URGENT ACTION ALERT:
CALIFORNIA AB 272, which would lower the age at which puppies must be
vaccinated from four months to three months just passed the Assembly Agriculture
Committee and has been assigned to the Assembly Appropriations Committee http://www.leginfo.ca.gov/pub/13-14/bill/asm/ab_0251-0300/ab_272_vote_20130313_000001_asm_comm.html
.
What You Can Do to
Help:
Contact Appropriations Committee members Mike Gatto
(Chair) (916) 319-2043 assemblymember.gatto@asm.ca.gov
& Susan T. Eggman assemblymember.eggman@asm.ca.gov
(916) 319-2013 & ask them to OPPOSE AB 272.
PERMISSION GRANTED TO CROSS-POST
Letter from The Rabies
Challenge Fund to Assembly Members Gatto & Eggman is below. If you would
like a copy of the e-mail correspondence between Dr. Karen Ehnert, Dr. Dodds and
me, please send me a request at ledgespring@lincoln.midcoast.com
& I will e-mail it to you.
(link to committee comments on AB
272 http://www.leginfo.ca.gov/pub/13-14/bill/asm/ab_0251-0300/ab_272_cfa_20130311_134658_asm_comm.html)
March 14, 2013
Assemblymember Mike Gatto, Chair Assemblymember
Susan T. Eggman, Chair
RE: AB 272 An Act
to Amend Section 121690 of the Health and Safety Code Relating to Rabies
Greetings Assemblymembers Gatto and Eggman :
There are
some misrepresentations and inaccuracies relating to AB 272 which should be
clarified before another vote is taken on this measure. On February 14, Dr. W.
Jean Dodds, a California veterinarian, and Co-Trustee of the Rabies Challenge
Fund Charitable Trust, corrected and clarified this misinformation regarding AB
272 in an e-mail to the Acting Director of Veterinary Public Health, Dr. Karen
Ehnert, but apparently this information was not conveyed to the bill sponsor or
members of the Agriculture or Appropriations Committees (see attached e-mail),
or it was disregarded.
The Agriculture Committee comments on AB 272
report that “California is the only state that
sets a minimum age of four months for dogs rabies vaccination.” This
statement is false. Only twelve (12) out of fifty (50) states require that dogs
be vaccinated by 3 months (Alabama, Arizona, Connecticut, Idaho, Indiana,
Louisiana, Mississippi, Nevada, New Hampshire, New Mexico, Oregon, Pennsylvania)
. Thirteen (13) states require that dogs be vaccinated by the age of 4 months
(Arkansas, Florida, Illinois, Kentucky, Maryland, Michigan, New York, North
Carolina, Oklahoma, Texas, Utah, Vermont, Virginia); one (1) state (Wisconsin)
requires vaccination by 5 months; and six (6) require vaccination by the age of
6 months (Delaware, Iowa, Maine, Massachusetts, Tennessee, West Virginia), and
twelve (12) refer to the National Association of State Public Health
Veterinarians’ Rabies Compendium which recommends that rabies vaccines should be
administered according to the manufacturers’ labeled instructions. Rabies
vaccine labels indicate that they may
be given at 3 months, not that they must
be. It is implied in the comments that the Compendium advises that
puppies should or must be vaccinated at 3 months of age, which is not the case.
Merial’s IMRAB rabies vaccine labels indicate that they "can be administered to puppies
as early as 3 months of age" and Pfizer’s Defensor rabies vaccine labels
advise that they are for dogs and cats “3
months of age or older.” These
instructions denote the minimum age at which it is safe to administer rabies
vaccines (i.e., do not administer before 3 months
of age) and not a minimum age at which
they must be administered to be effective. Scientific data reflect that the
later a puppy can be vaccinated, the more likely the vaccine will have
the desired immunological response due to reduced interference of maternal
antibodies, which are still present in 3 month old puppies. The 2011 American
Animal Hospital Association's Canine Vaccine Guidelines reports that: "Because dogs older than 14-16 wk of age are not
likely to have interfering levels of MDA [maternally derived antibodies],
administration of a single initial dose of an infectious vaccine to an adult
dog can be expected to induce a protective immune response. ..... MDA is
the most common reason early vaccination fails to immunize." [1]
Contributing to the likelihood of failure to achieve a proper immune
response to rabies vaccination at 3 months is that puppies are finishing up
their initial vaccination series of distemper, hepatitis, parvovirus at 12 weeks
(3 months) of age. Addition of a rabies vaccine into the mix will not only
increase the possibility of adverse reactions, but also the probability that the
vaccine components will interfere with each other and neutralize or negate an
appropriate immunological response. [2] [3]
In her e-mailed message
concerning AB 272 to Dr. Dodds and me, Dr. Ehnert wrote that: “to clarify, the one word change allows for dogs to
be vaccinated at 3 months of age, but does not
mandate it.” This is a misrepresentation of the bill as worded and
the committee summary declaring that “this bill
changes, from four months to three months, the age at which a dog is required to be vaccinated against rabies."
