February 26, 2009

ACTION ALERT: Help Alabama Reform Rabies Laws

Kris Christine, co -Trustee of the Rabies Challenge Fund, writes that Alabama pet owners have begun lobbying legislators to conform the annual rabies booster requirement for dogs and cats to the national standard of three years. Alabama is currently the only U.S. State that mandates rabies vaccine annually.

A copy of her letter to the Alabama Public Health Veterinarian and State Health Officer on behalf of The Rabies Challenge Fund www.RabiesChallengeFund.org and Alabama pet owners follows.

February 25, 2009


Dr. Dee Jones Dr. Donald E. Williamson
State Public Health Veterinarian State Health Officer
Department of Health Department of Health
201 Monroe Street, P.O. Box 303017 201 Monroe Street, P.O. Box 303017
Montgomery, AL 36104 Montgomery, AL 36104

RE: Alabama Code Title 3 Chapter 7A-2--Dogs and Cats to be Immunized

With the recent passage of Act 159 paving the way for Arkansas to conform to the national 3 year rabies immunization standard, Alabama has become the only state in the country to adhere to a now outdated annual rabies vaccination requirement for dogs and cats.

Title 3 Chapter 7A-2 of the Alabama Code mandating annual rabies vaccinations is counter to the recommendations of 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).” They specifically warn that, “[n]o laboratory or epidemiologic data exist to support the annual or biennial administration of 3- or 4-year vaccines following the initial series.”

It is recognized that most, if not all, currently licensed annual rabies vaccines given annually are actually 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 of the University of Wisconsin School of Veterinary Medicine, whose canine vaccine studies form a large part of the scientific base for the 2003 and 2006 American Animal Hospital Association’s (AAHA) Canine Vaccine Guidelines, as well as the World Small Animal Veterinary Association’s 2007 Vaccine Guidelines, “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.” [2]

Alabama’s code requiring annual rabies boosters 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 annual rabies shots needlessly expose dogs and cats 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.” The current rabies immunization code may violate Title 8 Section 8-19-5 of Alabama’s Consumer Protection Law by requiring pet owners to pay for a yearly veterinary medical procedure from which their animals derive no benefit and may be harmed.

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]

The labels on rabies vaccines state that they are for “the vaccination of healthy cats, dogs…,” and there are medical conditions for which vaccination can jeopardize the life or well-being of an animal. A medical exemption clause inserted into Title 3 Chapter 7A-2 would allow veterinarians to write waivers for animals for whom medical conditions preclude vaccination. The State of Maine inserted such an exemption into the 3 year rabies protocol, 7 M.R.S.A., Sec. 3922(3), it adopted in 2004 as follows:

A. A letter of exemption from vaccination may be submitted for licensure, if a medical reason exists that precludes the vaccination of the dog. Qualifying letters must be in the form of a written statement, signed by a licensed veterinarian, that includes a description of the dog, and the medical reason that precludes vaccination. If the medical reason is temporary, the letter shall indicate a time of expiration of the exemption.

B. A dog exempted under the provisions of paragraph 5 A, above, shall be considered unvaccinated, for the purposes of 10-144 C.M.R. Ch.251, Section 7(B)(1), (Rules Governing Rabies Management) in the case of said dog’s exposure to a confirmed or suspect rabid animal.

On behalf of The Rabies Challenge Fund and the many Alabama pet owners who have contacted us with concerns about the state’s annual rabies booster requirement for dogs and cats, we strongly urge you to change Title 3 Chapter 7A-2 of the Alabama Code to conform to the 3-year national standard recommended by the Center for Disease Control’s National Association of State Public Health Veterinarians and endorsed by the American Veterinary Medical Association. We also respectfully request that medical exemption language be inserted into the code.

Sincerely,
Kris L. Christine
Founder, Co-Trustee
THE RABIES CHALLENGE FUND
www.RabiesChallengeFund.org

cc: Governor Bob Riley

Attorney General Troy King
Alabama Legislature
Dr. Tony Frazier, State Veterinarian
Dr. Terry Slaten, Associate State Veterinarian
Dr. W. Jean Dodds
Dr. Ronald D. Schultz

[1] American Veterinary Medical Association, Veterinary Biologics, June 2007, “Rabies Vaccination Procedures”
[2] Schultz, Ronald D.; What Everyone Needs to Know about Canine Vaccines, October 2007, http://www.puliclub.org/CHF/AKC2007Conf/What%20Everyone%20Needs%20to%20Know%20About%20Canine%20Vaccines.htm
[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.

What You Can Do to Help:

Contact Alabama legislators and ask them to introduce legislation to change Alabama Code Title 3 Chapter 7A-2 to conform to the three-year protocol recommended by the National Association of State Public Health Veterinarians Rabies (NASPHV) Compendium, including a medical exemption for sick and senior animals. Ask your pet-owning friends to do the same.

Alabama Legislature: You can find contact information for Senator and Representative at the following link: http://www.legislature.state.al.us/


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