May 10, 2006
Dr. Jamie Snow
Wyoming Department of Public Health
Re: Wyoming’s New Euthanasia Rule
Greetings Dr. Snow:
In light of current scientific research, Wyoming’s rabies rule requiring mandatory euthanasia for cats and dogs deemed “unvaccinated” is unjustified. While I recognize that you have a mandate to protect public health, your new rule will needlessly take the lives of countless pets which are actually immune to rabies despite being overdue for or medically exempt from rabies boosters.
Under the new rule, it appears companion animals overdue for a rabies booster by a week or month (according to vaccine manufacturer’s recommendations) would be deemed “unvaccinated,” disregarding the fact that study results published in 1992 by Michel Aubert’s research team demonstrated that dogs were immune to a rabies challenge 5 years post-vaccination (see text of that study below). Serological studies done by Dr. Ronald Schultz of the University of Wisconsin School of Veterinary Medicine show that dogs have antibody titer counts at levels known to confer immunity to rabies 7 years post-vaccination. Based on the scientific research, any dog euthanized in Wyoming under this rule within 5 to 7 years of rabies vaccination will die needlessly.
On Page 13 of the The American Animal Hospital Association's (AAHA’s) 2003 Canine Vaccine Guidelines (accessible online at Leeburg Training http://www.leerburg.com/special_report.htm), it states: “The minimum DOI for killed rabies vaccine based on challenge studies is 3 years; based on antibody titers, it is considered to be up to 7 years [Table 2].”Vaccine manufacturers are not required by FDA to demonstrate long-term duration of immunity in order to license their products. According to the American Veterinary Medical Association’s Principles of Vaccination (http://www.avma.org/issues/vaccination/vaccination.asp), “..revaccination frequency recommendations found on many vaccine labels …does not resolve the question about average or maximum duration of immunity [Page 2] and.may fail to adequately inform practitioners about optimal use of the product…[Page 4] .” This holds true for rabies vaccines, as Aubert’s and Schultz’s studies demonstrate that rabies vaccination confers minimum duration of immunity in dogs far beyond vaccine manufacturers’ 3 year booster recommendation.
In conversations with rabies vaccine researchers, I have been told that the Center for Disease Control has no recorded cases of any dog contracting rabies after receiving 2 rabies vaccinations. The implication is that 2 rabies vaccinations confer a lifetime of immunity. As a veterinarian, your own experience being vaccinated against rabies indicates the same. The Populations at Risk for Rabies sheet from Chiron Corporation, manufacturers of the RabAvert rabies vaccines for humans is accessible at http://www.rabavert.com/risk.html. Their pre-exposure vaccination recommendation for veterinarians, who are at greater risk than the general population for contracting rabies because their profession brings them into physical contact with potentially rabid animals, is for a “Primary course. No serologic testing or booster vaccination.” In other words, after the initial series of rabies vaccinations, it is not recommended that veterinarians receive further boosters or serological testing, they are considered to be immune to a challenge. AAHA’s 2003 Canine Vaccine Guidelines (accessible online at Leeburg Training http://www.leerburg.com/special_report.htm) states on Page 18 that “There is no indication that the immune system of canine patients functions in any way different from the human immune system. In humans, the epidemiological vigilance associated with vaccination is extremely well-developed and far exceeds similar efforts in animals whether companion or agricultural. This vigilance in humans indicates that immunity induced by vaccination in humans is extremely long lasting and, in most cases, life-long.” This strongly suggests that, like the human rabies vaccine, the canine rabies vaccine also provides life-long immunity.
The science reflects that Wyoming will euthanize immune dogs under the new euthanasia rule.
I strongly urge you to re-examine this policy and consult with the world’s leading authorities on veterinary vaccines -- Dr. W. Jean Dodds of Hemopet and Dr. Ronald Schultz of the University of Wisconsin School of Veterinary Medicine -- about modifying this scientifically unwarranted euthanasia rule.
Ensuring that Wyoming’s beloved companion animals are not needlessly euthanized justifies closer scrutiny of this rule. Sincerely,
Kris L. Christine
The Rabies Challenge Fund Charitable Trust
Alna, ME 04535