Notice: California dog owners

[Kris Christine]

NOTICE: CALIFORNIA DOG OWNERS -- On 12/21/09 Dr. Ben Sun (916) 552-9744, Interim Chief of California's Veterinary Public Health Section, designated ALL COUNTIES in California as "rabies areas" http://www.cdph.ca.gov/HealthInfo/di...ion_Letter.pdf.

The declaration states: "The Director of the Department of Public Health has declared all counties in California as 'rabies areas' in 2010. This declaration is based on the ongoing cyclic nature of rabies in California wildlife, and the resulting threat of exposure to domestic animals, livestock, and humans."

An April 5, 2010 amendment to AB2000 AB 2000 Assembly Bill - AMENDED which seeks to add a medical exemption clause for sick dogs in designated "rabies areas," would included the following language:

" (2) A dog exempt from the canine antirabies vaccination shall be kept quarantined as directed by the local health officer, until the
dog's medical condition has resolved and the administration of the canine antirabies vaccine occurs."

This bill is currently in the Senate Rules Committee for consideration. The phone number for the California Senate Rules Committee is (916) 651-4120 and the Chair of the Committee is Senator Darrell Steinberg e-mail: Senator.Steinberg@senate.ca.gov Phone: (916) 651-4006

Under current law, the Department of Public Health is authorized to require annual rabies vaccinations in designated "rabies areas," which includes ALL counties in California for 2010. With the passage of AB2000 as amended on April 5th, dogs with medical exemptions would be required to be quarantined, which could be in an off-site pound or facility as determined by the local health officer, until their medical condition resolves or they are given a rabies vaccine.

[Kris Christine]

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[Kris Christine]

PERMISSION GRANTED TO POST AND CROSS-POST

At the bottom of this post is a copy of the letter I sent on behalf of The Rabies Challenge Fund on this issue.

What You Can Do to Help

Call the Senate Rules Committee and call or send an e-mail to all its members telling them to withdraw Paragraph (2) of the amendment pertaining to quarantining medically exemption animals and strike language in Section 121690 (b) of the law authorizing the Health Department to impose annual or biennial rabies vaccinations in "rabies areas."

The phone number for the California Senate Rules Committee is (916) 651-4120
Chair of the Committee is Senator Darrell Steinberg e-mail: Senator.Steinberg@senate.ca.gov (916) 651-4006
Vice-chair Sam Aanestad Senator.Aanestad@senate.ca.gov (916) 651-4004
Gilbert Cedillo Senator.Cedillo@senate.ca.gov (916) 651-4022
Robert Dutton Senator.Dutton@senate.ca.gov (916) 651-4031
Jenny Oropeza Senator.Oropeza@senate.ca.gov (916) 651-4028
Bill Co-Sponsor Assembly Member Curt Hagman Assemblymember.Hagman@assembly.ca.gov (916) 319-2060

Letter from The Rabies Challenge Fund

May 15, 2010

Senator Darrell Steinberg, Chair
Senate Rules Committee
State Capitol, Room 205
Sacramento, CA 94248-0001

RE: Amended Rabies Bill AB2000

Greetings Senator Steinberg:

The Rabies Challenge Fund Charitable Trust respectfully requests that the Senate Rules Committee withdraw Paragraph (2) of the April 5th amendment to AB2000 which mandates that “A dog exempt from the canine antirabies vaccination shall be kept quarantined, as directed by the local health officer, until the dog's medical condition has resolved and the administration of the canine antirabies vaccine occurs.” This amendment seeks to address a public health threat which does not exist in the canine community, and which will, if passed, pose a life-threatening risk to dogs whose health is already compromised.

California’s Department of Public Health (CDPH) statistics clearly demonstrate that bats and other wildlife pose the greatest rabies threat to the public, not dogs. From 2001 through 2008, the CDPH reported 2 cases of human rabies contracted in the state, both of which were transmitted by bats. Further, according to data contained in the annual Reported Animal Rabies by County and Species issued by the CDPH, from the period of 2001 through May 7, 2010, (throughout which time all counties had been designated “rabies areas”), dogs were among the species with the least number of rabies cases in California. During the cited surveillance period 1,440 bats, 462 skunks, 74 foxes, 11 cats, and 5 dogs were reported as rabid.

