**MICHIGAN Rabies Bill SB 118 ACTION ALERT: Senator Rick Jones has introduced legislation which would lower to 3 months the age at which puppies in large-scale breeding facilities must have rabies vaccinations http://www.legislature.mi.gov/documents/2013-2014/billintroduced/Senate/htm/2013-SIB-0118.htm. The Rabies Challenge Fund is concerned about the health impact this would have on those puppies if this bill passes with this change in it and that it will lead to a law change requiring all Michigan puppies to be vaccinated against rabies at the age of 3 months instead of at 4 months as the dog laws currently require. The bill has been assigned to the Senate Agriculture Committee for consideration.
**What You Can Do to Help:
Contact the bill sponsors and members of the Senate Agriculture Committee and request that they delete the language in this bill which lowers the age at which puppies in large-scale breeding facilities to 3 months.
**Bill Sponsors Contact Information:
Senator Rick Jones SenRJones@senate.michigan.gov (517) 373-3447 fax: (517) 373-5849
Sen. Steve Bieda SenSBieda@senate.michigan.gov (517) 373-8360 fax: (517) 373-9230
Sen. Tory Rocca SenTRocca@senate.michigan.gov (517) 373-7315 fax: (517) 373-3126
Sen. Tonya Schuitmaker SenTSchuitmaker@senate.michigan.gov (517) 373-0793 fax: (517) 373-5607
Sen. Glenn S. Anderson SenGAnderson@senate.michigan.gov (517) 373-1707 fax: (517) 373-3935
Sen. John Proos SenJProos@senate.michigan.gov (517) 373-63960 fax: (517) 373-0897
Sen. Mike Kowall SenJKowall@senate.michigan.gov (517) 373-1758 fax: (517) 373-0938
Sen. JohnPappageorge SenJPappageorge@senate.michigan.gov (517) 373-2523 fax: (517) 373-5669
Sen. Jim Marleau email@example.com (248) 724-2442 fax: (517) 373-2694
**Senate Agriculture Committee Members Contact Information:
Senator Joe Hune, Chair SenJHune@senate.michigan.gov (517) 373-2420 fax: (517) 373-2764
Sen. Darwin L. Booher SenDBooher@senate.michigan.gov (517) 373-1725 fax: (517) 373-0741
Sen. Judy K. Emmons SenJEmmons@senate.michigan.gov (517) 373-3760 fax: (517) 373-8661
Sen. Goeff Hansen SenGHansen@senate.michigan.gov (517) 373-1635 fax: (517) 373-3300
Sen. Virgil Smith firstname.lastname@example.org (517) 373-7918 fax: (517) 373-5227
Committee clerk: email@example.com
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Below is my letter to Senators Jones and Hune on behalf of The Rabies Challenge Fund:
February 15, 2013
RE: SB 118 to Amend Dog Law 1919 PA 339 MCL 287.261-287.290
Greetings Senators Jones and Hune:
Senate Bill SB 118, which would lower the age at which puppies in large-scale breeding facilities must be vaccinated against rabies from 4 months to 3 months, will result in an increase the number of puppies who will fail to elicit a proper immune response to rabies as well as increase the likelihood of adverse reactions to the vaccine. This portion of the bill appears to address a non-existent problem in the canine community, as the data reported in the government summary maps of all rabies positive cases in Michigan illustrate: bats and skunks pose the major public health threat, not puppies under the age of 4 months.
Michigan?s summary maps indicate that over the 34 years from 1978 through 2012 there were 14 rabid dogs (no mention of puppies under 4 months of age), 16 rabid horses, 27 rabid cats, 128 rabid skunks, and 1,279 rabid bats. These data evidence the fact that this segment of current law requiring puppies to be vaccinated against rabies by 4 months of age is effectively controlling rabies in Michigan?s canine community amongst large-scale and small-scale breeders and does not need to be changed.
Lowering the age at which puppies, whether in litters of large-scale or small-scale breeders, are required to have their first rabies shot from 4 months to 3 months would be counterproductive. At the age of 3 months (12 weeks), puppies are finishing up their initial series of other vaccinations (distemper, hepatitis, parvovirus). Mandating that these young animals be vaccinated against rabies at the same time will not only increase the likelihood of adverse reactions (some of which can be lethal), but also the probability that the vaccine components will interfere with each other and neutralize or negate the appropriate immunological response sought.
Augmenting the probability that rabies vaccination at 3 months may not be effective is the continued presence of maternal antibodies. According to the 2006 American Animal Hospital Association's Canine Vaccine Guidelines, the most common reason for vaccination failure is "the puppy has a sufficient amount of passively acquired maternal antibody (PAMA) to block the vaccine…..."  They elaborate by reporting that at the ages of 14 to 16 weeks of age, "PAMA should be at a level that will not block active immunization in most puppies (>95%) when a reliable product is used." After the age of 16 weeks (4 months), the maternal antibodies are reduced to a level at which they should not reduce the rabies vaccine's effectiveness.
Vaccinating puppies at too young an age can be ineffective. Keeping in mind that rabies vaccines are ?killed? vaccines, the 2003 American Animal Hospital Association's (AAHA) Canine Vaccine Guidelines reports on Page 17 that: "? when puppies are first vaccinated at 16 weeks (or more) of age (an age when passively acquired antibodies generally don't cause interference), ? two doses of a killed vaccine, are adequate to stimulate an immune response." 
As it currently stands, the law requiring all puppies to be vaccinated at 4 months of age is and has been effective at controlling rabies in Michigan?s canine population. There is no epidemiological or scientific rationale for changing this portion of 1919 PA 339 MCL 287.261-287.290 and needlessly exposing any 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 and the concerned Michigan dog owners who have requested our assistance, I strongly urge you to remove the section of this bill which would lower the required age of rabies vaccination for puppies in large-scale breeding facilities to 3 months.
Kris L. Christine
cc: Dr. W. Jean Dodds
Dr. Ronald Schultz
 American Animal Hospital Association Canine Vaccine Task Force. 2006 Canine Vaccine Guidelines, Recommendations, and Supporting Literature, 28pp.
 American Animal Hospital Association Canine Vaccine Task Force. 2003 Canine Vaccine Guidelines, Recommendations, and Supporting Literature, 28pp.********