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Below is a copy of my letter on behalf of The Rabies Challenge Fund to the Arkansas Governor and Attorney General.
What You Can Do to Help:
Contact the Arkansas Legislature http://www.arkleg.state.ar.us/
(full e-mail list at the bottom of this message) and ask them to pass the 3 year rabies legislation when it is introduced and request that a medical exemption clause for sick animals be included.
October 5, 2008
Governor Mike Beebe Attorney General Dustin McDaniel
Governor’s Office Office of the Attorney General
State Capitol Room 250 323 Center Street, Suite 200
Little Rock, AR 72201 Little Rock, AR 72201
RE: ARKANSAS RABIES IMMUNIZATION PROTOCOL
The Rabies Challenge Fund Charitable Trust has been made aware that the State of Arkansas is considering adoption of the 3-year rabies immunization protocol recommended by the Center for Disease Control’s National Association of State Public Health Veterinarians and the American Veterinary Medical Association[1] to replace the State’s current annual requirement. Not only does The Rabies Challenge Fund endorse adoption of the national 3-year standard, but we strongly encourage Arkansas to include a medical exemption clause for sick animals, for which vaccination is medically contraindicated.
It is recognized that most, if not all, currently licensed annual rabies vaccines given annually are actually the 3-year vaccine relabeled for annual use – Colorado State University's Small Animal Vaccination Protocol for its veterinary teaching hospital states: “Even with rabies vaccines, the label may be misleading in that a three year duration of immunity product may also be labeled and sold as a one year duration of immunity product.” According to Dr. Ronald Schultz of the University of Wisconsin School of Veterinary Medicine, whose canine vaccine studies form a large part of the scientific base for the 2003 and 2006 American Animal Hospital Association’s (AAHA) Canine Vaccine Guidelines as well as the World Small Animal Veterinary Association’s (WSAVA) 2007 Vaccine Guidelines, “There is no benefit from annual rabies vaccination and most one year rabies products are similar or identical to the 3-year products with regard to duration of immunity and effectiveness.”[2]
Section 20-19-202 of Arkansas’ Rabies Law requiring annual rabies boosters may have been intended to achieve enhanced immunity to rabies virus by giving the vaccine more often than the federal 3-year licensening standard. But, more frequent vaccination than is required to fully immunize an animal will not achieve further disease protection. Redundant annual rabies shots needlessly expose dogs and cats 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 law, as it currently reads, may violate Arkansas Consumer Protection Laws 4-88-107 and 4-88-108 by requiring pet owners to pay for a yearly veterinary medical procedure from which their animals derive no benefit and may be harmed. The fact that the rabies vaccine confers a minimum duration of immunity of 3 years is “concealed” or “omitted” from consumers (pet owners). Compliance with Section 20-19-202 of the Rabies Law places veterinarians in the uneasy position of “Over-treating patients” – an apparent violation of Section 17-101-305 (a)(17) of the Arkansas Veterinary Medical Practice Act.
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)."
The labels on rabies vaccines state that they are for “the vaccination of healthy cats, dogs…,” and there are medical conditions for which vaccination can jeopardize the life or well-being of an animal. A medical exemption clause inserted into the new 3 year Rabies Law being considered would allow veterinarians to write waivers for animals for whom medical conditions preclude vaccination. The State of Maine inserted such an exemption into the 3 year rabies protocol, 7 M.R.S.A., Sec. 3922(3), it adopted in 2004 as follows:
_A. A letter of exemption from vaccination may be submitted for licensure, if a medical reason exists that precludes the vaccination of the dog. Qualifying letters must be in the form of a written statement, signed by a licensed veterinarian, that includes a description of the dog, and the medical reason that precludes vaccination. If the medical reason is temporary, the letter shall indicate a time of expiration of the exemption.
B. A dog exempted under the provisions of paragraph 5 A, above, shall be considered unvaccinated, for the purposes of 10-144 C.M.R. Ch.251, Section 7(B)(1), (Rules Governing Rabies Management) in the case of said dog’s exposure to a confirmed or suspect rabid animal._
The Rabies Challenge Fund strongly supports a change in the Arkansas Rabies Law to conform to the 3-year national standard and respectfully requests that medical exemption language be inserted into the law.
Sincerely,
Kris L. Christine
Founder, Co-Trustee
THE RABIES CHALLENGE FUND
www.RabiesChallengeFund.org
cc: Arkansas State Legislature
Richard Bell, Secretary, Arkansas Department of Agriculture
Dr. Susan Weinstein, Arkansas Public Health Veterinarian
Dr. W. Jean Dodds, Co-Trustee of The Rabies Challenge Fund
Dr. Ronald Schultz, University of Wisconsin School of Veterinary Medicine
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[1] National Association of State Public Health Veterinarian's 2008 Compendium of Animal Rabies Prevention and Control, pp. 3, 6-7
[2] What Everyone Needs to Know about Canine Vaccines, Dr. Ronald Schultz http://www.puliclub.org/CHF/AKC2007Conf/What%20Everyone%20Needs%20to%20Know%20About%20Canine%20Vaccines.htm
Duration of Immunity to Canine Vaccines: What We Know and Don't Know, Dr. Ronald Schultz http://www.cedarbayvet.com/duration_of_immunity.htm
World Small Animal Veterinary Association 2007 Vaccine Guidelines http://www.wsava.org/SAC.htm Scroll down to Vaccine Guidelines 2007 (PDF)
[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]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.
Arkansas Legislators: http://www.arkleg.state.ar.us/
wyattd@arkleg.state.ar.us
