Below is a copy of the letter I have just sent to Tennessee's Governor and Attorney General regarding the state's rabies immunization protocol for dogs.
What You Can Do to Help
Contact the following:
Governor Bredesen phil.bredesen@state.tn.us Phone: 615.741.2001 Fax: 615.532.9711
Attorney General Cooper Phone: 615-741-3491 615/741-5860 Fax: 615/741-2009
Mr. Bernie Rhoades, Tennessee Department of Health
Bernie.Rhoades@state.tn.us Phone: (615) 741-8539
Dr. John Dunn, Tennessee Department of Health
John.Dunn@state.tn.us Phone: 615.741.7247
Your Legislator Tennessee Legislature
Welcome to the Tennessee General Assembly (full list of TN legislators e-mails in my original post above, just copy and paste)
PERMISSION GRANTED TO CROSS-POST
May 12, 2008
Governor Phil Bredesen Attorney General Robert E. Cooper, Jr.
Tennessee State Capitol P.O. Box 20207
Nashville, TN 37243-0001 Nashville, TN 37202-0207
RE:
Tennessee’s Anti-Rabies Law, Title 68 Chapter 8
Greetings Governor Bredesen and General Cooper:
Tennessee’s state anti-rabies law, Title 68 Chapter 8 Section 103 (i) declares that
“Nothing in this section shall be construed to require more frequent rabies vaccinations or a greater number of rabies vaccinations than are required by the rabies compendium,” and defines the “compendium” under Section 102 (3) as
“the most recent issue of the national ‘Compendium of Animal Rabies Prevention and Control’ published by the Association of State Public Health Veterinarians..”
The National Association of State Public Health Veterinarian’s (NASPHV) Compendium of Rabies Prevention and Control promulgated in Tennessee’s anti-rabies law declares that
“All vaccines must be administered in accordance with the specifications of the product label or package insert. …. Vaccines used in state and local rabies control programs should have at least a 3-year duration of immunity. ….. No laboratory or epidemiologic data exist to support the annual or biennial administration of 3- or 4-year vaccines following the initial series.”[1] The American Veterinary Medical Association also endorses NASPHV’s Compendium[2] which is incorporated into Tennessee’s law.
Confusion ensues and Tennessee dogs are inappropriately vaccinated when counties, towns, and veterinarians arbitrarily override the directives of Title 68 Chapter 8 by requiring annual rabies boosters after the initial puppy series. In a May 9th phone conversation, Mr. Bernie Rhoades of the Tennessee Department of Health told me that the media is responsible for spreading the fallacy that Tennessee law requires annual rabies boosters. While speaking later that day with Dr. John Dunn, State Medical Epidemiologist and DVM, he stated that he and the public officials favor the 3 year protocol in Tennessee’s law and that veterinarians are responsible for overriding the law in Davidson County. Random compliance with the state law means that some Tennessee dogs are subjected to a rabies vaccination protocol that directly conflicts with the recommendations of two of the country’s top veterinary medical associations -- the National Association of State Public Health Veterinarians and the American Veterinary Medical Association.
Medically unnecessary annual rabies vaccinations put dogs at needless risk of adverse reactions without boosting immunity, and it obligates Tennessee pet owners to pay for veterinary procedures from which their animals derive no benefit, and which may cause permanent harm. The American Veterinary Medical Association's 2001 Principles of Vaccination state that
“Unnecessary stimulation of the immune system does not result in enhanced disease resistance, and may increase the risk of adverse post-vaccination events.”[3]
Many, if not all, annual rabies vaccines are the 3 year vaccine relabeled for annual use -- Colorado State University's Small Animal Vaccination Protocol for its veterinary teaching hospital states:
“Even with rabies vaccines, the label may be misleading in that a three year duration of immunity product may also be labeled and sold as a one year duration of immunity product.” According to Dr. Ronald Schultz, Chair of the Department of Pathobiological Sciences at the University of Wisconsin School of Veterinary Medicine, “There is no benefit from annual rabies vaccination and most one year rabies products are similar or identical to the 3-year products with regard to duration of immunity and effectiveness.”[4]
Immunologically, the rabies vaccine is the most potent of the veterinary vaccines as well as being a “killed,” adjuvanted vaccine associated with clinically significant, sometimes lethal, adverse reactions (death was reported to the Center for Veterinary Biologics in 5.5% of dogs experiencing adverse reactions to the rabies vaccine between 4/20/04 and 3/31/07)[5]. In 1999, the World Health Organization
"classified veterinary vaccine adjuvants as Class III/IV carcinogens with Class IV being the highest risk,"[6] and the results of a study published in the August 2003 Journal of Veterinary Medicine documenting fibrosarcomas at the presumed injection sites of rabies vaccines reported,
“In both dogs and cats, the development of necrotizing panniculitis at sites of rabies vaccine administration was first observed by Hendrick & Dunagan (1992).”[7] According to the 2003 American Animal Hospital Association’s Canine Vaccine Guidelines,
"...killed vaccines are much more likely to cause hypersensitivity reactions (e.g., immune-mediated disease)."[8]
Adverse reactions such as polyneuropathy
“resulting in muscular atrophy, inhibition or interruption of neuronal control of tissue and organ function, incoordination, and weakness,”[9] auto-immune hemolytic anemia,[10] autoimmune diseases affecting the thyroid, joints, blood, eyes, skin, kidney, liver, bowel and central nervous system; anaphylactic shock; aggression; seizures; epilepsy; and fibrosarcomas at injection sites are linked to the rabies vaccine.[11] [12] It is medically unsound for this vaccine to be given more often than is necessary to maintain immunity.
