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 email@example.com or staffer Kevin Liao Kevin.Liao@asm.ca.gov & Asm. Susan T. Eggman firstname.lastname@example.org (916) 319-2013 or staffer Erin Flannery Erin.Flannery@asm.ca.gov & ask them to **OPPOSE AB 272.
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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 email@example.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." 
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.  
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. 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.
Kris L. Christine
THE RABIES CHALLENGE FUND
cc: Dr. W. Jean Dodds
Dr. Ronald Schultz
Assemblymember Jimmy Gomez
 American Animal Hospital Association Canine Vaccine Task Force. 2011 Canine Vaccine Guidelines, Recommendations, and Supporting Literature, p.12
 American Animal Hospital Association Canine Vaccine Task Force. 2003 Canine Vaccine Guidelines, Recommendations, and Supporting Literature, p.16
 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
 Blanton JD, et al. Rabies Surveillance in the United States During 2008. Journal of the American Veterinary Medical Association 2009; 235: 676-690.___****