September 07, 2007

All Dogs Get Rabies Shots or Go to Heaven

Tomorrow I am releasing news regarding the proposed changes to 25 TAC §§169.21 - 169.34, Rabies Rules.

Of necessity, there are several worrisome issues that I omitted. After six pages, content was getting too long to be considered a news release. However, other proposed revisions deserve attention:

Service Dogs & Therapy Dogs

In proposed rabies rules, Texas makes no mention of "Service Dogs" and eliminates any reference to "Therapy Dogs" in the Texas Administrative Code governing rabies prevention and control.

[ (27) Therapy dog--A dog that helps a person with a diagnosed emotional disorder for whom a letter has been issued by a physician stating that the removal of the animal would be detrimental to the person's emotional health. ]

According to the American Disabilities Act (federal) any dog assisting a person with a disability is considered a service dog. Service dogs are entitled to freely access buildings and transportation (buses, trains, planes). It is a dog that has been individually trained to do work or perform tasks for the benefit of an individual with a disability.

* Assistance in a Medical Crisis – Service dogs are trained to retrieve medications, beverages and telephones. They can bark for help, answer a door bell and even dial 911 on special K9 speaker telephones.

* Treatment Related Assistance – These special animals can be trained to deliver messages, remind individuals to take medications as specific times, assist with walking as well as alerting sedated individuals to doorbells, phones or smoke detectors.

* Assistance Coping With Emotional Overload – Service dogs can be taught to prevent others from crowding their owner. They can be taught to recognize a panic attack and nuzzle a distraught owner to help with calming.

* Security Enhancement Tasks – These canines are often trained to check the house for intruders. They can turn on lights and open doors. They can assist with leaving a premises during an emergency.

"Therapy dog" is a technical definition assigned to dogs specialized in Animal Assisted Therapy, a formal treatment program, usually involving one particular animal and handler assigned to one particular client. The handler and the health care provider consult on specific goals to be accomplished, and plan how to accomplish those goals.

Visiting with animals can help people feel less lonely, and less depressed. Visits from dogs can provide a welcome change from routine, or the renewal of old friendships. People become more active and responsive both during and after visiting with animals.

An animal visit can offer entertainment, or a welcome distraction from pain and infirmity. People often talk to the dogs, and share with them their thoughts and feelings and memories. Animal visits provide something to look forward to. Stroking a dog or cat can reduce a person's blood pressure. Petting encourages use of hands and arms, stretching and turning.

As a result of their great benefits to the public, therapy dogs are widely used in Health or Life Sciences, including Human medicine, pre-med, medical school; Nursing programs; Therapy programs; Diagnostic professions; Social science professions; Laboratory field professions: Discovery or Curative; Animal medicine, pre-vet, Veterinary School; Animal Technology professions; Animal Diagnostic and Laboratory professions.

By omitting language specific to service dogs and therapy dogs, interpretation of the law is left up to local jurisdiction. What can occur when a family pet, service dog or therapy dog is suspected of exposure to rabies?

The amendment to §169.22 5 (C) The time elapsed since the most recent vaccination has not exceeded the recommended interval for booster vaccination as established by the manufacturer [ label recommendations of the vaccine ].”

As written, it appears that any dog or cat that is overdue for rabies re-vaccination by a week or month (according to the interval of the drug the veterinarian recommends) would be deemed “unvaccinated” because it has not been revaccinated before its rabies inoculation “expires.”

In the case of suspected rabies exposure, a dog with a current vaccination is confined and observed for 10 days. A dog whose vaccination has lapsed is considered "unvaccinated;" it is seized, impounded and confined for three months at the owner's expense. In other states the quarantine period is six months, $3000. If the owner cannot pay, the dog is destroyed immediately.

I personally have a hard time imagining how a disabled person will survive this. It is also challenging to imagine a dog that is sick or has chronic health issues will survive this. I know for a fact that I could not.

Now I do not imply that animal control officers are incompetent to understand the importance of service dogs or that they have no feeling for animals; but they are not trained to use discretion. And there is sufficient evidence in Texas and nationwide to suggest that nothing should be left to chance when it comes to dogs we value as members of our family and valued assistants to disabled family members.

Moreover, if TDHS is responsible to clarify the law, they need to do a better job. As it stands, all dogs - including service dogs and therapy dogs - are required to get rabies revaccination on the dot, or they are at risk of going to heaven.

Comments on the proposal may be submitted to Tom Sidwa, DVM, Department of State Health Services, Community Preparedness Section, Zoonosis Control Branch, 1100 West 49th Street, Austin, Texas 78756, or by email to Comments will be accepted for 30 days following publication of the proposal in the Texas Register.
You can review the proposed revisions online:

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