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ACIP Group Letter

October 19, 2005

Jon Abramson, MD, Chairman of ACIP
Weston M. Kelsey Professor & Chair
Department of Pediatrics
Wake Forest University School of Medicine
Medical Center Boulevard
Winston Salem, NC  27157

Larry Pickering, MD,Executive Secretary for ACIP
National Immunization Program/CDC
1600 Clifton Road, NE, MS EO5
Atlanta, GA  30333

Dear Dr. Abramson and Dr. Pickering: 

On behalf of the undersigned organizations we are writing to request that a final vote on the draft Recommendations for Adult Hepatitis B Vaccination not be held at the October 26-27 meeting of the Advisory Committee on Immunization Practices (ACIP).  We are concerned that the public has not been given sufficient opportunity to review the current version of the draft adult hepatitis B vaccination recommendations.  We believe a more extensive consultation is vital to making appropriate recommendations on an issue of importance in protection our nation's public health.  As a result, we are requesting that the revised draft be made available and open for written comment prior to a vote.

This ACIP decision will become guiding public health policy in the US, perhaps for decades to come.  It is the first major change in adult hepatitis B recommendations to be made since 1991, yet it will be made without sufficient consultation with individuals and organizations in the public and private sectors that are leaders in the prevention, control and treatment of hepatitis B in the United States. Though public comment time is provided on the current meeting agenda, it will follow the Adult Hepatitis B decision. Even if the Committee agenda is changed to provide for public comment prior to the vote, there will be no opportunity to study what is likely to be an extensive – perhaps 40-50 page – draft.

Further, given recent disaster events in the United States, the diversion of some of our resources to help those affected by hurricanes, the cost of air travel, and the limited budgets of many groups engaged in hepatitis B activities, we believe it is unreasonable to expect representatives from organizations to attend the Committee meeting as the sole review and public comment opportunity. Therefore, it is important that ACIP accept written comments during a more inclusive comment period that we are requesting, and that those comments be considered as important as in-person attendance and that they are reviewed by ACIP before a vote is taken. 

We greatly appreciate the considerable time and effort CDC staff and ACIP hepatitis working group members have spent preparing this document, and recognize that we all share a strong commitment to hepatitis prevention.  To that end, we believe that those of us who are working on the front lines to prevent hepatitis B or who are providing care to persons living with hepatitis B have important contributions to make to the discussion.

We appreciate your timely consideration of this request.  To discuss this matter further, please contact Name and number.

 

Sincerely,

 

List in Formation

 

cc:

The Honorable Michael O. Leavitt, Secretary, Health and Human Services
Julie Gerberding, MD, MPH, Director, CDC
Mitchell Cohen, MD, Director, Coordinating Center for Infectious Diseases, CDC
John Ward, MD, Director, Division of Viral Hepatitis, CDC
Eric Mast, MD, MPH, Division of Viral Hepatitis, CDC
Dee Gardner, National Immunization Program, CDC
Dick Conlon, Administrator, National Viral Hepatitis Roundtable