The Pet Wellness Update
Dedicated to Rabies Medical Exemption Nationwide
Medical Exemption
Texas Says "No" Rabies Medical Exemption
Austin, TX , September 11, 2007 - In early August, Bob Rogers, DVM of Houston, and Pamela Picard, an Austin resident and advocate for rabies medical exemption, presented a petition to the Texas Department of Health Services (TDHS) oversight committee. It urges a provision to allow veterinary discretion in revaccinating dogs and cats when they are sick or frail. A legion of animal lovers and veterinary professionals endorses rabies medical exemption.
Proponents for relaxing the rules argue that label directions on USDA-approved rabies vaccine intend it "for healthy dogs and cats;" duration of immunity after the initial series of inoculations lasts up to seven years; there is no medical basis for repeating rabies shots; and that frequent and unnecessary re-vaccination is known to cause vaccine-related illness and death in companion animals.
"Any pet that has had at least two rabies vaccinations in its lifetime is at very minimal risk of developing rabies, and it is unlikely that this patient will benefit from another vaccination," wrote Dr. Bob Rogers in a letter sent ahead of the public meeting to Dr. Tom Sidwa, Texas State Public Health Veterinarian. "Veterinarians should have discretion in assessing the risk of the pet being exposed to rabies vs. the risk of an adverse and potentially fatal reaction.
TDHS defends tighter rabies laws; they believe this is the only way to prevent and control the untoward transmission of rabies from dogs and cats to humans.
No provision for discretion
As proposed, Texas veterinarians will have no discretion in assessing the risk versus benefit of administering rabies vaccine and no allowance to postpone or waive a rabies re-vaccination for any reason. All dogs and cats, including service dogs and therapy dogs, must be vaccinated according to the law regardless of health status or potential risk.
No safety and efficacy standards
Texas Department of Health Services proposes to gut language that establishes safety and efficacy standards for administration of rabies. The label on all rabies vaccines licensed by the USDA specifies, "For administration to healthy dogs and cats". (1)
Veterinary vaccines are not regulated by the FDA; there is no legal consideration if they are used - or abused - contrary to label directions. For the animal’s welfare, a prudent veterinarian would postpone re-vaccination of an animal during pregnancy, under general anesthesia, with infection, during radiation or chemotherapy or after an emergency. Then, there are efficacy considerations. Even a slight fever can affect the efficacy of rabies vaccine.
Deleting this provision to follow label directions is ill-advised. Moreover, it strikes at the heart of what it means to be a physician: - first do no harm.
Primum non nocere: First do no harm
"People have to get over the idea that repeating rabies shots is harmless," says Pamela Picard, who spearheads the initiative to grant a rabies medical exemption. "Dogs and cats are developing serious and sometimes deadly conditions from it."
Vaccine associated sarcoma (VAS) occurs in as many as 10 in every 10,000 vaccinations. It can take five years to manifest. (2)
Immune-mediated hemolytic anemia (IMHA) and immune-mediated thrombocytopenia (ITP) are diseases associated with over-vaccinating dogs and cats in which the body's own immune system attacks and destroys its red blood cells (IMHA) or platelets (ITP). A higher incidence of IMHA is seen in dogs within a month of vaccination. Prognosis is guarded. (3)
Companion animals are suffering chronic diseases previously unknown in pets - allergies, asthma, arthritis, ear infections, thyroid disease, heart disease, kidney failure and cancer. While dogs and cats can live with some of these afflictions, the symptoms are costly to manage, detrimental to quality of life and shorten the life span of family pets. (4)
No loss of immunity
A study published in 1992, by Michel Aubert, a research scientist, demonstrated that dogs were immune to a rabies challenge five years after a single vaccination. (5)
Serological studies done by Dr. Ronald Schultz, Professor and Chair, Patho-biological Sciences, the University of Wisconsin School of Veterinary Medicine over the course or 30 years show that dogs have antibody titer counts at levels that confer immunity to rabies seven years after one vaccination. (6)
No medical necessity
Yet the practice of re-vaccination at one or three-year intervals persists. This is purely on the basis of precedent, not science.
