[Kris Christine]

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As far as we can tell, RCF has made no attempts to date to get a serological protocol approved [i.e, titer testing commonly offered at many vet offices to accurately detect the concentration of rabies antibodies at any interval post-vaccination]. That is not true; most rabies titers done in the county today are to satisfy export requirements for animals moving to rabies-free countries. Relatively few clinical vets check rabies titers for purposes of getting exemption waivers as justified only on a case-by-case basis, and requiring approval by local public health regulatory authorities. In fact most vets don't even realize that such tests can be done. The experiments being conducted by RCF are purely elective. Also not true. Why not design a tenable serological protocol that can be approved by USDA? They have always deigned such methodology and every year the US State and Territorial Public Health Officials unequivocally state that rabies titer serology is unacceptable and unreliable -- this year's reiteration was published in a May 2008 issue of the JAVMA. A serological method would allow data to be collected from volunteers rather than dogs stuck in a laboratory. No , it will not suffice . I don't know whether the PETA people are completely naive here, or knowingly suggesting something to mislead their supporters into thinking that we've not thought of or tried to get such testing allowed. Why were none of these efforts made before PETA began to shine a spotlight on the myriad of problems with RCF’s plans? This presumption without evidence to support their contention is perhaps arrogant. These alternative suggestions have been made for years by myself, Dr. Schultz and others; they have been the subject of seminars, publications, and teaching handouts to both the profession and the public.

With regards to RCF's statement that PETA should be working on this issue, we are indeed working on non-animal protocols for vaccine testing at both the USDA and the FDA. PETA has spent more than three quarters of a million dollars in recent years to develop non-animal testing methods. We're very happy to put our money where our mouth is! IF that's true; we applaud the effort !

Despite repeated requests, the RCF folks have refused to provide details including:

• the actual number of dogs involved in each study. The USDA gives only the minimum number of dogs that they must have data for at the culmination of the study, so logically RCF must use more dogs than the USDA’s minimum of 70. No we only need a few extra animals (should a few become ill during the length of the study for some unforeseen natural disease), and we will not use more from both humane and cost issues. However, RCF has not answered even this simple question.

• the conditions and socialization for the dogs. Dodds referred PETA to USDA’s protocol for this information. USDA’s protocol does not specify that dogs should be socialized, group housed, or that they should receive toys or even a bed. The existing USDA CFR protocol is outdated in that regard, and the law has not been updated, BUT, as we and PETA all realize, all current research protocols are governed by the USDA Animal Welfare Act and the NIH Guide for the Care and Use of Laboratory Animals for all institutions that receive federal research monies. These regulations require socialization and exercise and specify the animal housing conditions. So, this point is moot and they're certainly are well aware of the current federal and state rules that apply.

• how and when the dogs would be killed. RCF referred PETA to the USDA protocol for this information. USDA’s protocol stipulates that even vaccinated dogs are to be killed and their brains examined. At the end of the 5 and 7 year studies, the current regulations do so state, but see above for our plans to get some amendments accepted in the interim years. This is in direct contradiction RCF’s current claim that it will adopt out the dogs who don't die.No one in an official capacity for the RCF or any one else purporting to represent us, to my knowledge, has ever said that. It would create a huge liability issue.

RCF makes it appear that dogs will be killed at the first signs of rabies. Rabies is painful and its symptoms can begin quietly. See above. Dogs will likely die of painful complications related to paralysis and inability to breathe. Not true; the end point will be recognized long before this end stage of paralysis.

No one is disputing how the immune system works and that dogs are most likely being over-vaccinated in many ways. However, much more good could have come from an effort to change the way rabies vaccine efficacy is tested rather than to use more than $1 million to kill beagles. This is just inflammatory rhetoric.

To paraphrase PETA's president, "A dog is a dog is a dog is a dog." It is unfortunate the RCF chose to use crude and cruel methods in its attempts to help other dogs." It is also unfortunate that PETA chooses to paint our good will for the benefit of millions in this light.

It seems there are critical differences here, and I stand with PETA and again demand (hey -- how about a request rather than demand here ?) the issues raised by PETA be addressed AND FOLLOWED.


Below is a copy of Dr. Dodds' previous responses to two other PETA members who have contacted her with concerns.

Unfortunately, this information from PETA is terribly misleading. See below. We've tried to have a dialog with PETA about their RCF concerns and so hope that they now understand what we're doing and why. We appreciate your concern about the way in which we must conduct the RCF Research Study. Please allow me to explain the regulatory requirements we must follow as specified by the Code of Federal Requirements, USDA , Title 9, part 113.209. We cannot get a new rabies vaccine licensed by the government with the extended booster periods of 5 and eventually 7 years unless we strictly follow these regulatory requirements. The protocol is not up to us .

The Rabies Challenge Fund is designed to prove to UDSA authorities that dogs only need two booster rabies vaccines in their lifetime. This would significantly reduce the tragedies outlined below, save countless animal pain and suffering, and still protect the public health.

The public has little understanding of how all vaccines must be tested through USDA -specified trials before they are licensed for veterinary use. Every currently licensed rabies vaccine has been required to successfully complete these specified trials; and these vaccines as you know are required by law.

Only purebred beagles raised in a dog breeding facility run by veterinarians are involved in our project. This a large USDA licensed facility maintained in strict compliance with animal care and use requirements. The dogs live in large pens and are housed together in small groups for socialization and exercise. Further socialization is provided by their caretakers.

Today, we have a formidable uphill battle compounded by inertia in trying to change outdated rabies regulations to reflect what is truly needed to protect animals and people from contracting rabies. The federal government is just not interested in promoting a uniform requirement throughout the country that rabies booster vaccinations be given every three years. A few individual states and locales still insist on mandating annual rabies boosters when these vaccines are licensed for three years by the USDA. The recent media furor over the annual rabies booster mandate by the city of Wichita, KS is but one example.

While this travesty continues under the rubric of state's rights, countless companion animals suffer from being required to receive rabies boosters even when they're terminally ill, debilitated, very old or have a record of prior serious adverse reaction to vaccination. This usually occurs when veterinarians either don't believe that adverse events occur or are likely, or they use the excuse that they're merely following the law. This situation is further complicated when local or state authorities will not accept waivers of booster requirement even with a veterinary letter of justification and/or a rabies antibody titer beyond the 1:5 titer level deemed by CDC to be adequate for people. Just today, a distraught caregiver was faced with having to revaccinate a middle aged dog with prior history of collapse after rabies vaccine. The dog's rabies antibody titer was 1: 3125, six hundred times that required for people, and yet the local authorities refused to grant a waiver.

These all too common occurrences have resulted in an increasing number of people simply breaking the law and not vaccinating their dogs at all. However, IF these dogs injure someone, even accidentally, and they're quarantined without evidence of an in-date rabies vaccination, the public health authorities have the right to require surety and direct that the animal be killed; his/her head is then examined for rabies. One such tragedy where a family was not given the chance to appeal on behalf of their dog is in litigation as we speak.

Then, there are the heartbreaking adverse reactions and deaths that occur when animals are forced to be given rabies boosters in lieu of waivers, when justified, and the dog seizures uncontrollably and dies in the caregiver's arms. Such a case also happened this past week.

With reverence for all life. Jean


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