Tennessee state law, Title 68 Chapter 8, should be consistently enforced statewide. Individual veterinarians, town and county officials should not arbitrarily override the section of the law pertaining to the rabies immunization protocol for dogs. Not only is it medically inappropriate, but the practice of vaccinating dogs annually against rabies after the puppy series may violate Tennessee’s Consumer Protection Laws; and veterinarians promoting such procedures may be engaged in Unprofessional Conduct as defined in Rule 1730-1-.13 (9) under the General Rules Governing Veterinarians disseminated by the Tennessee State Board of Veterinary Medical Examiners, as well as breaching Rule 1730-1-.02 (c).
I strongly urge you to review Tennessee’s Anti-Rabies Law and draft legislation to close any legal loopholes in the language which allow for arbitrary adherence. If you have any questions or would like further information, my contact information is below.
Respectfully submitted,
Kris L. Christine
Founder, Co-Trustee
THE RABIES CHALLENGE FUND
cc: Mr. Bernie Rhoades, Tennessee Department of Health
Dr. John Dunn, Tennessee Department of Health
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[1] National Association of State Public Health Veterinarian's 2008 Compendium of Animal Rabies Prevention and Control, pp. 3, 6-7
[2] American Veterinary Medical Association 2007 RABIES VACCINATION PROCEDURES, p. 11
[3] AVMA, Principles
[4] Schultz, R.; What Everyone Needs to Know About Canine Vaccines and Vaccination Programs, October 2007, p. 3
[5] Frana, T. et als, Postmarketing Surveillance of Rabies Vaccines for Dogs to Evaluate Safety and Efficacy, Journal of the American Veterinary Medical Association April 1, 2008 issue, Vol. 232, No. 7, p. 1001
[6] IARC Monographs on the Evaluation of Carcinogenic Risks to Humans: Volume 74, World Health Organization, International Agency for Research on Cancer, Feb. 23-Mar. 2, 1999, p. 24, 305, 310.
[7] Vascelleri, M. Fibrosarcomas at Presumed Sites of Injection in Dogs: Characteristics and Comparison with Non-vaccination Site Fibrosarcomas and Feline Post-vaccinal Fibrosarcomas; Journal of Veterinary Medicine, Series A August 2003, vol. 50, no. 6, pp. 286-291(6)
[8] Report of the American Animal Hospital Association (AAHA) Canine Vaccine Task Force: 2003 Canine Vaccine Guidelines, Recommendations, and Supporting Literature, p. 16
[9] Dodds, W. Jean Vaccination Protocols for Dogs Predisposed to Vaccine Reactions, The Journal of the American Animal Hospital Association, May/June 2001, Vol. 37, pp. 211-214
[10] Duval D., Giger U.Vaccine-Associated Immune-Mediated Hemolytic Anemia in the Dog, Journal of Veterinary Internal Medicine 1996; 10:290-295
[11] American Veterinary Medical Association (AVMA) Executive Board, April 2001, Principles of Vaccination, Journal of the American Veterinary Medical Association, Volume 219, No. 5, September 1, 2001.
[12] Vascelleri, M. Fibrosarcomas 286-291(6)
TENNESSEE Rabies Laws-My Letter to Governor & Attorney General 
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