According to a landmark report on dogs and cat vaccines published in 2002 by the AVMA Council on Biologic and Therapeutic Agents (COBTA), there is no scientific basis for annual revaccination. Re-administering rabies vaccine does not enhance disease resistance and may expose animals to unnecessary risk. (7)
To be perfectly clear: the duration of a license may expire; a drug with a shelf life may expire on the shelf; a dog or cat's immunity to rabies does not expire in one or three years.
All dogs and cats endangered
The only reason to re-vaccinate cats and dogs is to guard against mistakes in the interpretation of rabies laws by animal control officers.
As written, any animal that is overdue for rabies re-vaccination by a week or month (according to the interval of the drug the veterinarian recommends) would be deemed "unvaccinated" because it has not been revaccinated before the interval lapses.
If a dog or cat deemed that is deemed unvaccinated is suspected of rabies exposure, no matter how many rabies shots it has had in its life, it will be isolated and confined for 90 days at the expense of up to $1500 to its family. If the family cannot afford this, the animal is needlessly killed.
K9 cops are exempt; the disposition of service dogs and therapy dogs is left to the discretion of local animal control officers. This language needs clarification; animal control officers are not educated to interpret the law.
Little risk of public exposure
After the first rabies inoculation, and most certainly after one re-vaccination, the risk of public exposure to rabies is less than minuscule.
According to a research study published in 1992 by Michel Aubert, a dog or cat that has been inoculated with rabies vaccine once in its life has a less than 1 in 8 million chance of contracting rabies. (8)
This remote risk is reduced to the infinitesimal when a dog or cat has had two rabies inoculations, lives with no chance of exposure to rabies and is closely supervised by its owner. In these instances, a rabies medical exemption is no danger to public health.
No change in compliance
In 2002, TDHS Zoonosis Control Division reported that roughly 50 percent of six million Texas dogs and only 25 percent of 6.6 million owned cats were vaccinated against rabies. Four years later, the pet population has doubled, rabies in dogs and cats has gone down and compliance among irresponsible pet owners remains unchanged.
Big risk of unintended consequences
By eliminating the infinitesimal, TDHS raises the risk of unintended consequences for all pets and their families by an order of magnitude. Regrettably, only responsible and law-abiding citizens who consider their pets valued members of our human family pay the price.
"After two VAS cats and $25,000, I think vaccines suck." says Kris Hanson, a pet owner who provided testimony enact rabies medical exemption in Connecticut. "How's that for this so called 'very rare VAS?' I had four cats and two had VAS; that's 50 percent in my house alone."
Significant economic impact
In fiscal notes, State of Texas officials see "no anticipated economic costs to persons who are required to comply with the sections as proposed." Insofar as rabies laws affect small and micro business, this is accurate; relative to economic impact on the Texas public who must comply with rabies laws, "not so much."
According to cat owners recently facing VAS, surgical removal and post-operative care for cats with injection site cancer is around $6,000. VAS treatment expenses that reach $10,000 are becoming more common. When post-op care includes radiation and chemotherapy, veterinary medical expense easily double those costs to $20,000. Morbidity in VAS cats if high.
These costs are just the tip of the iceberg.
Ear and skin conditions are the most common problems veterinarians deal with day to day. Often pet owners report that these begin shortly after re-vaccination and are exacerbated with every subsequent vaccine. Chronic, incurable health issues are detrimental to a dog or cat’s quality of life and longevity. Treatment is financially draining to its family.
Cui bono: who benefits?
Based on a study published in 2004 by Texas A&M College of Veterinary Medicine and Biomedical Sciences and the Texas Veterinary Medical Association, 21 million Texans owned pets. In 2003 alone, the financial outpouring of love and devotion amounted to $2.8 billion for food and veterinary medical services in addition to medicine and supplies.
