood test) on my dog just for information at the time of the vaccine and it showed 10 times more protection than needed for a rabies response. Since the rabies vaccine is only 86 % effective and that means 14% of the animals vaccinated do not have protection. My dog did not need that vaccine but I gave it due to the law and it eventually killed my dog.
My dog's antibodies were protecting her from the deadly disease of rabies and giving her another vaccine did not make her more protected but instead drove her body into an auto-immune reaction attacking her own body.
I received my own rabies vaccines in 1974 and was told in Veterinary School that I should never just blindly get vaccinated but should titer every other year and see if my titer had dropped. If my titer dropped below the level then I should get a booster. Under no circumstances should I just blindly get a booster as it can cause auto-immune issues. As veterinarians, we are required to do that. The vaccine has hazardous effects. With 46 % of dogs and 39 % of cats now getting cancer, giving an unnecessary rabies vaccine is very dangerous to the pet.
Vaccines are strong immune stimulators and can work negatively on the immune system. Titers are the best way to see if vaccines are effective protection and they should be an accepted evaluation of a pets protection from Rabies.
Margo Roman,DVM
www.mashvet.comMargo Roman, DVM
MASH Main St Animal Services of Hopkinton
Hopkinton, MA 01748
508-435-4077 fx 508-435-5533
www.mashvet.comDrDoMore Project
www.drdomore.com
drdomoredvm@aol.com -
CALIFORNIA AB2000 UPDATE: Yesterday, with Saulo Londono and AM Curt Hagman, representatives of all the interested parties from the government agencies and California Veterinary Medical Association, including Dr. W. Jean Dodds from The Rabies Challenge Fund met via telephone conference. Draft amendments to the bill will NOT include quarantine, and I will post an update as soon as that rewording is available. The Senate Health Committee meets today.
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CALIFORNIA Medical Exemption Bill AB 2000 Senate Health Committee Votes DO PASS 6/30/10 http://www.leginfo.ca.gov/pub/09-10/bill/asm/ab_1951-2000/ab_2000_bill_20100701_status.html amended language not available yet, so we are not sure precisely what wording passed.
The bill has been referred to the Committee on Appropriations.
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CA Rabies Medical Exemption Bill AB 2000 – Senate Appropriations hearing set for 8/2/10 http://www.leginfo.ca.gov/pub/09-10/bill/asm/ab_1951-2000/ab_2000_bill_20100714_status.html
Please contact the members of the Appropriations committee below and ask them to fully fund AB 2000
Senator Christine Kehoe (Chair) senator.kehoe@sen.ca.gov Phone: (916) 651-4039 Fax: (916) 327-2188
Senator Elaine Alquist senator.alquist@sen.ca.gov Phone: (916) 651-4013 Fax: (916) 324-0283
Senator Elaine Corbett senator.corbett@sen.ca.gov Phone (916) 651-4010 Fax: (916) 327-2433
Senator Jeff Denham senator.denham@sen.ca.gov Phone (916) 651-4012 Fax: (916) 445-0773
Senator Mark Leno senator.leno@sen.ca.gov (916) 651-4003 Fax: (916) 445-4722
Senator Curren Price senator.curren@sen.ca.gov Phone (916) 651-4026 Fax: (916) 445-8899
Senator Mimi Walters senator.walters@sen.ca.gov Phone (916) 651-4033 Fax: (916) 445-9754
Senator Lois Wolk senator.wolk@sen.ca.gov (916) 651-4005 Fax: (916) 323-2304
Senator Mark Wyland senator.wyland@sen.ca.gov (916) 651-4038 Fax: (916) 446-7382
Senator Leland Yee senator.yee@sen.ca.gov (916) 651-4008PERMISSION GRANTED TO POST AND CROSS-POST
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UPDATE: CA Medical Exemption Bill AB 2000 – On 8/2/10, California's Senate Appropriations Committee decided that the medical exemption bill AB 2000, Molly's Bill, "met the criteria for referral to the Suspense File," meaning that it will cost the state over $150,000 to implement http://www.leginfo.ca.gov/pub/09-10/bill/asm/ab_1951-2000/ab_2000_cfa_20100802_131733_sen_comm.html .