Addition of a clause such as "or
previously vaccinated at the age of three months in another state or country
with a rabies vaccine licensed by the USDA" to the current law requiring
vaccination at four months would accomplish that goal without changing the
mandated age of vaccination to three months.
Dr. Ehnert also explained
that one of the reasons she has “pushed” for this change is she and the Health
Officers Association “… want to give owners the
opportunity to vaccinate puppies earlier when there is increased risk. The past
two years we have seen a 4 -5 fold increase in bat rabies in LA County, with
some areas being hot spots.” There has been no escalation in canine
rabies corresponding to the increase in bat rabies, which according to the
Department of Health’s Reported Animal
Rabies, for Los Angeles County there were no cases of rabid dogs from
2010 through 2012, while there were 114 rabid bats (22 in 2010, 38 in 2011, and
54 in 2012—representing an increase of nearly 2.5 times instead of a 4-5 fold
increase). Statewide, there have only been three cases of rabies in dogs since
2007, as opposed to 981 rabid bats and 147 rabid skunks for the same period,
which evidences the fact that the current law requiring puppies to be vaccinated
against rabies by 4 months of age is effective at controlling rabies in
California’s canine community and does not need to be changed.
To
address the concern over a rising increase in rabies in the bat population
spilling over into the domestic pet population, Dr. Ehnert and other members of
the Health Officers Association of California should request introduction of a
bill requiring that all cats in California be vaccinated against rabies, as cats
are reported to be 4 times as likely to be infected with rabies as dogs.[4] The
Chair of the Compendium of Animal Rabies Prevention and Control Committee, Dr.
Catherine M. Brown, stated that “because more
rabies cases are reported annually involving cats…than dogs, vaccination of cats
should be required.”
As it currently stands, the law requiring
puppies to be vaccinated at 4 months of age is and has been effective at
controlling rabies in California’s canine population. There is no
epidemiological or scientific rationale for changing this law and prematurely
exposing puppies to the potentially harmful, sometimes fatal, adverse side
affects of the rabies vaccine prior to the age of 4 months.
On behalf of
The Rabies Challenge Fund, a registered California Charitable Trust, and the
many concerned California pet owners who have requested our assistance, I
strongly urge you to oppose passage of AB 272 as it is currently written.
Respectfully submitted,
Kris L. Christine
Founder,
Co-Trustee
THE RABIES CHALLENGE FUND
www.RabiesChallengeFund.org
ledgespring@lincoln.midcoast.com
Pages:
8
Attachment: 1
cc: Dr. W. Jean Dodds
Dr. Ronald Schultz
Assemblymember Jimmy Gomez
California Assembly
--------------------------------------------------------------------------------
[1] American Animal Hospital Association Canine Vaccine Task Force. 2011
Canine Vaccine Guidelines, Recommendations, and Supporting Literature, p.12
[2] American Animal Hospital Association Canine Vaccine Task Force. 2003
Canine Vaccine Guidelines, Recommendations, and Supporting Literature, p.16
[3] Moore, et als., Adverse Events Diagnosed Within Three Days of Vaccine
Administration in Dogs; Journal of the American Veterinary Medical Association.,
Vol. 227, No. 7, October 1, 2005
[4] Blanton JD, et al. Rabies Surveillance
in the United States During 2008. Journal of the American Veterinary Medical
Association 2009; 235: 676-690.
_________________