January 15, 2012

MISSOURI: Rabies Challenge Fund Proposes Rabies Medical Exemption

Senator Dan Brown has introduced a rabies bill, SB 566, into the Missouri legislature for consideration. This bill has been assigned to the Agriculture, Food Production & Outdoor Resources Committee.

While the state legislature considers setting state guidelines for rabies vaccination of all dogs and cats, the Rabies Challenge Fund has submitted a letter urging lawmakers to insert a medical exemption clause into this bill.

It states that rabies vaccine is intended for use in only healthy animals for efficacy reasons. Even a slight elevation in temperature can thwart the efficacy of the vaccine. Furthermore, there is strong evidence that the administration of this vaccine in the very sick or senior family pets can be extremely damaging or even deadly. 

The conflict between periodic mandatory rabies vaccination in the interest of public health and the desire of pet owners to protect companion animals sets up conditions for unintended consequences. Pet owners may choose to disobey the law and refuse to license their animals thus raising concerns for public health. When animals in frail health are exempted, no such conflict exists.

This rabies medical exemption clause insures that dogs or cats under the care of a licensed veterinarian for acute or chronic disease are excused from mandatory rabies vaccination until their health is judged sufficiently robust to withstand the challenge of a potent biologic agent.

So far 14 states have included medical exemption clauses for sick animals in their rabies prevention and control ordinances. There has been no increase in the reported cases of rabies in those states.

What You Can Do

Missouri residents  are urged to contact the bill sponsor and the Chair of the Agriculture Committee asking them to place a medical exemption clause into the language of the bill and to vote that the bill "ought to pass." Please ask all of the Missouri pet owners you know to do the same. 

Senator Dan Brown (573) 751-5713 Dan.Brown@senate.mo.gov Senator Brian Munzlinger, Chair of the Agriculture Committee (573) 751-7985 Brian.Munzlinger@senate.mo.gov


January 14, 20012

Senator Dan Brown
Senator Brian Munzlinger

RE: SB 566 Bill Requiring Dogs and Cats to be Vaccinated Against Rabies

Greetings Senators Brown and Munzlinger:

The Rabies Challenge Fund supports passage of the proposed language in SB 566 which would amend Section A, Chapter 322 RSMo, Subsection 322.035 (5) to require that dogs and cats be immunized against rabies in accordance with the current recommendations of the Centers for Disease Control’s (CDC) National Association of State Public Health Veterinarian’s (NASPHV) Rabies Compendium.

Also in accordance with the Rabies Compendium, we strongly urge the Committee to insert a rabies medical exemption clause into the language of this bill.

The Rabies Compendium directs that “All vaccines must be administered in accordance with the specifications of the product label or package insert,” and rabies vaccine labels specify that they are for healthy animals. In addition to limiting its rabies vaccine for use in healthy animals, Pfizer’s Defensor 3 label cautions that: “[a] protective immune response may not be elicited if animals are incubating an infectious disease, are malnourished or parasitized, are stressed due to shipment or environmental conditions, are otherwise immunocompromised.”

The states of Alabama, California, Colorado, Connecticut, Florida, Maine, Massachusetts, New Hampshire, New Jersey, New York, Oregon, Vermont, Virginia, and Wisconsin all have medical exemption clauses for sick animals in their rabies immunization laws/regulations.

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,”[1] auto-immune hemolytic anemia,[2] thrombocytopenia, anorexia, regional lymphadenomegaly, cutaneous ischemic vasculopathy;[3] 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.[4] [5]

It is medically unsound for this vaccine to be given to any animal deemed unhealthy by a veterinarian.

A medical exemption clause would allow Missouri veterinarians to write waivers for animals whose medical conditions (such as those with cancer, kidney/liver failure, hemolytic anemia, thrombocytopenia, grand mal seizures, and chronic autoimmune disorders) would be exacerbated by rabies vaccination.

The State of Maine inserted such an exemption for dogs into their 3 year rabies protocol, 7 M.R.S.A., Sec. 3922(3), which became effective in April 2005, and not one rabid dog has been reported in the nearly 7 years since.

Maine’s exemption language is 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. Without a provision for medical exemptions in Section A, Chapter 322 RSMo, Missouri’s rabies immunization requirement would thrust an ethical quandary on veterinarians with seriously ill patients -- they must either violate their Veterinarian’s Oath and administer a rabies vaccine contrary to sound medical practice and against the vaccine manufacturer’s labeled instructions, or recommend their clients break the law by not immunizing their unhealthy pets against rabies.

Being compelled by law to vaccinate sick dogs and cats against rabies in order for their clients to comply with the statute also puts Missouri’s veterinarians at risk of being held liable for any adverse reactions the animals may suffer after administering a vaccine inconsistently with the labeled directions.

Owners of critically ill dogs may choose not to comply with the law rather than jeopardize the lives of their pets and then fail to license their dogs to avoid detection.

On behalf of The Rabies Challenge Fund Charitable Trust and Missouri pet owners, we urge you to insert a medical exemption clause in Senate Bill 566 and to vote that the bill ought to pass.

You may contact me at the number below if you would like any scientific data on the rabies vaccine or if you have any questions.

Sincerely, Kris L. Christine

Dr. W. Jean Dodds
Dr. Ronald Schultz
Missouri Legislature & Agriculture Committee

[1] 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 [2] Duval D., Giger U.Vaccine-Associated Immune-Mediated Hemolytic Anemia in the Dog, Journal of Veterinary Internal Medicine 1996; 10:290-295
[3] American Animal Hospital Association, 2011 Canine Vaccination Guidelines, p. 20
[4] 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.
[5] 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.

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