WYOMING Rabies Laws--Movement to Change

[Kris L. Christine]

Following a 3/22/08 article entitled Vaccine overkill? in the Wyoming News Wyoming Tribune-Eagle Online by Baylie Davis and inspired by encouraging developments in Kansas, Wyoming dog owners have contacted Wyoming's Governor, Attorney General as well as the Mayor of Cheyenne imploring the state to adopt the national standard of a 3 year rabies vaccination protocol.


What You Can Do To Help

1.) Contact Cheyenne Mayor Jack Spiker mayor@cheyennecity.org Phone: (307) 637-6200; Fax: (307)637-6378


Below is a copy of a letter I wrote in support of the request for change to a 3 year protocol.

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March 30, 2008


Governor Dave Freudenthal Attorney General Bruce A. Salzburg
State Capitol, 200 West 24th Street State Capitol, 200 West 24th Street
Cheyenne, WY 82002-0010 Cheyenne, WY 82002-0010

RE: WYOMING’S ANNUAL RABIES LAWS/ORDINANCES

Greetings Governor Freudenthal and General Salzburg:


The time for Wyoming to adopt a uniform, state-wide 3 year canine rabies immunization protocol conforming to the national standard is long overdue. Scientific data demonstrating a minimum duration of immunity for the canine rabies vaccine of 3 years by challenge and 7 years serologically was incorporated into the 2003 American Animal Hospital Association’s Canine Vaccine Guidelines more than 5 years ago.

Because the rabies vaccine is the most potent of the veterinary vaccines and associated with significant adverse reactions, it should not be given more often than is necessary to maintain immunity. Adverse reactions such as 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 linked to rabies vaccinations.

The rabies is a “killed” vaccine and 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," [1] 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).” [2] According to the 2003 American Animal Hospital Association’s Canine Vaccine Guidelines, "...killed vaccines are much more likely to cause hypersensitivity reactions (e.g., immune-mediated disease)."

Many, if not all, annual rabies vaccines are 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.” Wyoming city laws/ordinances requiring annual rabies boosters do not enhance an animal’s immunity and needlessly expose dogs to the risk of adverse reactions. 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.”

Of importance to policy makers is data indicating that compliance rates are no higher in states 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.” [3]

The Center for Disease Control’s National Association of State Public Health Veterinarian's Compendium of Animal Rabies Prevention and Control 2007 recommends that: "Vaccines used in state and local rabies-control programs should have at least a 3-year minimum duration of immunity.” They state further that, “No laboratory or epidemiologic data exist to support the annual or biennial administration of 3- or 4-year vaccines following the initial series.”

Medical, epidemiological, and scientific data, as well as the recommendations of the Center for Disease Control’s National Association of State Public Health Veterinarians’ Compendium of Animal Rabies Prevention and Control 2007 and the American Animal Hospital Association’s Canine Vaccine Guidelines for 2003 and 2006 evidence the need for Wyoming to revise its state-wide rabies immunization requirements for dogs by adopting the national 3 year standard in all municipalities.

Perhaps Attorney General Salzburg’s department could issue a legal opinion on whether or not municipalities with annual rabies vaccination requirements are violating Wyoming’s consumer protection laws by mandating that dog owners pay for yearly veterinary procedures from which their animals derive no benefit.

I strongly urge you to conform all of the state’s rabies immunization requirements to the 3 year standard so that Wyoming dogs are no longer put at unnecessary risk of harmful side affects by being forced to receive medically unwarranted annual rabies boosters.

Sincerely,

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


cc: Cheynne Mayor Jack Spiker

Cheyenne City Council

Director of Department of Agriculture, John Etchepare

Deputy Director of Department of Agriculture, Jason Fearneyhough

Wyoming Legislature



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[1] 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.

[2] 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)

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

__________________________________________________ __________________________________________________ ______________________________

[Kris L. Christine]

WYOMING Rabies Laws--Update

To update you on efforts to change Wyoming's rabies laws, on Saturday April 12, 2008, an article entitled Changes to Vaccine Ordinance Unlikely Wyoming Tribune-Eagle Online was published in the Wyoming News.

Below is a copy of a letter to the editor I sent to the paper this morning.

What You Can Do To Help

1.) Contact Cheyenne Mayor Jack Spiker mayor@cheyennecity.org Phone: (307) 637-6200; Fax: (307)637-6378
2.) Leave a comment on the newspaper article at Wyoming Tribune-Eagle Online
3.) Write a letter to the editor of the Wyoming News (Scott Smith) ssmith@wyomingnews.com Fax: 307-633-3189

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April 14, 2008

To the Editor:

There are a number of issues in the April 12, 2008 article entitled Changes to Vaccine Ordinance Unlikely that need to be addressed.

The state veterinarian, Dr. Walter Cook, seems to be unaware that the national organization of which he is supposed to be a member, the Center for Disease Control’s (CDC) National Association of State Public Health Veterinarians (NASPHV), currently recommends a 3 year rabies vaccination protocol in their 2008 Compendium of Animal Rabies Prevention and Control and has done so since at least 2001. The American Veterinary Medical Association also endorses the NASPHV’s 3 year rabies immunization protocol.

