Animal Control Facilities and Rabies Vaccines Guidance (Chapter 588)

Good Evening Shelter Administrators, 

As many of you know, Chapter 588 (HB 325), Acts of 2023 - PDF, will go into effect on October 1, 2023. The purpose of the new law is to enable clinical staff at an animal shelter, humane society, or animal control facility that has a valid animal control facility (ACF) license issued by the State Board of Veterinary Medical Examiners (SBVME) to administer rabies vaccines to shelter animals. The SBVME is currently processing updates to the Code of Maryland Regulations (COMAR) chapter governing animal control facility licenses (COMAR 15.14.04). These new regulations will establish the SBVME’s requirements for licensed ACFs that authorize clinical staff to administer rabies vaccines to ensure that best practices for storage, administration, record keeping, and certificate issuance for rabies vaccinations will be followed. The regulations will describe requirements and responsibilities of ACF owners, responsible individuals, affiliated veterinarians, and clinical staff who will administer rabies vaccinations.

The updated regulations are still under review, and the SBVME must consult with the Maryland Department of Health (MDH) before the proposed regulations can be finalized and submitted for approval. Accordingly, the changes will not be finalized by October 1, 2023, when the new legislation takes effect. The SBVME is providing this guidance to inform ACFs of important requirements before they implement a new process allowing staff to vaccinate shelter animals for rabies.

Clinical staff at shelters may only vaccinate for rabies if the shelter holds a valid ACF license.  

Many shelters already hold ACF licenses and will not require an additional license before allowing trained clinical staff to vaccinate shelter animals for rabies. For those that do not currently have an ACF license but are interested in getting one, please contact us at [email protected] for more information and/or visit the following link to submit an application: Animal Control Facilities (maryland.gov). Unless an animal control facility license has been issued and is in effect, no animal shelter, humane society, or animal control facility may allow clinical staff who are not Maryland licensed and registered veterinarians to administer rabies vaccines. 

Only shelter-owned animals, meaning those in the care and custody of the licensed ACF, may receive rabies vaccinations from clinical staff. 

The new rules authorizing rabies vaccination administration by clinical staff only apply to animals currently owned by and under the care of the shelter. An animal may not be surrendered to a shelter and then adopted out to circumvent this requirement. Any animal owned by a member of the public must still be vaccinated by a Maryland licensed and registered veterinarian. The legislative change and new regulations are intended to promote efficient shelter operations by allowing shelters to be able to place animals in adoptive homes more quickly. 

The licensed ACF shall maintain a list of all supervising veterinarians and clinical staff who will administer rabies vaccines at the ACF.

Although the new law allows clinical staff to vaccinate shelter animals for rabies, a Maryland licensed and registered veterinarian must still sign every rabies vaccination certificate and indirectly supervise the administration of rabies vaccines by ACF clinical staff. The owner and responsible individual must keep a list of 1) all veterinarians affiliated with the licensed ACF who provide indirect supervision over vaccinating staff (supervising veterinarians); and 2) all clinical staff who have been trained to administer rabies vaccines and are authorized by a supervising veterinarian to vaccinate shelter animals for rabies (authorized staff). These requirements are similar to those applicable to authorized euthanasia employees. 

Before any staff member is authorized to vaccinate for rabies, a supervising veterinarian shall complete a “training certificate” verifying that the person has been adequately trained and is authorized to administer rabies vaccines and complete vaccination certificates to be signed by the supervising veterinarian.

The regulations will establish the duties and responsibilities of a supervising veterinarian. These include: 1) directly training or verifying adequate training of each clinical staff member authorized to vaccinate shelter animals for rabies in the scope of the staff member’s duties with the licensed ACF; 2) preparing a written training certificate for each clinical staff member authorized to administer rabies vaccines verifying that the staff member has received adequate training in rabies vaccine administration and is authorized to administer rabies vaccines and prepare rabies vaccine certificates to be signed by the supervising veterinarian; and 3) providing indirect supervision of rabies vaccine administration. 

Staff training must address: the safe handling and storage of rabies vaccines, rabies vaccine administration techniques, how to identify a vaccine reaction, what to do in the event of an adverse vaccine reaction; and record keeping requirements. Supervising veterinarians may use their discretion to train employees in rabies vaccine administration personally or accept training by other providers, including training a staff member who is registered with the SBVME as a Registered Veterinary Technician (RVT) has received. RVTs who receive training in rabies vaccine administration may use the training to satisfy their annual CE requirements.

A staff member may not vaccinate for rabies unless a current training certificate signed by the supervising veterinarian is on file with the ACF. A sample training certificate is attached and may be used until the final version is posted (once the regulations have been finalized). 

Authorized vaccination employees may vaccinate shelter animals for rabies under the indirect supervision of the supervising veterinarian. Indirect supervision does not require the veterinarian to be on the premises during the vaccine administration; however, it does require the veterinarian to be available for contact via telephone, text, or other means in the event of an emergency and be able to provide consultation and review of the administration of rabies vaccines at the animal control facility. Staff should be reminded that their authority to administer rabies vaccines is limited to vaccinations given in the scope of their employment with the ACF.

Rabies vaccination certificates reflecting vaccinations by authorized staff shall be completed by authorized staff when the vaccine is administered, identify the staff member administering the rabies vaccine, be signed by the supervising veterinarian, and comply with all applicable legal requirements.

Rabies certificates reflecting rabies vaccinations at the shelter must be filled out completely and satisfy all legal requirements, including those established by MDH (found in COMAR 10.06.02.10). The rabies vaccination certificates must include, among other things, the name of the authorized employee who administered the rabies vaccine and the name and signature of the veterinarian that has authorized the vaccination. The veterinarian should review each certificate for completeness prior to signing. If a rabies vaccination is given and the veterinarian is not immediately available to sign the certificate, the certificate may be mailed, or picked up by the adopter, after the veterinarian puts the final signature on the certificate. 

If you have any questions regarding this new process or the SBVME’s expectations, please feel free to reach out to [email protected].