The Center for Disease Control documented 32 cases of domestically-contracted cases of human rabies in the U.S. from 1995 through 2008 – 30 illnesses were transmitted by bats, 1 by fox, and 1 by raccoon. Since 1995, there have been no reported cases of human rabies from exposure to an indigenous dog in this country, and no demonstrated need exists for the California Legislature to pass harsh rabies regulations targeting dogs.

Further, The Rabies Challenge Fund asks that the Committee strike the following bolded, underlined language in the current law under Section 121690 (b) which is reiterated in AB2000 as follows: “(b) Every dog owner, after his or her dog attains the age of four months, shall, at intervals of time not more often than once a year, as may be prescribed by the department, procure its vaccination by a licensed veterinarian with a canine antirabies vaccine approved by, and in a manner prescribed by, the department, unless a licensed veterinarian determines, on an annual basis, that the dog may have a potentially lethal reaction to the canine antirabies vaccine. is currently immune compromised or has a documented medical record of a preexisting condition, including, but not limited to, an immune mediated disease, or a serious adverse reaction to a prior canine antirabies vaccine.”

Mandating rabies vaccinations more often than once every 3 years, even in designated “rabies areas,” 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.”

Section 121690 (b) of the Health and Safety Code 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 section of the law requiring 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.”

The 3 year rabies vaccines currently licensed by the USDA for dogs all have a minimum duration of immunity of 3 years proven by challenge studies (the definitive standard in vaccine research) 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]

On behalf of The Rabies Challenge Fund Charitable Trust and the many concerned California pet owners who have requested our assistance, I strongly urge you to withdraw Paragraph (2) of the April 5th amendment to AB2000 and strike the language in the current law cited in the bill authorizing the CDPH to impose annual or biennial rabies boosters in “rabies areas.”

Sincerely,
Kris L. Christine
Founder, Co-Trustee
THE RABIES CHALLENGE FUND
Duration of Immunity Study for Rabies Vaccine - Rabies Challenge Fund
ledgespring@lincoln.midcoast.com

cc: W. Jean Dodds, DVM
Ronald D. Schultz, PhD
Assembly Member Curt Hagman

--------------------------------------------------------------------------------

[Kris Christine]

[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.

[Kris Christine]

UPDATE: Assembly Member Curt Hagman and his staff are responding to the public outcry over the quarantine clause in AB 2000 and working hard to find suitable language to substitute.

Dog Owners Say Rabies Vaccination Exemption Could Lead To Quarantines, by Lonnie Wong Fox 40 May 20, 2010http://www.fox40.com/news/headlines/ktxl-tv-rabiesvaccinationrestrictions,0,5632202.story

"That amounts to a lifetime quarantine for her dog.

But Hagman says that was not his intention. He says he's trying to remove the word "quarantine" from the bill so that animals in Louie's situation would not be confiscated."

[Kris Christine]

If the link above doesn't work by clicking on it, copy and paste it into the browser. Here it is again: Dog Owners Say Rabies Vaccination Exemption Could Lead To Quarantines - KTXL

[Kris Christine]

AB 2000 -- I received the following e-mail from Assembly Member Hagman last night:

Thank you for contacting me to express your concerns over paragraph 2 in AB 2000, Molly’s Bill, which states that a dog exempt from the canine anti-rabies vaccination shall be kept quarantined as directed by the local health officer, until the dog's medical condition has resolved and the administration of the canine anti-rabies vaccine occurs.

When sponsoring this bill, it was definitely not my intent to cause pet owners to be forced to quarantine their animals for an indeterminable and possible indefinite amount of time. AB 2000’s main goal is to provide anti-rabies vaccination flexibility for dogs with pre-existing health problems. It will create an exemption from anti-rabies vaccine for dogs when a licensed veterinarian determines they are likely to have lethal reactions to the vaccine.

