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California Rabies Bill Ab 272 Action Alert


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CALIFORNIA ACTION ALERT: Rabies Bill AB 272
introduced by Assemblyman Gomez seeks to lower required age of vaccination to 12
weeks from the current 16 weeks http://www.leginfo.ca.gov/pub/13-14/bill/asm/ab_0251-0300/ab_272_bill_20130207_introduced.html .


What You Can Do to Help:


Please contact Mr. Gomez & ask him to
WITHDRAW this bill! assemblymember.gomez@assembly.ca.gov (916) 319-2051


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Edited by Kris L. Christine
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Below is my letter to Assemblymember Gomez on behalf of The Rabies Challenge Fund.

February 13, 2013

Assemblymember Jimmy Gomez
State Capitol
P.O. Box 942849
Sacramento, CA 94249-0051


RE: AB 272 An Act to Amend Section 121690 of the Health and Safety Code Relating to Rabies

Greetings Assemblymember Gomez:

Assembly Bill AB 272 which you have introduced seeking to lower the age at which dogs must be vaccinated against rabies from 4 months to 3 months is ill-advised and scientifically unfounded. The bill seeks to address a problem in the canine community that does not exist, as the California Department of Public Health’s statistics in Reported Animal Rabies Data make abundantly clear: bats and other wildlife pose the major threat of rabies transmission to the public, not dogs under the age of 4 months.

Three cases of rabies in dogs since 2007 (no mention of them being dogs under 4 months of age), as opposed to 981 rabid bats and 147 rabid skunks for the same period, 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.

Lowering the age at which puppies are required to have their first rabies shot from 4 months to 3 months would be counterproductive. Puppies are finishing up their other vaccinations (distemper, hepatitis, parvo) at 12 weeks (3 months) of age, and adding a rabies vaccine into the mix will not only increase the likelihood of adverse reactions, but also the probability that the vaccine components will interfere with each other and neutralize or negate the desired immunological response.

Contributing to the chance 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......" [1] 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. The 2003 American Animal Hospital Association's (AAHA) Canine Vaccine Guidelines reports on Page 16 that: "When vaccinating an animal, the age of the animal, the animal's immune status, and interference by maternal antibodies in the development of immunity must be considered. Research has demonstrated that the presence of passively acquired maternal antibodies interferes with the immune response to many canine vaccines, including CPV, CDV, CAV-2 and rabies vaccines.” [2]

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 and the many concerned California pet owners who have requested our assistance, I strongly urge you to withdraw AB 272.

Respectfully submitted,

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


cc: Dr. W. Jean Dodds
Dr. Ronald Schultz
California Assembly
--------------------------------------------------------------------------------


[1] American Animal Hospital Association Canine Vaccine Task Force. 2006 Canine Vaccine Guidelines, Recommendations, and Supporting Literature, 28pp.
[2] American Animal Hospital Association Canine Vaccine Task Force. 2003 Canine Vaccine Guidelines, Recommendations, and Supporting Literature, 28pp.

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  • 2 weeks later...
CALIFORNIA RABIES
BILL AB 272 seeking to lower the required age of
vaccination for dogs from 16 weeks to 12 weeks will have a
hearing 3/13/13 before the Assembly Agriculture Comittee http://www.leginfo.ca.gov/pub/13-14/bill/asm/ab_0251-0300/ab_272_bill_20130207_introduced.html.



What You Can Do to
Help:



Contact Committee Chair Susan Eggman assemblymember.eggman@assembly.ca.gov (916) 319-2013 & committee members below and ask them
TO REJECT this bill.



California Agriculture
Committee Members



Susan T. Eggman, Chair assemblymember.eggman@assembly.ca.gov
(916) 319-2013


Kristen Olsen, Vice Chair assemblymember.olsen@assembly.ca.gov (916) 319-2012


Toni Atkins assemblymember.atkins@assembly.ca.gov (916) 319-2078


Brian Dahle assemblymember.dahle@assembly.ca.gov (916) 319-2001


Richard Pan assemblymember.pan@assembly.ca.gov (916) 319-2009


Bill Quirk assemblymember.quirk@assembly.ca.gov (916) 319-2020


Marioko Yamada assemblymember.yamada@assembly.ca.gov (916) 319-2020



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  • 2 weeks later...
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.



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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 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.
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