This is significant economic impact by any one's accounting; all the more so when needless vaccinations with no real medical value affect your cat or dog and you're footing the bill.
Now that State of Texas Health Services has turned a deaf ear to requests for a reasonable reform and a blind eye to the multiple negative effects (read economic impact) of an unnecessary and potentially deadly medical procedure, Texas veterinary professionals can expect more pet-crazy clients to ask, "Cui bono: who benefits?"
Read TDHS proposed rule changes
Comments on the proposal may be submitted in writing to Tom Sidwa, DVM, Department of State Health Services, Community Preparedness Section, Zoonosis Control Branch, P. O. Box 149347, Austin, Texas 78714-9347, or by email to Tom.Sidwa@dshs.state.tx.us.
Read reference citations
Austin, TX , September 11, 2007 - In early August, Bob Rogers, DVM of Houston, and Pamela Picard, an Austin resident and advocate for rabies medical exemption, presented a petition to the Texas Department of Health Services (TDHS) oversight committee. It urges a provision to allow veterinary discretion in revaccinating dogs and cats when they are sick or frail. A legion of animal lovers and veterinary professionals endorses rabies medical exemption.
Proponents for relaxing the rules argue that label directions on USDA-approved rabies vaccine intend it "for healthy dogs and cats;" duration of immunity after the initial series of inoculations lasts up to seven years; there is no medical basis for repeating rabies shots; and that frequent and unnecessary re-vaccination is known to cause vaccine-related illness and death in companion animals.
"Any pet that has had at least two rabies vaccinations in its lifetime is at very minimal risk of developing rabies, and it is unlikely that this patient will benefit from another vaccination," wrote Dr. Bob Rogers in a letter sent ahead of the public meeting to Dr. Tom Sidwa, Texas State Public Health Veterinarian. "Veterinarians should have discretion in assessing the risk of the pet being exposed to rabies vs. the risk of an adverse and potentially fatal reaction.
TDHS defends tighter rabies laws; they believe this is the only way to prevent and control the untoward transmission of rabies from dogs and cats to humans.
No provision for discretion
As proposed, Texas veterinarians will have no discretion in assessing the risk versus benefit of administering rabies vaccine and no allowance to postpone or waive a rabies re-vaccination for any reason. All dogs and cats, including service dogs and therapy dogs, must be vaccinated according to the law regardless of health status or potential risk.
No safety and efficacy standards
Texas Department of Health Services proposes to gut language that establishes safety and efficacy standards for administration of rabies. The label on all rabies vaccines licensed by the USDA specifies, "For administration to healthy dogs and cats". (1)
Veterinary vaccines are not regulated by the FDA; there is no legal consideration if they are used - or abused - contrary to label directions. For the animal’s welfare, a prudent veterinarian would postpone re-vaccination of an animal during pregnancy, under general anesthesia, with infection, during radiation or chemotherapy or after an emergency. Then, there are efficacy considerations. Even a slight fever can affect the efficacy of rabies vaccine.
Deleting this provision to follow label directions is ill-advised. Moreover, it strikes at the heart of what it means to be a physician: - first do no harm.
Primum non nocere: First do no harm
"People have to get over the idea that repeating rabies shots is harmless," says Pamela Picard, who spearheads the initiative to grant a rabies medical exemption. "Dogs and cats are developing serious and sometimes deadly conditions from it."