Contrary to Dr. Cook’s statement, veterinarians are not required to report adverse reactions to vaccines and the World Small Animal Veterinary Association (WSAVA) stated in 2007 there is “gross under-reporting of vaccine-associated adverse events which impedes knowledge of the ongoing safety of these products.” In an article entitled, A New Approach to Reporting Medication and Device Adverse Effects and Product Problems, (JAMA - June 2, 1993. Vol.269, No.21) Dr. David Kessler, former head of the Food & Drug Administration, reported that "only about 1% of serious events are reported to the FDA."

Studies demonstrating long-term (more than 3 years) duration of immunity for the canine rabies vaccine have already been published. In 1992, a French research team led by Michel Aubert published the results of a rabies challenge study in Scientific Technical Review (Rev. sci.tech. Off. int. Epiz.) 1992, 11 (3), 735-760 in which they demonstrated that dogs were immune to a rabies challenge 5 years after vaccination. The serological studies of Dr. Ronald Schultz of the University of Wisconsin School of Veterinary Medicine showed that dogs had antibody titers counts at levels known to confer immunity to rabies 7 years after vaccination, the results of which have been incorporated into the 2003, 2006 American Animal Hospital Association’s Canine Vaccine Guidelines as well as WSAVA’s 2007 Vaccine Guidelines.

Because the rabies vaccine is the most potent of the veterinary vaccines and associated with significant adverse reactions, it should not be given more often than is necessary to maintain immunity. Adverse reactions such as 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 linked to rabies vaccinations.

Rabies is a “killed” vaccine and contains adjuvants to enhance the immunological response. Mercury (Thimersol) is commonly found as a preservative in killed, adjuvanted veterinary vaccines such as Rabies, Leptospira, and Lyme. The combination of mercury with adjuvant components (aluminum hydroxide, aluminum phosphate) are of considerable concern because of the reactive properties of aluminum, when in contact with mercury. Reactivity with aluminum is so acute that mercury may not be packed in checked or carry-on baggage on commercial airplanes, and there is currently a petition to Congress Petition to Congress, Removal of Aluminum Additive in Vaccines Resolution and Petition, citing as cause for removing aluminum in human vaccines that: "The combination of mercury plus aluminum is far worse than the sum of the two toxicities added together. The synergistic toxicity could be increased to unknown levels."

In 1999, the World Health Organization "classified veterinary vaccine adjuvants as Class III/IV carcinogens with Class IV being the highest risk," 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).” According to the 2003 American Animal Hospital Association’s Canine Vaccine Guidelines, "...killed vaccines are much more likely to cause hypersensitivity reactions (e.g., immune-mediated disease)."

A clarification on the Postmarketing Surveillance of Rabies Vaccines for Dogs to Evaluate Safety and Efficacy referenced in the story. Only the 246 adverse reactions to the rabies vaccine reported directly to the Center for Veterinary Biologics by the public, veterinarians, and pet owners had 72% of the dogs receiving other vaccines or drugs at the same time as the rabies shot. That is not stated to be the case further on in the report where they discuss the 10,000 adverse reactions reported by the rabies vaccine manufacturers, 65% of which were in dogs.

If the 6,500 of canine adverse rabies vaccine reactions reported by the vaccine manufacturers represents "only about 1% of serious events are reported to the FDA,” then that would translate into 650,000 if all reactions were reported.

Cheyenne Mayor Jack Spiker and State Public Health Veterinarian, Dr. Cook, should be guided by the recommendations of the CDC’s National Association of State Public Health Veterinarians and the American Veterinary Medical Association to determine the state’s and city’s rabies immunization protocols rather than seeking the advice of local animal shelters and veterinary practitioners to determine appropriate protocols.

Sincerely,

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

[Kris L. Christine]

4/29/08 Wyoming Rabies Law Update and ISDRA--International Sled Dog Racing Association

Once again, dog lovers are helping to bring about great changes for dogs with active participation on rabies laws -- THANK YOU to all of you who have been assisting in these efforts -- it's working!

Kris

Wyoming update: The e-mail below, shared with permission from the recipient, from the President of the Cheyenne City Council, Don Pierson, was received 4/29/08 by the lead activist in Wyoming, Karon Volk:

"Hello Mrs. Volk Just a followup to let you know that the Mayor and I are working together and have instructed the city attorney to prepare an ordinance or a resolution to take care of the 1 year vs 3 year problem. All the research I have found says that to require our city residents to get the vaccination for their pets every year is unnecessary. I will let you know when it will be ready for introduction and would hope that you would like to attend our meetings and testify about the situation. Let me know if there is anything else I can do at this time about this situation. Thanks for all your info you provided and your concern."

