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Christina Abel
*OAH_RuleComments.OAH
# 8-0900-30570
Wednesday, July 17, 2013 1:28:17 PM
law.docx
Dear Judge Lipman,
This e-mail is in regards to requiring meningococcal vaccine for Minnesota 7th grade
studutents.
The attachment is a correction and addition to the number of states that require
meningococcal vaccination as previously stated in my June 27 th letter, Comment 33
(PDF: 451KB/16 pages) .
Thank you for your patience.
Chris Abel
Requiring Meningococcal Vaccine for Minnesota Adolescents
This is a correction and addition to the number of states that require meningococcal vaccination
as previously stated in my June 27th letter.
SONAR, P 45 “Currently, 22 states require meningococcal vaccination for students in
sixth or seventh grade.”
Only 16 states have recent requirements for meningococcal vaccination with waivers, of
these 5 require education. Another 6 states have education only. Most states do not
require this vaccine for Elementary and Secondary Schools.
http://www.immunize.org/laws/menin_sec.asp
The correction and additional information Eleven states passed laws requiring meningococcal vaccine for adolescents. And of the eleven
states eight included meningococcal disease and vaccine education. But when adolescents are
required to be vaccinated through “regulation”, 4 states plus District of Columbia, none included
education.
Nine states have required education without meningococcal vaccine requirement, but again
through legislative process.
Recently 5 states were not able to pass legislation for meningococcal vaccine requirement for
adolescents even though all of these states have vaccine exemptions for school age children.
MDH wants to require meningococcal vaccine for 7th grade students through regulation without
including any education.
Maybe an educational statute could have prevented most if not all of Minnesota’s reported
meningococcal disease cases in adolescents in the last five years since most of the reported cases
were not preventable by the meningococcal vaccines.
In the last two years the three reported meningococcal disease cases in adolescent/young adults
were 17 to 22 years of age. All three cases were Not vaccine preventable including the two who
were vaccinated. And if the vaccine fails to protect it does not diminish the severity of
meningococcal disease.
Minnesota 7th to 12th grade population has over 400,000 students. Three years, 2010-2012, the
only meningococcal disease case in this age group was a vaccinated 17-year-old. This was
accomplished without requiring the meningococcal vaccine. The meningococcal vaccine is
already under recommendation on the School Vaccine Record.
The vaccine may have very rare side effects but the occurrence of vaccine preventable
meningococcal disease in Minnesota’s adolescents is also very rare to none at all without
requiring the vaccine.
There has been no reported vaccine preventable meningococcal disease death in this age group
for 8 years, 2005-2012.
First do no harm.
It seems requiring education would be more important and reasonable since most of Minnesota’s
reported meningococcal disease cases in adolescents were not vaccine preventable.
- The meningococcal vaccine is already on the School Immunization Record under
recommendation.
- Even though Minnesota statute requires that parents be informed of an exemption option, and
that the exemption information must be on the same page as the requirement information, the
MDH has put the exemption information on the back side of the form which at times has been
omitted when copies (front side) were made for parents.
- Meningococcal disease is very rare in the U.S., including Minnesota’s adolescents.
- The bacteria is not easily transmittable.
- Vaccinating adolescents does not create herd protection in the community.
- When the vaccine fails to protect the vaccine does not reduce the seriousness of the disease.
- Routine vaccination of Meningococcal vaccine (MCV4) is not cost-effective.
Thank you,
Chris Abel, RN
Crystal, MN
Vaccine Awareness Minnesota
“The case-fatality ratio was similar among persons who had received vaccine compared with
those who were unvaccinated (CDC, unpublished data, 2012).” ACIP, Recommendations and
Reports, March 22, 2013 / 62(RR02);1-22, p 7 http://www.cdc.gov/mmwr/pdf/rr/rr6202.pdf
States and D.C meningococcal vaccine and education “requirements” information:
National Conference of State Legislatures http://www.ncsl.org/issues-research/health/meningitis-state-legislation-and-laws.aspx
Immunization Action Coalition http://www.immunize.org/laws/menin_sec.asp
Ten states have a state statute that requires meningococcal vaccine for adolescents. Seven
include education requirement.
Three states plus District of Columbia require meningococcal vaccine for adolescents through
“regulation” but none have education requirements.
Two states require vaccination only for residential students. One has a state statute that
includes education for all students and one state has a “regulation” with no education
requirement
Nine other states have statutes that require education without requiring vaccination.
All of the 17 states that include education requirement were passed through legislation.
The 4 states plus D.C. that require meningococcal vaccine through “regulation” do not require
education.
More recently 5 states were not able to pass legislation for meningococcal vaccine
requirement. All of these states already have vaccine exemptions for adolescent students.
Wyoming
SB 104 would require that the meningitis vaccination is included in the immunization standards and
recommendations issued by the state health officer. Would also add the meningitis immunization to
state vaccine program. Died in Senate, 2/2/11.
Maine
SP 329 would require meningococcal vaccines for students who are 11 years of age or older, beginning
with the 2010-2011 school year by requiring the Department of Health and Human Services to amend
the immunization rule. Placed in Legislative Files (Dead), 4/9/09.
Oregon
SB 716 would require the department of human services to adopt rules to include the meningitis
vaccine among those required for school attendance. Senate Human Services and Rural Health Policy,
4/22/09; did not pass by end of session 6/30/09.
New York
AB 10313 and SB 7156 would require seventh graders and students entering college to receive a
vaccination against meningococcal disease. AB 10313 Assembly Rules Committee, 6/28/10; SB 7156,
engrossed in Senate, Assembly Health Committee, 6/23/10; both did not pass by end of session 1/5/11.
AB 10942 would require 7th graders and all college students to receive the meningococcal disease
immunization as a prerequisite for enrollment. Allows only state mandated exemptions. The bill
repeals Public Health Law §2167 that gives the option of a waiver to college freshmen. Assembly Health
Committee, 6/20/08; did not pass by end of 2008 session.
SB 7822 would add meningococcal disease vaccine to school requirements for students in the seventh
grade and higher. Medical and religious exemptions may apply, as with other vaccines. Senate Rules
Committee, 6/16/08; did not pass by end of 2008 session.
SB 8623 would add meningococcal disease vaccine to school requirements for students in the seventh
grade and higher. Medical and religious exemptions may apply, as with other vaccines. Senate Rules
Committee, 6/19/08; did not pass by end of 2008 session.
Ohio SB 311 would require students either to be vaccinated against meningitis or students (parents or
guardians for minors) must sign a waiver that they have received the information and declined the
vaccination. Currently students in Ohio's institutions of higher education are only required to disclose
whether or not they have been vaccinated against meningitis. Senate Health, Human Services, and
Aging Committee, 3/27/08; did not pass by end of 2008 session.