I believe that the anti-rabies vaccine is a very important safety and health measure, but it is common-sense for us to create exemptions for those few instances when the health of the canine could be severely affected by the vaccine. Dogs are our best friends, even members of our family, and we should make sure that we are flexible enough to keep them safe.

Thank you for bringing your concerns to my attention. My staff and I are working on modifying the wording of this bill to clarify its original intent. When this matter has been resolved, please join me in supporting AB 2000 so we can move forward in further giving protection to our family pets.

Thank you. Please do not hesitate to call me at 916-319-2060 should you have any additional questions or concerns.

Sincerely

Assemblyman Curt Hagman
District 60

[Kris Christine]

UPDATE California Rabies Bill AB 2000 -- Jan Rasmusen, a Friend of The Rabies Challenge Fund, contacted Saulo Londono in AM Hagman's office Tuesday (5/25/10). Mr. Londono sent her an e-mail which said:

"We have indeed come to the understanding that we will remove Paragraph 2. I have put the request into Leg Counsel to have language written as such and I expect to receive that before the week is over. I will then immediately pass the amendment to the Senate Health Committee, and it is up to them to put it in print. With that said, I think the final language should be available by middle of next week. I have requested a hearing for this bill on June 23rd, at 1:30pm, in the Senate Health Committee. "

We are waiting to see the revised bill in print.

[Kris Christine]

REVISED CALIFORNIA AB 2000 -- PLEASE SUPPORT

The quarantine clause in AB 2000 inserting a medical exemption in California's rabies law has been removed http://www.leginfo.ca.gov/pub/09-10/...ed_sen_v97.pdf , and The Rabies Challenge Fund is asking dog owners to voice their support for this bill. The bill has a hearing set for June 23rd in the Senate Health Committee. Please contact the members of the Senate Health Committee below and ask them to pass the bill.

PERMISSION GRANTED TO CROSS-POST

STANDING Committee

Senate Health Committee Phone: (916) 651-4111

Elaine Alquist (Chair) senator.alquist@sen.ca.gov Phone: (916) 651-4013, Fax: (916)-324-283
Tony Stickland (Vice-Chair) senator.strickland@sen.ca.gov Phone: (916) 651-4019 Fax: (916) 324-7544
Samuel Aanestad Senator.Aanestad@senate.ca.gov Phone: (916) 651-4004 Fax: (916) 445-7750
Gilbert Cedillo Phone: (916) 651-4022 Fax: (916) 327-8817
Dave Cox senator.cox@senate.ca.gov Phone: (916) 651-4001 Fax: (916) 324-2680
Mark Leo senator.leo@senate.ca.gov Phone: (916) 651-4003 Fax: (916) 445-4722
Gloria Negrete McLeod senator.mcleod@senate.ca.gov Phone: (916) 651-4032 Fax: (916) 445-0128
Fran Pavley senator.pavley@senate.ca.gov Phone: (916) 651-4023 Fax: (916) 324-4823
Gloria Romero senator.romero@senate.ca.gov Phone: (916) 651-4024 Fax: (916) 445-0485
Bill Co-Sponsor Assembly Member Curt Hagman Assemblymember.Hagman@assembly.ca.gov Phone: (916) 319-2060 Fax: (916) 319-2160

[Kris Christine]

Letter from The Rabies Challenge Fund

June 4, 2010

Senator Elaine K. Alquist, Chair
Senate Health Committee
State Capitol, Room 5080
Sacramento, CA 95814

RE: Revised Rabies Medical Exemption Bill AB 2000

Greetings Senator Alquist:

The Rabies Challenge Fund strongly supports the June 2nd revision of AB 2000, which will insert a medical exemption clause for dogs into Section 121690 of California’s Health and Safety Code, and we respectfully request that the Senate Health Committee vote to support this bill.

