Below is a copy of the letter I faxed to Assembly Member Smyth regarding AB 2689.
PERMISSION GRANTED TO POST AND CROSS-POST
April 12, 2010
Assembly Member Cameron Smyth, Chair
Local Government Committee
State Capitol, Room 4098
Sacramento, CA 94249-0038
RE: California Rabies Bill AB 2689
Greetings Assembly Member Smyth:
Assembly Bill AB 2689 which you introduced on behalf of the City of Los Angeles is ill-advised and scientifically unfounded. The bill seeks to address a problem in the canine community that does not exist, as the California Veterinary Public Health Section’s statistics in Reported Animal Rabies by County and Species make abundantly clear: bats and other wildlife pose the major threat of rabies transmission to the public, not dogs.
According to the rabies data cited above, from 2007 until April 2, 2010, there was only 1 dog reported in California with rabies, while there were 2 cats, 442 bats, 55 fox, 107 skunks, 1 coyote, and 2 raccoons confirmed rabid. This bill authorizing the State Public Health Officer to require dogs to be vaccinated against rabies more often than once every 3 years as allowed by State law and lowering the age of required puppy vaccination to 3 months will not solve the issue of rabies in wildlife – it will, however, needlessly expose dogs of law-abiding citizens to the adverse reactions of medically unwarranted rabies boosters for which expense their owners will be charged.
Mandating rabies vaccinations more often than once every 3 years goes against the recommendations of all the national veterinary medical associations, including the American Veterinary Medical Association [1] and the Center for Disease Control’s National Association of State Public Health Veterinarian’s Compendium of Animal Rabies Prevention and Control 2008 which states that,
“Vaccines used in state and local rabies control programs should have at least a 3-year duration of immunity. This constitutes the most effective method of increasing the proportion of immunized dogs and cats in any population (50).”
Amending Section 121690 of the Health and Safety Code to require biennial or annual rabies boosters in “rabies areas” may have been intended to achieve enhanced immunity to the rabies virus by giving the vaccine more often than the federal 3-year licensing standard, but, more frequent vaccination than is required to fully immunize an animal will not achieve further disease protection. Redundant rabies shots needlessly expose dogs to the risk of adverse effects while obligating residents to pay unnecessary veterinary medical fees. 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.” This amendment may violate California’s Consumer Protection Law by requiring pet owners to pay for a veterinary medical procedure from which their animals derive no benefit and may be harmed.
The 3 year rabies vaccines currently licensed by the USDA for dogs all have a
minimum duration of immunity of 3 years, backed by challenge studies conducted according to the licensing standards set forth in USDA Title 9 Part 113.209, serological studies performed by Dr. Ronald Schultz of the University of Wisconsin School of Veterinary Medicine show a minimum duration of immunity of 7 years. According to the Center for Disease Control,
"A fully vaccinated dog or cat is unlikely to become infected with rabies…. In a nationwide study of rabies among dogs and cats in 1988,….no documented vaccine failures occurred among dogs or cats that had received two vaccinations. " [2]
Immunologically, the rabies vaccine is the most potent of the veterinary vaccines and associated with significant adverse reactions such as polyneuropathy
“resulting in muscular atrophy, inhibition or interruption of neuronal control of tissue and organ function, incoordination, and weakness,”[3] auto-immune hemolytic anemia,[4] 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 all linked to the rabies vaccine.[5] [6] It is medically unsound for this vaccine to be given more often than is necessary to maintain immunity.
A “killed” vaccine, the rabies vaccine contains adjuvants to enhance the immunological response. In 1999, the World Health Organization
“classified veterinary vaccine adjuvants as Class III/IV carcinogens with Class IV being the highest risk,"[7] 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 stated,
“In both dogs and cats, the development of necrotizing panniculitis at sites of rabies vaccine administration was first observed by Hendrick & Dunagan (1992).” [8] According to the 2003 AAHA Guidelines,
"...killed vaccines are much more likely to cause hypersensitivity reactions (e.g., immune-mediated disease)." [9]
Lowering the age at which puppies are required to have their first rabies shot from 4 months to 3 months is counterproductive. Puppies are finishing up their other vaccinations (distemper, hepatitis, parvo) at 12 weeks (3 months) of age, and adding a rabies vaccine into the mix will not only increase the likelihood of adverse reactions, but also the probability that the vaccine components will interfere with each other and neutralize or negate the desired immunological response. Contributing to the chance that rabies vaccination at 3 months may not be effective is the continued presence of maternal antibodies. According to the 2006 American Animal Hospital Association's Canine Vaccine Guidelines, the most common reason for vaccination failure is
"the puppy has a sufficient amount of passively acquired maternal antibody (PAMA) to block the vaccine......" They elaborate by reporting that at the ages of 14 to 16 weeks of age,
"PAMA should be at a level that will not block active immunization in most puppies (>95%) when a reliable product is used." After the age of 16 weeks (4 months), the maternal antibodies are reduced to a level at which they should not reduce the rabies vaccine's effectiveness.
By lowering the age to 3 months in "rabies areas," not only will puppies be put at increased risk for adverse reactions, but they will also be less likely to mount the desired immunological response because of passively acquired maternal antibodies and the impact of the other puppyhood vaccinations.
On behalf of The Rabies Challenge Fund and the many concerned California pet owners who have requested our assistance, I strongly urge you to withdraw AB 2689 in its entirety.
Sincerely,
Kris L. Christine
Founder, Co-Trustee
THE RABIES CHALLENGE FUND
www.RabiesChallengeFund.org
ledgespring@lincoln.midcoast.com
cc: Dr. W. Jean Dodds
Dr. Ronald D. Schultz
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[1] American Veterinary Medical Association, Veterinary Biologics, June 2007, “Rabies Vaccination Procedures”
[2] Immunization Practices Advisory Committee, Rabies Prevention—United States, 1991 Recommendations of the Immunization Practices Advisory Committee, Center for Disease Control Morbidity and Mortality Weekly Report March 22, 1991/40(RR03);1-19
[3] 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
[4] Duval D., Giger U.Vaccine-Associated Immune-Mediated Hemolytic Anemia in the Dog, Journal of Veterinary Internal Medicine 1996; 10:290-295
[5] 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.
[6] 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.
[7] 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.
[8] 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.
[9] American Animal Hospital Association Canine Vaccine Task Force. 2003 Canine Vaccine Guidelines, Recommendations, and Supporting Literature, 28pp. and ibid. 2006 AAHA Canine Vaccine Guidelines, Revised, 28 pp.
URGENT--Defeat CA Rabies Bill AB 2689
Both now have dilated cardiomyopathy and are 11 and 12 years old--Doubt if they will make it for that 6th shot! In my mind I always figured that 5th shot pretty much puts the last nail in the coffin. Thanks again for all your efforts.
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