TEXAS Rabies Law–Bell County
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    A debate over the annual county rabies protocol in Bell County, Texas has erupted (see 6/7/09 Temple Daily Telegram Bell County eyes rabies ordinance change: Required shots could switch from yearly to every three years http://www.tdtnews.com/story/2009/06/07/58450 6/2/09 story on Channel 25 ABC News Bell County Rabies Debate Continues http://www.kxxv.com/global/story.asp?s=10467503 , Killeen Takes Closer Look at Rabies Vaccinations KCEN Channel 9 News 6/4/09 http://www.kcendt.com/?p=12086, Killeen Daily Herald stories Regulations for rabies vaccination under debate http://www.kdhnews.com/news/story.aspx?s=33495 and County debates changing rabies law http://www.kdhnews.com/news/story.aspx?s=33636) and it is urgent that any and all concerned pet owners contact the county officials below to urge them to change the protocol to the national 3 year standard. A copy of my letter to County officials is below. Texas state law recognizes the 3 year rabies vaccines licensed by the USDA and at least one town's 3 year protocol is overridden by the County order.

    **What You Can Do to Help

    Contact the Bell County Commissioners, County Attorney and/or District Attorney via phone, e-mail, or fax (contact information is below) and tell them it is time for them to adopt the 3 year rabies protocol recommended by all the national veterinary medical associations and adopted by all the states. Please share this action alert with all the pet-owners you know.

    County Commissioners: Phone 1-800-460-2355 or 254-939-3521 Fax: 254 - 933-5179 Richard Cortese richard.cortese@co.bell.tx.us; Tim Brown tim.brown@co.bell.tx.us; Eddy Lange william.lange@co.bell.tx.us; John Fisher john.fisher@co.bell.tx.us

    County Attorney Richard Miller Phone 1-800-460-2355 or 254-939-3521 Faxes 254-933-5150 and 254-933-5176
    District Attorney Henry Garza henry.garza@co.bell.tx.us fax: 254-933-5179 phone Phone 1-800-460-2355 or 254-939-3521

    May 26, 2009

    Bell County Commissioners
    County Attorney Richard Miller
    District Attorney Henry Garza
    101 East Central Avenue
    Belton, TX 76513

    RE: BELL COUNTY ANNUAL RABIES VACCINATIONS ORDER

    Greetings Messrs. Cortese, Brown, Lange, Fisher, Miller, and Garza:

    Bell County should amend the outdated section (4.01) of its Animal Control County Order governing rabies vaccinations which requires annual rabies boosters following the initial puppy and kitten series of shots and institute a 3 year rabies immunization protocol conforming to the national standard adopted by all the states, including Texas, and recommended by the Center for Disease Control?s (CDC) National Association of State Public Health Veterinarians as well as the American Veterinary Medical Association.

    The CDC?s National Association of State Public Health Veterinarian?s Compendium of Animal Rabies Prevention and Control 2008 states that, **?Vaccines used in state and local rabies control programs should have at least a 3-year duration of immunity. This constitutes the most effective method of increasing the proportion of immunized dogs and cats in any population (50).? They specifically warn that, **?[n]o laboratory or epidemiologic data exist to support the annual or biennial administration of 3- or 4-year vaccines following the initial series.?

    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 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.? [1]

    Bell County?s code requiring annual rabies boosters may have been intended to achieve enhanced immunity to the rabies virus by giving the vaccine more often than Texas state law and the federal 3-year licensing 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.?

    By requiring pet owners to pay for a yearly veterinary medical procedure from which their animals derive no benefit and may be harmed, the county?s current rabies immunization code may violate the Texas Deceptive Trade Practices Act (Title 2, Chapter 17) and may place veterinarians in the uneasy position of violating Title 4 Chapter 801Subsection 402 (12) of the Veterinary Licensing Act, which cites as grounds for license denial or disciplinary action any veterinarian who ?performs or prescribes unnecessary?treatment.?

    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,?[2] auto-immune hemolytic anemia,[3] 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.[4] [5] 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," [6]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).?[7] According to the 2003 AAHA Guidelines, **"…killed vaccines are much more likely to cause hypersensitivity reactions (e.g., immune-mediated disease)." [8]

    County officials should note data indicating that compliance rates are no higher in areas with annual rabies immunization requirements than in those with triennial protocols. A 2002 report compiled by the Banfield Corporation for the Texas Department of Health on rabies vaccination rates determined that a** ?comparison of the one-year states and the three-year states demonstrates no difference in the delinquency rates? and that, ?A paucity of scientific data exists to demonstrate a clear public health benefit of a one-year vaccination protocol versus a three-year vaccination protocol.? [9]

    On behalf of The Rabies Challenge Fund and the Bell County pet owners who have contacted us, we strongly urge you to amend Section 4.01 of the Bell County Order governing Animal Control and Rabies Vaccinations to conform to the 3-year national standard recommended by the Center for Disease Control?s National Association of State Public Health Veterinarians and endorsed by the American Veterinary Medical Association.

