CALIFORNIA Rabies Bill AB 272 ACTION ALERT

[Kris L. Christine]

*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 'AB 272 Assembly Bill - INTRODUCED'
(http://tinyurl.com/aqycrpm) .

*_What_You_Can_Do_to_Help:*_

Please contact Mr. Gomez & ask him to *WITHDRAW* this bill!
Assemblyme...@Asm.CA.Gov (916) 319-2051

PERMISSION GRANTED TO CROSS-POST




--
Kris L. Christine

[Kris L. Christine]

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
'Duration of Immunity Study for Rabies Vaccine - Rabies Challenge Fund'
(http://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.




--
Kris L. Christine

[Kris L. Christine]

*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 'AB 272 Assembly Bill

- INTRODUCED' (http://tinyurl.com/aqycrpm).

*_What_You_Can_Do_to_Help:*_

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

*_California_Agriculture_Committee_Members*_

Susan T. Eggman, Chair assemblyme...@assembly.ca.gov (916)
319-2013
Kristen Olsen, Vice Chair assemblyme...@assembly.ca.gov (916)
319-2012
Toni Atkins assemblyme...@assembly.ca.gov (916) 319-2078
Brian Dahle assemblyme...@assembly.ca.gov (916) 319-2001
Richard Pan assemblym...@assembly.ca.gov (916) 319-2009
Bill Quirk assemblyme...@assembly.ca.gov (916) 319-2020
Marioko Yamada assemblyme...@assembly.ca.gov (916) 319-2020

*PERMISSION GRANTED TO CROSS-POST*




--
Kris L. Christine

[Kris L. Christine]

URGENT ACTION ALERT: CALIFORNIA AB 272, [/B]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://tinyurl.com/btoxq76 .

*_WHAT_YOU_CAN_DO_TO_HELP:*_

CONTACT APPROPRIATIONS COMMITTEE MEMBERS MIKE GATTO (CHAIR) (916)
319-2043 ASSEMBLYME...@ASM.CA.GOV & SUSAN T. EGGMAN
ASSEMBLYME...@ASM.CA.GOV (916) 319-2013 & ASK THEM TO *OPPOSE AB
272.

PERMISSION GRANTED TO CROSS-POST

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
LEDGE...@LINCOLN.MIDCOAST.COM & I WILL E-MAIL IT TO YOU.

(link to committee comments on AB 272 'AB 272 Assembly Bill - Bill
Analysis' (http://tinyurl.com/b5ed3k5))

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 [b]-_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
'Duration of Immunity Study for Rabies Vaccine - Rabies Challenge Fund'
(http://www.RabiesChallengeFund.org)

ledge...@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.




--
Kris L. Christine

[Kris L. Christine]

*_URGENT_ACTION_ALERT:_ CALIFORNIA AB 272,* which would lower the age at
which puppies must be vaccinated from four months to three months will
be heard by the Assembly Appropriations Committee on Wednesday April
10th 'AB 272 Assembly Bill - Status' (http://tinyurl.com/cs9sy36)

Please contact Appropriations Committee Chair Mike Gatto (916) 319-2043
assemblyme...@asm.ca.gov & ask the committee to *OPPOSE AB 272. *




--
Kris L. Christine

[Kris L. Christine]

Dr. W. Jean Dodds' Interview with Dr. Karen Becker on California AB 272
https://www.youtube.com/watch?v=kZzmVtfzO08




--
Kris L. Christine

[Kris L. Christine]

*URGENT CALIFORNIA AB 272,* lowering the age at which puppies must be
vaccinated against rabies from 4 to 3 months will have 2nd full House
consideration *TODAY*. Contact your legislators & tell them to *OPPOSE
AB 272 * 'Find Your California Representative'
(http://findyourrep.legislature.ca.gov/).

Unfortunately, Appropriations unanimously passed this yesterday, despite
the bill summary 'AB 272 Assembly Bill - Bill Analysis'
(http://tinyurl.com/dygkjgq) indicating that, as currently worded, it
will not accomplish the authors' stated goals. California Assembly
calendar for today
ftp://leginfo.public.ca.gov/pub/dailyfile/asm/assembly_floor .

Dr. W. Jean Dodds' video interview with Dr. Karen Becker on California
AB 272 https://www.youtube.com/watch?v=kZzmVtfzO08 .




--
Kris L. Christine

[Kris L. Christine]

[Kris L. Christine]

*CALIFORNIA AB 272*, lowering the age at which puppies must be
vaccinated against rabies from 4 to 3 months will have its 2nd full
House vote Monday April 15. Please contact your legislators & tell them
to *OPPOSE AB 272* 'Find Your California Representative'
(http://findyourrep.legislature.ca.gov/).

Assembly Calender for Monday April 15th
ftp://leginfo.public.ca.gov/pub/dailyfile/asm/assembly_floor




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Kris L. Christine