Sincerely,

Kris L. Christine
Founder, Co-Trustee
THE RABIES CHALLENGE FUND CHARITABLE TRUST
Duration of Immunity Study for Rabies Vaccine - Rabies Challenge Fund
ledgespring@lincoln.midcoast.com

cc: W. Jean Dodds, DVM
Ronald D. Schultz, PhD
Assembly Member Curt Hagman

[Kris Christine]

URGENT ACTION NEEDED -- On June 8th Monica Wagoner, the Deputy Director of the California Department of Public Health (916) 440-7502, sent a letter to legislators opposing the revised medical exemption bill AB 2000. Her letter states: "There is no scientific evidence that canine rabies vaccines are associated with severe or a high rate of vaccination reactions. ...Modern canine rabies vaccines are safe ...."

PLEASE make a brief call or send a short e-mail to the Senate Health Committee members below and tell them you support "Molly's Bill" AB 2000 and ask everyone you know to do the same. Opposition to this bill from the Health Department will require a very strong show of public support to overcome.

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Senate Health Committee Members

Elaine Alquist (Chair) senator.alquist@sen.ca.gov (916) 651-4013
Tony Stickland (Vice-Chair) senator.strickland@sen.ca.gov (916) 651-4019
Samuel Aanestad Senator.Aanestad@senate.ca.gov (916) 651-4004
Gilbert Cedillo (916) 651-4022
Dave Cox senator.cox@senate.ca.gov (916) 651-4001
Mark Leo senator.leo@senate.ca.gov (916) 651-4003
Gloria Negrete McLeod senator.mcleod@senate.ca.gov (916) 651-4032
Fran Pavley senator.pavley@senate.ca.gov (916) 651-4023
Gloria Romero senator.romero@senate.ca.gov (916) 651-4024

[Kris Christine]

Clarification:This bill will not change anything regarding the frequency of rabies vaccinations required, it will only add a medical exemption clause for dogs who are too ill to be vaccinated.

The current law already authorizes the Public Health Officer to impose annual rabies boosters in "rabies areas," which all counties in the state have been annually declared to be since at least 2001. As far as I know, the Health Department has not exercised that power by imposing annual rabies boosters in the last few years. In order to remove that authorization, another bill will have to be introduced in the next legislative session.

There are many precious canine lives depending on this medical exemption being being passed into California law, and now that the mandatory quarantine requirement for exempted dogs, which the California Department of Public Health (CDPH) and the California Veterinary Medical Association (CVMA) requested, has been removed from the bill, The Rabies Challenge Fund is fully supporting passage of this bill. We urge anyone concerned to take immediate action and call or e-mail the Senators on the Health Committee and ask them to pass "Molly's Bill", AB 2000. Once the mandatory quarantine clause, which the CDPH and CVMA had requested, was removed from AB 2000, they decided to oppose the bill. Government agencies carry a great deal of weight, and it is essential that there be a large voice of public support for this bill to get it passed in the face of such powerful opposition, so please call all the members of the Senate Health Committee and tell them to support "Molly's Bill", AB 2000.

Below again is the contact information for the Senate Health Committee which has a hearing set for AB 2000 on June 23rd. Included are the e-mail addresses of the specific legislative aids who are working on this bill:

Elaine Alquist (Chair) senator.alquist@sen.ca.gov Phone: (916) 651-4013, Fax: (916)-324-0283
Tony Stickland (Vice-Chair) senator.strickland@sen.ca.gov Phone: (916) 651-4019 Fax: (916) 324-7544
Samuel Aanestad Senator.Aanestad@senate.ca.gov legislative aid: julie.nystrom@sen.ca.gov Phone: (916) 651-4004 Fax: (916) 445-7750
Gilbert Cedillo legislative aid: luis.quinonez@sen.ca.gov Phone: (916) 651-4022 Fax: (916) 327-8817
Dave Cox senator.cox@senate.ca.gov legislative aid: kirk.cowgill@sen.ca.gov Phone: (916) 651-4001 Fax: (916) 324-2680
Mark Leo senator.leo@senate.ca.gov legislative aid: sara.rogers@sen.ca.gov Phone: (916) 651-4003 Fax: (916) 445-4722
Gloria Negrete McLeod senator.mcleod@senate.ca.gov Phone: (916) 651-4032 Fax: (916) 445-0128
Fran Pavley senator.pavley@senate.ca.gov legislative aid: elise.thurau@sen.ca.gov Phone: (916) 651-4023 Fax: (916) 324-4823
Gloria Romero senator.romero@sen.ca.gov legislative aid: rae.flores@sen.ca.gov Phone: (916) 651-4024 Fax: (916) 445-0485