    Sincerely,

    Kris L. Christine
    Founder, Co-Trustee
    THE RABIES CHALLENGE FUND
    www.RabiesChallengeFund.org

    cc: Dr. W. Jean Dodds
    Dr. Ronald Schultz
    Belton, Harker Heights, Killeen, Salado, and Temple City Officials
    Justin Cox

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    [1] Schultz, Ronald D.; What Everyone Needs to Know about Canine Vaccines, October 2007, http://www.puliclub.org/CHF/AKC2007Conf/What%20Everyone%20Needs%20to%20Know%20About%20Canine%20Vaccines.htm

    [2] 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

    [3] Duval D., Giger U.Vaccine-Associated Immune-Mediated Hemolytic Anemia in the Dog, Journal of Veterinary Internal Medicine 1996; 10:290-295

    [4] 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.

    [5] 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.

    [6] 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.

    [7] 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.

    [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.

    [9] Texas Department of Public Health, Zoonosis Control; The White Paper, Options for Rabies Vaccination of Dogs and Cats in Texas, 2002************************

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  • Below is a copy of a letter from Patti Emmerling (pattiemmerling@yahoo.com) of Temple, Texas to the Bell County Commissioners. It, and her e-mail, are posted with her permission.

    Judge Jon H. Burrows

    101 E. Central Ave

    Belton, TX 76513

    6/8/2009

    Dear Honorable Jon H. Burrows:

    I am writing this letter and asking you to consider an effective change to the current rabies vaccination ordinance for Bell County Texas.

    My husband and I relocated to Temple a little over a year ago and we were very surprised to learn the rabies booster is required annually. Most places across the nation have changed their protocols to a 3-year booster and are further researching possible changes for longer term boosters, such as 5 to 7 year. There is much research and data available to indicate 3-year rabies boosters are more than sufficient in healthy animals.

    As I opened the Sunday edition of the Temple Daily Telegram yesterday morning and began to read the front page article about this very topic, I was happy to see that there may be a chance of Bell County effecting change in the vaccination ordinance. However, I must say I was also quite disappointed with some aspects of this article.

    First, the comment made regarding how a clinic does not depend upon income from administering annual rabies vaccinations. While this may be somewhat true, I do not feel this statement to be a complete disclosure. Many veterinary clinics certainly do rely on required vaccinations to bring clients in the door and to keep them returning for future visits. Once clients are in the door veterinarians can, and do, recommend other services and products. Without mandatory vaccination protocols, many people would not otherwise take their pets to see a veterinarian. Without these people visiting these clinics, veterinarians lose the opportunity to offer and/or provide other services, thereby losing this very large source of income. For example:

    ? Rabies booster: $10.00

    ? Bordatella: $20.00 ($10.00 every 6 months)

    ? DHLP-P: $27.00

    ? Rattlesnake: $26.00

    ? Office Visit: $20.00

    ? Total: $103.00 annually per pet

    Now we know a veterinarians practice provides other services, so giving vaccinations all day would be unfair. However, a veterinarian may see as many as 36 pets per day, so we?ll round it down to 30. Taking the annual income from the vaccinations shown above, with vaccinations given only one day per month, would provide a monthly income of $3,708.00 or $44,496.00 annually. With a large multi-vet clinic, these numbers increase dramatically, because more pets are seen. With 5 veterinarians in one practice providing immunizations, using the same calculations, would generate well over $200,000 annually for vaccinations alone. Other services or care provided, such as Heartworm test ($27.50), Heartworm preventative ($35.76/box), Flea & Tick preventative ($59.17/box), Office exam ($20.00), X-Rays 1 film ($50.00), are offered to the clients. I have to surmise that vaccinations are indeed a very large source of income a veterinarian depends upon.

    Remarks such as, "It?s based on lots of years of precedent and experience with things that work," "I?d rather be over-protected than under-protected," "I bet she?s never seen rabies, I have."