ISDRA-International Sled Dog Racing Association: After Steve Goldman, a concerned ISDRA member, contacted the International Sled Dog Racing Association about ISDRA sanctioned races requiring annual rabies vaccinations for sled dogs and asked for assistance, I wrote the letter to the Executive Director Below. Mr. Steele responded immediately and will be publishing announcements in 2 issues of Dog and Driver before the proposal comes before the full ISDRA Board.

What You Can Do

If you are concerned about racing events that require sled dogs to receive redundant annual rabies boosters, please e-mail Dave Steele at dsteele@brainerd.net

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March 18, 2008

Mr. Dave Steele, Executive Director
International Sled Dog Racing Association
22702 Rebel Road
Merrifield, MN 56465, USA
E-mail: dsteele@brainerd.net

Greetings Mr. Steele:


One of the objectives listed in the International Sled Dog Racing Association’s (ISDRA) Constitution and By-Laws under Article II C is to: “Promote the welfare of sled dogs in all activities and endeavors.” Further on, under Article IX Section 2 A 4, it declares one of the duties of the Animal Welfare Committee shall be to: “Inform the membership of new advances in canine nutrition and all areas related to the physical and mental well-being of sled dogs."

With those objectives and the physical and mental well-being of sled dogs in mind, I am writing to request that ISDRA’s Board of Directors seriously consider alerting its membership to the potential health hazards associated with redundant annual rabies vaccinations, which some U.S. and Canadian races require for team entrants.

Annual rabies vaccinations after the initial puppy series are medically unnecessary and contrary to the recommendations of the Center for Disease Control’s (CDC) National Association of State Public Health Veterinarian's (NASPHV) Compendium of Animal Rabies Prevention and Control which declare that: "Vaccines used in state and local rabies control programs should have at least a 3-year duration of immunity,”[1] and should be administered no more often than specified by the product label or package insert. The American Veterinary Medical Association (AVMA) endorses a 3 year protocol as does the American Animal Hospital Association (AAHA).[2]

Many, if not most or all, annual rabies vaccines are the 3 year vaccine relabeled for annual use. 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 2007 AAHA Canine Vaccine Guidelines as well as the World Small Animal Veterinary Association’s (WSAVA) 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.”[3]

Because the rabies vaccine is the most potent of the veterinary vaccines and associated with significant adverse reactions, it should not be given more often than is necessary to maintain immunity. Adverse reactions such as 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 linked to rabies vaccinations.

Rabies is a “killed” vaccine, for which internationally accepted scientific data have demonstrated a minimum duration of immunity of 3 years by challenge and 7 years serologically. The rabies vaccine, and other killed vaccines such as Leptospira and Lyme, contains adjuvants such as aluminum hydroxide, aluminum phosphate, and aluminum potassium sulfate 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,"[4] 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).” [5] According to the 2003 AAHA Canine Vaccine Guidelines, "...killed vaccines are much more likely to cause hypersensitivity reactions (e.g., immune-mediated disease)."[6]

With the physical challenges of the trail to meet, sled dogs should not be exposed to the health hazards associated with medically unwarranted annual rabies boosters in order to enter racing events. I strongly urge you to inform your membership of the potential risks associated with unnecessary annual rabies vaccinations and request that ISDRA only sanction races that conform to the 3 year standard recommended by the Center for Disease Control’s National Association of State Public Health Veterinarians, the American Veterinary Medical Association, and the American Animal Hospital Association.

If you have any questions or would like copies of the material referenced above, please contact me at [redacted].

Sincerely,

Kris L. Christine
Founder, Co-Trustee
The Rabies Challenge Fund


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[1] Center for Disease Control’s National Association of State Public Health Veterinarian's Compendium of Animal Rabies Prevention and Control http://www.nasphv.org/Documents/RabiesCompendium.pdf

[2]The American Veterinary Medical Association’s 2007 RABIES VACCINATION PROCEDURES www.avma.org/products/scientific/biologics.pdf

The 2006 American Animal Hospital Association's Canine Vaccine Guidelines are downloadable in PDF format at About AAHA

[3] What Everyone Needs to Know about Canine Vaccines, Dr. Ronald Schultz What Everyone Needs to Know About Canine Vaccines

Duration of Immunity to Canine Vaccines: What We Know and Don't Know, Dr. Ronald Schultz Duration of Immunity

World Small Animal Veterinary Association 2007 Vaccine Guidelines - WSAVA - Scientific Advisory Committee Scroll down to Vaccine Guidelines 2007 (PDF)

[4] 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

[5] 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)

[6] The 2003 American Animal Hospital Association's Canine Vaccine Guidelines are accessible online at Special Report

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More information on the rabies vaccine can be found at the following links :

Animal Wellness Magazine Article Vol. 8 Issue 6, How Often Does he REALLY Need A Rabies Shot Animal Wellness Magazine - devoted to natural health in animals

The Rabies Challenge Animal Wise Radio Interview
Listen to Animal Wise (scroll down to The Rabies Challenge 12/9/07)

The Vaccine Challenge Animal Talk Naturally Online Radio Show » The Vaccine Challenge - Show #91