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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
_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 do***enting
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 tem****ary, 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 sup****ts 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
'About the Rabies Challenge Fund' (http://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
--
Kris L. Christine
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