[Kris Christine]

The following is Dr. W. Jean Dodds' letter of support for "Molly's Bill", AB 2000, and her refutation of the California Department of Public Health's opposition:

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June 14, 2010

The Honorable Curt Hagman
California State Assembly
State Capitol, Room 4116
Sacramento, CA 95814

Re: CA Assembly Bill AB2000

Dear Assembly Member Hagman:

I learned today from your staff person, Saulo Londono, that the California Department of Public Health (CDPH) has officially opposed your sponsored bill AB 2000. This decision by the CDPH is a huge step backwards for veterinary health care professionals, like myself, who need to be able to justify exemption from rabies vaccine boosters on a case-by-case basis. Your bill AB 2000 would permit a safe alternative for dogs whose illnesses were caused by a rabies vaccine, as well as those too sick to tolerate the rabies vaccine because of terminal cancer, kidney/liver failure, grand mal seizures, and other chronic diseases.

The CDPH letter of June 8, 2010 states that “there is no scientific evidence that rabies vaccines are associated with severe or a high rate of vaccination reactions.” This statement is just false. The letter goes on to state that “Modern rabies vaccines are safe and effective”, and that “ A recent study published by the U.S. Department of Agriculture (USDA) found that rabies vaccines used for dogs ---- do not result in a high frequency or unexpected pattern of adverse events.” On the contrary, this same cited study found:

Rabies Vaccines and the USDA/CVB

Rabies vaccines are the most common group of biological products identified in adverse event reports received by the USDA’s Center for Veterinary Biologics (CVB). Currently, 14 rabies vaccines are labeled for use in dogs. Before licensure, a product must be shown to be safe through a combination of safety evaluations. The field safety trial is the most comprehensive evaluation and has the objective of assessing the safety of the product in its target population under the conditions of its intended use. However, safety studies before licensure may not detect all safety concerns for a number of reasons, as follows: insufficient number of animals for low frequency events, insufficient duration of observation, sensitivities of subpopulations (e.g. breed, reproductive status, and unintended species), or interactions with concomitantly administered products.

Reporting Adverse Vaccine Reaction to Manufacturer and the Government

There is no mandatory reporting of adverse reactions in veterinary medicine. The 2007 World Small Animal Veterinary Association (WSAVA) Vaccine Guidelines states that there is: "gross under-reporting of vaccine-associated adverse events which impedes knowledge of the ongoing safety of these products." WSAVA 2007 Vaccine Guidelines - WSAVA - Scientific Advisory Committee,

Despite the serious under-reporting of vaccine-associated adverse reactions, the 2008 Report from the USDA’s CVB [JAVMA 232:1000-1002, 2008], states that between April 1, 2004 and March 31, 2007, they "requested manufacturers of rabies vaccines to provide adverse event report summaries for their products. During this period, nearly 10,000 adverse event reports (all animal species) were received by manufacturers of rabies vaccines. Approximately 65% of the manufacturer's reports involved dogs."

The USDA/CVB 2008 Report further states that "Rabies vaccines are the most common group of biological products identified in adverse event reports received by the CVB." During the 3-year period covered in this report, the CVB received 246 adverse event reports for dogs in which a rabies vaccine was identified as one of the products administered.