Vaccine associated sarcoma (VAS) occurs in as many as 10 in every 10,000 vaccinations. It can take five years to manifest. (2)
Immune-mediated hemolytic anemia (IMHA) and immune-mediated thrombocytopenia (ITP) are diseases associated with over-vaccinating dogs and cats in which the body's own immune system attacks and destroys its red blood cells (IMHA) or platelets (ITP). A higher incidence of IMHA is seen in dogs within a month of vaccination. Prognosis is guarded. (3)
Companion animals are suffering chronic diseases previously unknown in pets - allergies, asthma, arthritis, ear infections, thyroid disease, heart disease, kidney failure and cancer. While dogs and cats can live with some of these afflictions, the symptoms are costly to manage, detrimental to quality of life and shorten the life span of family pets. (4)
No loss of immunity
A study published in 1992, by Michel Aubert, a research scientist, demonstrated that dogs were immune to a rabies challenge five years after a single vaccination. (5)
Serological studies done by Dr. Ronald Schultz, Professor and Chair, Patho-biological Sciences, the University of Wisconsin School of Veterinary Medicine over the course or 30 years show that dogs have antibody titer counts at levels that confer immunity to rabies seven years after one vaccination. (6)
No medical necessity
Yet the practice of re-vaccination at one or three-year intervals persists. This is purely on the basis of precedent, not science.
According to a landmark report on dogs and cat vaccines published in 2002 by the AVMA Council on Biologic and Therapeutic Agents (COBTA), there is no scientific basis for annual revaccination. Re-administering rabies vaccine does not enhance disease resistance and may expose animals to unnecessary risk. (7)
To be perfectly clear: the duration of a license may expire; a drug with a shelf life may expire on the shelf; a dog or cat's immunity to rabies does not expire in one or three years.
All dogs and cats endangered
The only reason to re-vaccinate cats and dogs is to guard against mistakes in the interpretation of rabies laws by animal control officers.
As written, any animal that is overdue for rabies re-vaccination by a week or month (according to the interval of the drug the veterinarian recommends) would be deemed "unvaccinated" because it has not been revaccinated before the interval lapses.
If a dog or cat deemed that is deemed unvaccinated is suspected of rabies exposure, no matter how many rabies shots it has had in its life, it will be isolated and confined for 90 days at the expense of up to $1500 to its family. If the family cannot afford this, the animal is needlessly killed.
K9 cops are exempt; the disposition of service dogs and therapy dogs is left to the discretion of local animal control officers. This language needs clarification; animal control officers are not educated to interpret the law.
Little risk of public exposure
After the first rabies inoculation, and most certainly after one re-vaccination, the risk of public exposure to rabies is less than minuscule.
According to a research study published in 1992 by Michel Aubert, a dog or cat that has been inoculated with rabies vaccine once in its life has a less than 1 in 8 million chance of contracting rabies. (8)
This remote risk is reduced to the infinitesimal when a dog or cat has had two rabies inoculations, lives with no chance of exposure to rabies and is closely supervised by its owner. In these instances, a rabies medical exemption is no danger to public health.
No change in compliance
In 2002, TDHS Zoonosis Control Division reported that roughly 50 percent of six million Texas dogs and only 25 percent of 6.6 million owned cats were vaccinated against rabies. Four years later, the pet population has doubled, rabies in dogs and cats has gone down and compliance among irresponsible pet owners remains unchanged.
Big risk of unintended consequences
By eliminating the infinitesimal, TDHS raises the risk of unintended consequences for all pets and their families by an order of magnitude. Regrettably, only responsible and law-abiding citizens who consider their pets valued members of our human family pay the price.
"After two VAS cats and $25,000, I think vaccines suck." says Kris Hanson, a pet owner who provided testimony enact rabies medical exemption in Connecticut. "How's that for this so called 'very rare VAS?' I had four cats and two had VAS; that's 50 percent in my house alone."
Significant economic impact
In fiscal notes, State of Texas officials see "no anticipated economic costs to persons who are required to comply with the sections as proposed." Insofar as rabies laws affect small and micro business, this is accurate; relative to economic impact on the Texas public who must comply with rabies laws, "not so much."
According to cat owners recently facing VAS, surgical removal and post-operative care for cats with injection site cancer is around $6,000. VAS treatment expenses that reach $10,000 are becoming more common. When post-op care includes radiation and chemotherapy, veterinary medical expense easily double those costs to $20,000. