The document outlines procedures for processing rabies vaccination exemption requests in Orange County, California. It states that a rabies exemption may be issued if a veterinarian determines vaccination would endanger a dog's life due to medical conditions. The process involves submitting forms signed by an owner and veterinarian, which are reviewed by an OC Animal Care veterinarian who approves or denies the request. Approved exemptions last one year, after which the dog must be vaccinated unless a new exemption is issued.
1. Number: 600.29
SUBJECT: RABIES VACCINATION EXEMPTION REQUESTS 1
Date: 01/22/82
Approved: Jennifer Hawkins, DVM, Director Revised: 10/19/15
I. PURPOSE
To establish a procedure for processing rabies vaccination exemption requests.
II. POLICY
Health and Safety Code section 121690 states, in part, that every dog owner, after his or her dog
attains the age of three months or older, shall, at intervals of time no more often than once a
year, as may be prescribed by the department, procure its vaccination by a licensed veterinarian
with a canine antirabies vaccine approved by the department and administered according to the
vaccine label, unless a licensed veterinarian determines, on an annual basis, that a rabies
vaccination would endanger the dog’s life due to disease or other considerations that the
veterinarian can verify and document.
A rabies vaccination exemption may be issued when licensing an animal. In the case where a
pet owner declares their animal cannot be safely vaccinated for rabies due to a medical
condition, the animal’s owner and private veterinarian must complete and submit the two
required forms and up to 5 pages of medical records, as specified below.
OC Animal Care will process all rabies vaccination exemption requests in accordance with
applicable law. On occasion, exemption requests are submitted by owners of cats required to
be licensed and vaccinated as a condition of an animal permit in accordance with Orange
County Codified Ordinance (OCCO) 4-1-76 or from owners of dogs licensed as service dogs.
These requests will be subject to the same approval process. Discrepancies regarding animals
listed on an animal permit will be brought to the attention of the OC Animal Care Business
Licensing Department.
Health and Safety Code section 121690 also states, in part, that dogs with approved rabies
vaccination exemptions will be considered unvaccinated and shall have no contact with any dog
or cat that is not currently vaccinated against rabies. For this reason, Rabies Control personnel
will utilize the Chameleon database to ensure two dogs in one household do not have
concurrent rabies vaccination exemptions and that all other dogs and cats currently on record at
the specific address are currently rabies vaccinated prior to processing the request.
III. SCOPE
Applicable to Rabies Control, Customer Services and Veterinary Services personnel.
2. Number: 600.29
SUBJECT: RABIES VACCINATION EXEMPTION REQUESTS 2
Date: 01/22/82
Approved: Jennifer Hawkins, DVM, Director Revised: 10/19/15
IV. FORMS
Rabies Vaccination Exemption Request Correction Letter
Rabies Vaccination Exemption Request Denial Letter
Rabies Vaccination Exemption Request Approval Letter
Rabies Vaccination Exemption Request Chameleon Approval Letter
Rabies Vaccination Certificate – Exemption from Canine Rabies Vaccination Form
Count of Orange Supplemental Form for Canine Rabies Vaccination Exemption Requests Form
Canine Rabies Vaccination Exemption Forms Information Sheet
V. REFERENCES
Health and Safety Code section 121690
Orange County Codified Ordinance 4-1-76
VI. DEFINITIONS
Not applicable
VII. PROCEDURE
A. Receipt of Rabies Exemption Request Forms for animal owners who reside within OC
Animal Care’s jurisdiction.
1. In order for the approval process to begin, Rabies Control personnel will ensure
the Rabies Vaccination Certificate – Exemption from Canine Rabies
Vaccination Form, the County of Orange Supplemental Form for Canine Rabies
Vaccination Exemption Requests and up to 5 pages of medical records have
been submitted and completed properly. These forms, along with the Canine
Rabies Vaccination Exemption Forms Information Sheet, can be accessed on the
OC Animal Care website under the Licensing tab or by mail, email or fax upon
request.
2. Rabies Control personnel will run the Chameleon licensing records of all
animals currently on record at the specific address noted on the request to ensure
current rabies vaccinations. In the event there is another dog or cat at the
residence that is not currently rabies vaccinated a Rabies Vaccination Exemption
Request Correction Letter will be mailed to the owner.
3. In the event one or both of the forms are missing entirely, are incomplete or are
missing information or the required medical records were not received, a Rabies
Vaccination Exemption Request Correction Letter will be mailed to the owner
3. Number: 600.29
SUBJECT: RABIES VACCINATION EXEMPTION REQUESTS 3
Date: 01/22/82
Approved: Jennifer Hawkins, DVM, Director Revised: 10/19/15
indicating what corrections are required. It will be the responsibility of the
animal owner to coordinate the completion of the forms with their veterinarian,
as necessary, and ensure they are submitted within the required timeframe.
4. Rabies Control personnel may contact animal owners and veterinarians directly
to confirm information and resolve other minor necessary corrections.
5. All forms will be date stamped upon receipt by the Rabies Control Department.
The owner must submit their corrected form(s) and/or the missing medical
records within 15 calendar days of the date the correction letter is created or a
Rabies Vaccination Exemption Request Denial Letter will be mailed to the
owner. A 5 calendar day internal grace period will be allowed to account for
mailing time. Denial letters should be mailed 20 days from the date of the
correction letter, as applicable. Owners disputing the imposition of a late fee as a
result of a denial or missed timeframe are to be transferred to a Customer
Services supervisor for assistance. Rabies Control personnel are not permitted
to waive fees.
6. A file system will be maintained by the Rabies Control Department where the
incomplete paperwork submitted by the animal owner will be filed 20 calendar
days from the date received.. All incomplete and expired paperwork will be filed
in the appropriate designated file cabinet for record keeping purposes.
7. All correspondence with animal owner’s and their veterinarians, including the
mailing of the correction or denial letter and the reason for the correction, should
be noted in a memo attached to the animal owner’s Chameleon Person ID.
8. Upon the mailing of a correction and/or denial letter, the Tag Date field in the
Tag/Link window of Chameleon should be updated to reflect the date in which
the missing documentation/corrections are due. By doing so, this will help
ensure the owner is not receiving unnecessary notices and/or late fees that may
be generated by the Chameleon or On Base data systems.
B. Processing of forms where all information is complete:
1. Once staff has confirmed that all required information has been submitted,
Rabies Control personnel will staple the two forms and medical records together,
Rabies Vaccination Certificate on top as this is the form the OC Animal Care
veterinarian will sign.
2. Once attached, the paperwork will be placed in the designated space and
submitted to the designated OC Animal Care veterinarian on a weekly basis for
review.
4. Number: 600.29
SUBJECT: RABIES VACCINATION EXEMPTION REQUESTS 4
Date: 01/22/82
Approved: Jennifer Hawkins, DVM, Director Revised: 10/19/15
C. Duties of the OC Animal Care Veterinarian
1. The veterinarian will review each request taking into consideration the
established criteria for exemption listed below and approve or deny the request
by marking the appropriate box at the bottom of the Rabies Vaccination
Certificate – Exemption from Canine Rabies Vaccination Form and providing
their signature and date.
Cases where an exemption may be approved include but are not limited to:
a. Life-threatening anaphylactic reaction soon after administration of a rabies
vaccine:
aa. Signs consistent with anaphylactic shock.
bb. Mild facial angioedema, hives, lethargy and/or localized reactions do
not qualify as life-threatening.
b. Immune-Mediated Hemolytic Anemia (IMHA), if:
aa. Dog is still within first year after diagnosis, or
bb. Onset was within one month of a rabies vaccination, or
cc. More than one episode (i.e. relapses).
c. Polyradiculoneuropathy if:
aa. Dog is still within the first year after diagnosis, or
bb. Onset was within one month after rabies vaccination
d. Terminal prognosis (dog has fewer than three months to live in the opinion
of presiding veterinarian).
e. Dog is currently on immunosuppressive therapy for cancer or immune-
mediated disease (low dose prednisone is not considered immunosuppressive
therapy).
5. Number: 600.29
SUBJECT: RABIES VACCINATION EXEMPTION REQUESTS 5
Date: 01/22/82
Approved: Jennifer Hawkins, DVM, Director Revised: 10/19/15
Exemptions will not be approved in the following cases:
a. Old age, minor reactions to rabies or other vaccinations, positive rabies
titers, severe reaction to vaccinations other than rabies, medical condition not
documented or no documentation submitted, illegible requests.
b. Short term exemptions (e.g. one month exemption for recovery from acute
illness). In these cases, the owners are to be referred to the Rabies Control
Department who can grant extensions upon the owner submitting
documented proof of the condition from a licensed veterinarian.
2. The veterinarian may contact the animal owner’s private veterinarian to discuss
a case in the event additional clarification is needed. If the request is denied, the
veterinarian must write their reason for denial in the appropriate space on the
Rabies Vaccination Certificate – Exemption from Canine Rabies Vaccination
Form.
3. Once complete, the requests will be returned to the Rabies Control Department
who will complete the notification process.
D. Processing Denied Exemption Requests
1. In the event a request is denied, a Rabies Vaccination Deferment Request Denial
Letter will be drafted by Rabies Control personnel and mailed to the owner. The
owner may resubmit the request for reconsideration, if the reason for denial is
correctable, within 15 days of the date of the denial letter. Resubmitted requests
will be subject to the same approval process as the previous request.
2. The same 5 day grace period applies to denial letters. Late fees will be assessed
20 days after the denial is mailed, as applicable.
E. Entering a Denied Rabies Exemption Request into the Chameleon Database
There are many reasons why a rabies exemption request may be denied. The request
may be denied in the event the proper forms are not utilized or required information is
missing, for example. Regardless of the reason for the denial, for the health of the
animal, the medical condition listed on the exemption request is to be noted in
Chameleon, if legible, so OC Animal Care Veterinary Services personnel is aware of the
condition in the event the animal is impounded.
6. Number: 600.29
SUBJECT: RABIES VACCINATION EXEMPTION REQUESTS 6
Date: 01/22/82
Approved: Jennifer Hawkins, DVM, Director Revised: 10/19/15
1. In the event a rabies exemption request is denied, a memo with a Type of
“Medical” is to be stored on the Animal ID indicating the reason for the denial
and the medical condition, if legible, noted by the veterinarian. This information
may also be used by Customer Services staff when assessing late fees.
2. Any correspondence with the owner or their private veterinarian will be noted in
a memo with a Type of “Note” attached to the owner’s Person ID.
3. In the Tag window, the Status of the license will remain “Temporary” and the
Problem Code “V” indicating a rabies vaccination certificate is required. The
Tag Date will be changed to reflect the date in which the missing
documentation/corrections are due.
F. Processing Approved Exemption Requests
Once the designated OC Animal Care veterinarian has approved the week’s rabies
exemption requests, they must be processed and the approval letters prepared and
mailed.
1. All approved requests are to be listed on the Rabies Exemption List for the
appropriate year (Z drive: Rabies Desk: Rabies Deferment List: Rabies
Exemption List). Rabies Control personnel will add all required information to
this list.
2. The Chameleon Tag window will be updated by a memo type of “Medical” to be
stored on the Animal ID with verbiage similar to the following:
“Rabies exemption for “Sam” approved for 1 year by Dr. Hawkins. Approval
letter will be mailed to animal owner”.
The memo type is “Medical” so that in the event the animal is impounded,
Veterinary Services will be notified that the animal should not be vaccinated.
3. The licensing Status will be changed from “Temporary” to “Current” and a
Problem Code of “Y” is to be added to indicate a one year exemption has been
granted.
4. The Tag Date in the Tag window must reflect the date the exemption was
approved. By changing the Tag Date and Problem Code to “Y”, the license will
now be considered valid and a License Certificate will be mailed by Customer
Services to the owner advising of such and that their rabies deferment request
has been approved for one year.
5. In the event the animal is not currently licensed, Rabies Control personnel will
link the animal and owner in the Tag window by creating a VAC CERT record
7. Number: 600.29
SUBJECT: RABIES VACCINATION EXEMPTION REQUESTS 7
Date: 01/22/82
Approved: Jennifer Hawkins, DVM, Director Revised: 10/19/15
prompting a mailer to the owner advising them they are required to license their
dog
6. In the event the animal has not been licensed in the past and will need a tag sent,
or there is any other licensing discrepancy, an email is to be sent to the
designated Licensing Supervisor advising them of such and they will process the
information and mail the tag or make any necessary corrections.
7. In the event there are other Problem Codes listed in addition to missing proof of
a rabies vaccination (“V”), the “V” problem code would be removed and “Def
Vac” would be noted in the Vaccine field. All other problem codes will remain.
8. Should there be no code that includes “Y” or you are otherwise unable to add it,
Rabies Control will remove the “V” Problem Code and enter “Def Vac” in the
Vaccine field. The remaining Problem Codes must be listed in the Problem
Code field so Customer Services personnel are aware of what information is
needed in order for a license to be made valid. No changes will be made to the
Tag Date in these cases as the license is still invalid.
9. In the event a deferment is approved but there are additional requirements in
order to make a license valid such as a sterility certificate, etc. or the license has
not been purchased or renewed recently, Rabies Control personnel will manually
create a Rabies Vaccination Exemption Request Approval Letter to be mailed to
the owner.
10. In the event the Tag window shows the Status as “Current” and a Problem Code
of “T”, the “T” is to be removed and replaced with the “Y”. Additionally, in this
case, the Tag Expiration date should be changed to one year from the Tag Date
giving the owner a full term license. By making this change, a License
Certificate will be mailed to the owner by Customer Services.
11. Approval letters are stored in the Z drive (Z drive: Rabies Desk: Deferments:
Deferment Letters Approved). Once a letter is drafted it is to be stored with the
others and listed under the owner’s last name, first name followed by the
animal’s name. All manual approval letters must be signed or stamped by the
designated OC Animal Care veterinarian prior to mailing.
12. Once all letters are signed, one copy will be made andmailed by standard mail to
the animal owner.
13. A copy of each approved exemption request will be forwarded to the Veterinary
Public Health Section of the California Department of Public Health in
accordance with Health and Safety Code section 121690.
G. Requests received from outside jurisdictions
All rabies vaccination exemption requests must be approved by an OC Animal Care
Veterinarian as the County has jurisdiction over all rabies control issues in the County
8. Number: 600.29
SUBJECT: RABIES VACCINATION EXEMPTION REQUESTS 8
Date: 01/22/82
Approved: Jennifer Hawkins, DVM, Director Revised: 10/19/15
of Orange. The review process is the same for these requests with the following
exceptions:
1. Approved Requests
a. Once an exemption request is approved, Rabies Control personnel will mark
the “Approved” box on the supplemental form and write in the expiration
date which will be one year from the date OC Animal Care has approved the
request.
b. The “Local Animal Control Agency” box will also be marked and the
appropriate agencies name will be written in the “Agency name” space.
c. Enter the required information on the Rabies Deferment List located in the Z
drive.
d. The form will then be faxed or emailed to the appropriate agency based on
where the animal resides.
e. A copy of each approved exemption request will be forwarded to the
Veterinary Public Health Section of the California Department of Public
Health in accordance with Health and Safety Code section 121690.
2. Denied Requests
a. For exemption requests that are denied, the veterinarian will mark the
“Denied” box on the supplemental form and write in the reason for the
denial.
b. The “Local Animal Control Agency” box will also be marked by Rabies
Control personnel and the appropriate agencies name written in the “Agency
name” space.
c. Enter the required information on the Rabies Deferment List located in the Z
drive.
d. The form will then be faxed or emailed to the appropriate agency based on
where the animal resides.
e. OC Animal Care personnel will not attempt to obtain missing forms, medical
records and/or information from constituents of cities not serviced by OC
Animal Care. So there are no negative impacts to the outside agencies
licensing requirements, this will be the responsibility of the city in which the
animal owner resides.
9. Number: 600.29
SUBJECT: RABIES VACCINATION EXEMPTION REQUESTS 9
Date: 01/22/82
Approved: Jennifer Hawkins, DVM, Director Revised: 10/19/15
H. Resubmitted Corrected Forms
Owners who choose to submit forms after previously being denied will be subject to the
same approval process as outlined above. Any late fees that were assessed as a result of
the denial will remain in effect unless waived by a Customer Services supervisor.
I. Rabies Virus Titers
Rabies virus titers are not recognized in the State of California as serum antibody titer is
a measure of the animal’s response to vaccine or infection and not a reliable indicator of
protection.
J. Lifetime Rabies Vaccination Exemptions
In accordance with Health and Safety Code section 121690, OC Animal Care will only
grant one year deferments. However, in the event an animal was granted a lifetime
exemption by OC Animal Care prior to 2012 and the lifetime approval is noted in the
Animal ID memo, it will be recognized.
K. Short Term or Temporary Exemption Requests
There are times when a private veterinarian will request an exemption for a few months,
for example, while they complete treatment for a medical condition or work toward a
diagnosis. In these cases, the exemption will only be approved for one year by OC
Animal Care. The veterinarian should be contacted by Rabies Control and told that in
the event the animal can be vaccinated for rabies they should do so and submit a valid
Rabies Vaccination Certificate to OC Animal Care and the records will be updated by
Customer Services personnel.