An Appropriations Committee hearing is scheduled for 8/12/10 to vote yes or no on all the suspense file bills – a yes vote will send a bill to the Senate floor, a no vote will kill the bill. Saulo Londono from AM Hagman's office told me today that his office has requested that the committee pull AB 2000 from the Suspense File and send it directly to the Senate floor for vote; he expects to hear back within 48 hours whether they will pull the bill or not.
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UPDATE 8/13/10 California Medical Exemption AB 2000, "Molly's Bill" – Saulo Londono from AM Hagman's office just informed me that AB 2000, "Molly's Bill," was NOT voted out of the "Suspense File" at yesterday's Appropriations Committee hearing, which means that the bill will not go to the Senate for a floor vote, which it must do in order to become law. According to Mr. Londono, the Committee Chair's STAFF (Senator Christine Kehoe (Chair) senator.kehoe@sen.ca.gov Phone: (916) 651-4039 Fax: (916) 327-2188) determined that the bill doesn't merit the cost of implementing it. He believes that Senator Kehoe's staff is "playing politics" with this bill, and AM Hagman's office has contacted the Governor's office to see what can be done.
Mr. Londono will get back in touch with me next week to let us know what we dog owners can do.
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URGENT–California AB 2000 Action Alert "Molly's Bill" – Please make 3 calls: Monica Wagoner Dept. Health (916) 440-7502, Appropriations Committee (916-651-4101), and Committee Chair Senator Kehoe (916) 651-4039. Tell them to stop playing politics with the lives of California's sick dogs and get this bill to the Senate Floor for passage.
Saulo Londono called from AM Hagman's office with an update. Apparently the problem with this bill lies with the Deputy Director of Legislative & Governmental Affairs in the Department of Health, Monica Wagoner (916) 440-7502, who claims they will need to hire a 1/2 time research scientist for 18 months at the cost of $160,000 to put this bill through the regulatory process. Other states, such as Maine, did not have to hire anyone to process their medical exemption regulations -- it appears that the Health Department is trying to use this bill as an excuse to hire an extra researcher. Monica Wagoner is the same person who wrote a letter to California legislators on June 8th opposing the rabies medical exemption after the mandatory quarantine clause was removed. Please call Monica Wagoner's office and tell her this cost is ridiculous, other states did not take 18 months to process a medical exemption clause into their regulations, and they did not have to hire a research scientist in order to do so.
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UPDATE "Molly's Bill" CALIFORNIA AB 2000 August 28: Saulo Londono from AM Hagman's office called to say that Senate Appropriations Committee Chair, Senator Christine Kehoe (916) 651-4039 "killed" the rabies medical exemption bill, AB 2000 "Molly's Bill" yesterday in committee by aligning all the Democrats on the Committee to vote against it strictly along party lines rather on the merit of the bill. Senator Kehoe's Chief of Staff reportedly told Saulo that this was "all about politics."
Remember this bill unanimously passed an Assembly floor vote (74-0) May 6th, and on July 15th received a unanimous 8-0 "DO PASS" vote from the Senate Health Committee. The Appropriations Committee should respect this strong vote of support from the Legislature and fund this bill. **Please direct any and all calls of concern to Senator Kehoe at (916) 651-4039.
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UPDATE "Molly's Bill" CALIFORNIA AB 2000 September 9. This bill unanimously passed an Assembly floor vote (74-0) May 6th, and on July 15th received a unanimous 8-0 "DO PASS" vote from the Senate Health Committee http://www.leginfo.ca.gov/pub/09-10/bill/asm/ab_1951-2000/ab_2000_bill_20100827_history.html . Thus, it was deemed by the California legislature to be medically meritorious and in need of enactment. The bill was then ?killed? by Senator Christine Kehoe and the Senate Appropriations Committee based solely on perceived fiscal needs and party line politics during this time of recession.
**Should any one residing in California have a dog justifiably in need of medical exemption from rabies booster vaccination, the fact that this bill unanimously passed both houses can be used as a rationale for rabies exemption at the local level.