The following clinical terms were listed “to describe possibly related adverse events in dogs vaccinated against rabies “ and reported to the USDA/CVB between April 1, 2004-March 31, 2007. For 217 adverse event reports – the clinical term is followed by the % of dogs affected:

Vomiting-28.1%; facial swelling-26.3%; injection site swelling or lump-19.4%; lethargy-12%; urticaria-10.1%; circulatory shock-8.3%; injection site pain-7.4%; pruritus-7.4%; injection site alopecia or hair loss-6.9%; death-5.5%; lack of consciousness-5.5; diarrhea-4.6%; hypersensitivity (not specified)-4.6%; fever-4.1%;, anaphylaxis-2.8%; ataxia-2.8%; lameness-2.8%; general signs of pain-2.3%; hyperactivity-2.3%; injection site scab or crust-2.3%;, muscle tremor-2.3%; tachycardia-2.3%; and thrombocytopenia-2.3%.

The overall adverse report rate for rabies vaccines was determined to be 8.3 reports/100,000 doses sold. Adverse events considered possibly related to vaccination included acute hypersensitivity (59%); local reactions (27%); systemic reactions, which refers to short-term lethargy, fever, general pain, anorexia, or behavioral changes, with or without gastrointestinal disturbances starting within 3 days after vaccination (9%); autoimmune disorders (3%); and other (2%).

While there may be no contraindications listed on the label for canine rabies vaccines, the labeling instructions on vaccine products clearly instruct veterinarians to only vaccinate healthy dogs. I submit that the dogs for which medically justified exemptions from rabies boosters are sought are not healthy.

The CDPH “believes that passage of AB 2000 could increase the risk to the public health by allowing dogs to be exempted from current rabies vaccination requirements.” This statement lacks credibility, as the number of dogs eligible for exemptions statewide would be small and such exemptions require that a primary care veterinarian justify them on a case-by-case basis. To deny these animals the opportunity to avoid serious or even fatal adverse events from rabies vaccines just encourages pet owners to break the law to save their pets from harm. They would then join the approximate 50% of pet owners in our State that fail to vaccinate their dogs at all. It is those that flaunt the law and never comply that we should seek out, rather than penalizing the few unfortunate pets and owners whose dogs cannot tolerate rabies boosters.

Finally, the CDPH letter states “ Standard veterinary immunization protocols already exist to prevent vaccine adverse reactions.” I know of no such standard protocols, and further, one often cannot predict which animals will react adversely without a prior history of reaction or family predisposition.

Sincerely,
W. Jean Dodds, DVM Co -Trustee, Rabies Challenge Fund Charitable Trust;
President, Hemopet

[Kris Christine]

Below is the letter I just faxed to the Senate Health Committee.

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June 16, 2010

Senator Elaine Alquist, Chair
Senate Health Committee
State Capitol, Room 5080
Sacramento, CA 95814

RE: Support for “Molly’s Bill,” AB2000

Greetings Senator Alquist:

The Rabies Challenge Fund, a California-registered charitable trust of which Co-Trustee Dr. W. Jean is a California resident, strongly supports “Molly’s Bill,” AB 2000.

For years, many states have had medical exemptions in rabies laws without experiencing an increase in rabies for the species of domestic animals covered by the laws, and there is no epidemiological or scientific data indicating that California residents will be at an elevated risk of contracting rabies if “Molly’s Bill” is passed.

Maine is a rabies endemic state, yet the Department of Health passed a medical exemption clause into the rabies regulations, which became effective in April 2005 (DHS Chapter 260 http://www.maine.gov/sos/cec/rules/10/144/144c260.doc). Dr. Donald E. Hoenig, Maine’s State Veterinarian (207) 287-7615, confirmed today that there have been no rabid dogs reported in the state since the passage of the rabies medical exemption clause more than five years ago.

Within the last year, the states of Alabama, Rhode Island, and Virginia have all passed rabies medical exemption clauses into their laws and regulations. The Rabies Challenge Fund Charitable Trust urges the Senate Health Committee to support “Molly’s Bill.”