    ?First, medicine changes all the time, regardless of what type of medicine is being practiced; veterinary medicine, pediatrics, geriatrics, oncology, etc. There have been many discoveries made throughout the centuries which have set "precedence" however, they are no longer used in treatment because research has shown there is no benefit, or the risks outweigh the benefit, or risks include further damage, disease or even death. Research is constantly showing better and healthier treatments and continually replacing older or outdated methods of care. This is what Progress is all about. Something which may have worked 20 years ago may not work today because of a lot of different factors.

    ?One remark that really caught my attention was the belief to "over-vaccinate than under-vaccinate." I?m not sure how to digest this statement. Would one also be willing to over-vaccinate their children or grandchildren? I would much rather have my pets vaccinated and then have titers drawn to determine if the vaccine is still working; just as the medical profession does for many human vaccinations. I spent over 10 years in the military; we were required to have several vaccinations, including a vaccination for HIV. While I was administered the original live virus vaccination (not the synthetic), I have not been required to be revaccinated since the original series. I have had blood titers drawn, which indicate the vaccination still remains active even after more than 25 years. I would certainly have some concern if I were required to have a live HIV virus vaccination injected into my body on an annual basis. Revaccination or boosters are only needed if the titers indicate. Vaccinations in animals offer the same protection and are effective for several years, if not a lifetime. I personally do not wish to have myself, my family, or my pets to be over-vaccinated.

    ?I feel when one makes such a statement regarding cases they have seen, a full disclosure of those cases should also be made. For example, how long ago (1 yr ago vs. 20 years ago) and what were the other circumstances (was the animal vaccinated or not, where was the animal located, did the animal have other existing medical issues, what was the age of the animal, what were the living conditions, was the animal a stray, was the animal domesticated or feral, etc.). Yes, rabies is terrible, no one will argue that. However, most rabies cases in humans are the result of transmission from bats, not dogs, cats or other domesticated animals.

    ?"I bet she?s never seen rabies." How can one make a comment such as this without truly knowing if it is true or not. This gives the appearance of making an attempt to instill "fear and/or panic" in the readers, while also trying to discredit an opposing view. It is my understanding that all the veterinary teaching schools across the country have adopted and now recommend the 3-year booster, including the very school which some of those interviewed and the clinic?s entire veterinarian staff have trained at, Texas A&M. I phoned Texas A&M today to ask what they teach and the response: "We teach to vaccinate for rabies at 12 weeks, 1 year (12 weeks, 12 months) and 3-year booster using Merial Imrab 3." I am actually quite surprised there is a belief that rabies boosters should remain as an annual vaccination.

    I simply do not share the belief that rabies boosters should be administered annually, especially since so many other veterinary schools and practitioners across the nation also agree with the 3-year rabies booster, including the American Veterinarian Medical Association and Center for Disease Control. Even the State of Texas requires the 3-year booster, not an annual vaccination. While it may be easier to seek the opinions of local professionals because they may be more readily available to answer questions, theirs? should not be the only opinion relied upon for decisions which not only affect policy, but also the health and welfare of the members of the community and their pets. County rabies ordinance should be based on the scientific data presented by the CDC, National Association of State Public Health Veterinarians and the American Veterinary Medical Association rather than on opinions of local veterinarians whose income may be directly impacted by a change in the ordinance. I have included several articles regarding such data. Much more is available online, as well as from many well respected veterinarians and teaching facilities across our great Nation. I am not a veterinarian and I have not attended medical school, but this does not make me any less intelligent or concerned regarding this issue. I am a member of this community and I believe in progress. I am concerned about the welfare of my pets. In closing, I respectfully urge you to reconsider the current rabies vaccination policy and to institute the 3-year protocol for Bell County.

    Sincerely, Patti Emmerling

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  • Update: July 23, 2009 article in the Killeen Daily Herald on efforts to change the annual rabies ordinance in Bell County, Texas: Animal Advisory Committee Works to Revamp Rabies Policy http://www.kdhnews.com/news/story.aspx?s=34716

    "Killeen's animal advisory committee can't change the annual rabies vaccination policy ? so it's going to the source.

    The committee is sending representatives to the Bell County Commissioners Court and the Killeen City Council in an effort to change the county's policy on rabies vaccinations."

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  • TEXAS: Bell County Relaxes Rabies Shots Requirements Temple Daily Telegram 2/8/11 http://www.tdtnews.com/story/2011/02/08/72249/

    "the county has essentially adopted the state standard, which allows an attending veterinarian to determine, together with the pet owner, how often the shots are needed. "

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