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CALIFORNIA: Rabies Medical Exemption Petition http://www.change.org/petitions/view/california_take_action_to_help_dogs_too_ill_to_receive_the_rabies_vaccine for California residents. If the link to the petition does not work by clicking on it, simply copy and paste it into your browser. Please ask all the California residents you know to sign this petition.
Veterinary student Lisa Lippman has started a petition to get Rabies Medical Exemption legislation reintroduced in California. Lisa's story and another link to petition: http://www.truthaboutpetfood.com/articles/vet-student-assists-to-change-rabies-law-in-california.html
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CALIFORNIA Rabies Medical Exemption Bill AB 258 (Molly's Bill) http://www.leginfo.ca.gov/pub/11-12/bill/asm/ab_0251-0300/ab_258_bill_20110222_status.html has been referred to the Agriculture Committee. Please contact Committee members (especially Chair Galgiani (916) 319-2017 Assemblymember.Galgiani@assembly.ca.gov ) and ask that they vote "Ought to Pass."
2011 California Agriculture Committee http://www.assembly.ca.gov/acs/newcomframeset.asp?committee=53
Committee Phone (916) 319-2084
Cathleen Galgiani - Chair (916) 319-2017 Assemblymember.Galgiani@assembly.ca.gov
David G. Valadao - Vice Chair (916) 319-2030 Assemblymember.Valadao@assembly.ca.gov
Bill Berryhill (916) 319-2026 Assemblymember.Bill.Berryhill@assembly.ca.gov
Jerry Hill (916) 319-2019 Assemblymember.Hill@assembly.ca.gov
Fiona Ma (916) 319-2012 Assemblymember.Ma@assembly.ca.gov
Tony Mendoza (916) 319-2056 Assemblymember.Mendoza@assembly.ca.gov
Kristin Olsen (916) 319-2025 Assemblymember.Olsen@asm.ca.gov
Henry T. Perea (916) 319-2031 Assemblymember.Perea@assembly.ca.gov
Mariko Yamada (916) 319-2008 Assemblymember.Yamada@assembly.ca.gov -
CALIFORNIA Rabies Medical Exemption Bill AB 258 Hearing Date April 6 http://www.leginfo.ca.gov/pub/11-12/bill/asm/ab_0251-0300/ab_258_bill_20110310_status.html before the Assembly Agriculture Committee. Please contact Committee Chair Cathleen Galgiani (916) 319-2017 Assemblymember.Galgiani@assembly.ca.gov and ask the committee to vote "ought to pass."
Please attend the hearing if you can and share this message with everyone you know in California, the more California pet owners the committee hears from, the more likely the bill will pass.
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CALIFORNIA Medical Exemption Bill AB 258 ("Molly's Bill") passed the Assembly Agriculture Committee yesterday 9-0 "on consent" http://www.leginfo.ca.gov/pub/11-12/bill/asm/ab_0251-0300/ab_258_bill_20110406_status.html and has been referred to the Appropriations Committee.
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California Medical Exemption Bill AB 258 "Do Pass" 5/4/11 Appropriations Committee 17-0 vote http://www.leginfo.ca.gov/pub/11-12/bill/asm/ab_0251-0300/ab_258_bill_20110504_status.html
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CALIFORNIA Rabies Waiver Bill AB 258 http://www.leginfo.ca.gov/pub/11-12/bill/asm/ab_0251-0300/ab_258_bill_20110531_status.html has a Senate Health Committee hearing on June 8, 2011. Contact Committee Chair Senator Ed Hernandez senator.hernandez@senate.ca.gov (916) 651-4024 and ask the committee to vote "OUGHT TO PASS."
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CALIFORNIA Rabies Waiver Bill AB 258 (Molly's Bill) http://www.leginfo.ca.gov/pub/11-12/bill/asm/ab_0251-0300/ab_258_bill_20110608_status.html unanimously passed Senate Health Committee yesterday.
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CALIFORNIA Rabies Waiver Bill AB 258 http://www.leginfo.ca.gov/pub/11-12/bill/asm/ab_0251-0300/ab_258_bill_20110620_amended_sen_v98.html amended in Senate on second reading 6/20/11 to include phrase: "that the veterinarian can verify and document."