Charlie F. Howard

The State of Texas
House of Representatives

March 13,1998

No 980313-12

Robert D. Crider, Jr., MS, MPA
Director; Immunization Division
Texas Department of Health
1100 West 49th St
Austin, TX 78756

Dear Mr. Crider:

A constituent has brought to my attention a concern with the proposed rules implementing HB 3054 from the 75th Legislature. These Immunization Registry rules were published in the February 20th issue of the Texas Register.

The citizen 's comments were that they objected to having to provide their child's social security number and certain other pieces of information for the registry. I understand from a newspaper article printed today in the Austin-American Statesman that this information is optional. I would make two comments about the proposed rules. First, you may be aware that there has been federal legislation introduced that would prohibit the use of social security numbers for uses such as database. I would personally support this legislation and would hope for its passage. In light of that, I would urge you to not become dependent upon using social security numbers, or key your database on the social security number.

Second, and more important for the current circumstance, I would not have been certain from reading the rules alone, that providing the social security number was optional. I would request a modification in the rules which make this fact completely clear. I would also urge that you mandate that all forms produced to gather information for the registry make it obviously clear to parents that the information is optional.

Thank you for your time and attention.

Serving You,
Charlie Howard
State Representative, District 26