Sincerely,

Kris L. Christine
Founder, Co-Trustee
THE RABIES CHALLENGE FUND CHARITABLE TRUST
Duration of Immunity Study for Rabies Vaccine - Rabies Challenge Fund
ledgespring@lincoln.midcoast.com

cc: W. Jean Dodds, DVM
Ronald D. Schultz, PhD
Assembly Member Curt Hagman

[Kris Christine]

Humane Society Veterinary Medical Association's Letter of Support for "Molly's Bill," AB 2000 California Rabies Medical Exemption

June 16, 2010

Senator Elaine Alquist, Chairperson
CA State Senate Health Committee
State Capitol Building, Room 2191
Sacramento, CA 95814
FAX: (916) 324‐0384

RE: Follow‐up Veterinary Support Letter for AB 2000 (Medical Exemption from Rabies Vaccination), including Response to California Department of Public Health (CDPH) Objections

Dear Senator Alquist and Committee Members:

I am writing on behalf of the Humane Society Veterinary Medical Association (HSVMA), an organization representing approximately 2,000 veterinary professionals nationwide with a focus on the health and welfare of all animals, including companion dogs and cats, to reiterate our support for AB 2000 and to counter objections voiced in the California Department of Public Health’s opposition letter, dated June 8. (Our original letter, dated May 7, in support of the bill, is attached for your reference.)

The CDPH statement that “there is no scientific evidence that rabies vaccines are associated with severe or a high rate of vaccination reactions,” is simply incorrect. The USDA Center for Veterinary Biologics (CVB) reports that rabies vaccines are the most common group of biological products named in the adverse event reports they receive. Adverse vaccine‐associated reactions are not required to be reported in veterinary medicine. Even in the face of what is probably gross underreporting, the USDA/CVB Report, published in the April 1, 2008 issue of the Journal of the American Medical Association (pages 1000‐1002), states that from April 2004 through March 2007 nearly 10,000 adverse event reports were received by rabies vaccine manufacturers, and that about 65% of these concerned dogs. The overall rate of such adverse rabies vaccine reactions during the report period was 8.3 reports/100,000 doses of vaccine. These are by no means trivial findings nor is the magnitude of the numbers insignificant. Although canine rabies vaccine labels may not enumerate contraindications, the labeling instructions on vaccine products clearly instruct veterinarians to vaccinate only healthy dogs. A small number of companion animals have medical conditions for which vaccination is life‐ or health‐threatening and thus, inappropriate. In these cases, a dog’s particular exemption from rabies vaccination would be individually substantiated by a veterinarian, and under these stringent circumstances, we do not foresee the submission of illegitimate or frivolous requests.

Veterinarians are well trained in immunology and develop a great respect for both the powerful positive and potential negative consequence of vaccinating their patients. Veterinary schools require detailed study of those zoonotic diseases, like rabies, that are transmissible from animals to humans. State and national veterinary board exams rigorously test this understanding. Veterinary schools and professional advisory bodies regularly update vaccination protocols as new findings emerge. Vaccinology is one of the most active areas of research and discussion in the professional literature, at continuing education venues, and among clinicians around the country and throughout the world.

The Veterinarian’s Oath states, “I solemnly swear to use my scientific knowledge and skills for the benefit of society through the protection of animal health, the relief of animal suffering… (and) the promotion of public health…” As veterinarians we continuously safeguard the public health by protecting the health and welfare of our patients within the context of their families and our communities. Disallowing veterinary medical exemption from rabies vaccination impugns this professional commitment and puts the public at greater potential risk by those who, concerned
about their dogs’ health and deprived of a vaccination exemption option, may choose to fly ‘under the radar,’ eluding both licensing and vaccination entirely.

A number of states, including Alabama, Florida, Colorado, Connecticut, Maine, Massachusetts, New Jersey, New York, Virginia and Wisconsin, successfully provide medical exemption from rabies vaccination without quarantine provisions. Once again, we encourage your support of this important state legislation, similarly safeguarding the health and welfare of the companion canines of Californians.

Please contact me if you have any questions or if you would like more details about our perspective on these issues. Thank you for your consideration.

Sincerely,
Barbara Hodges, DVM, MBA
Veterinary Consultant
Humane Society Veterinary Medical Association (HSVMA)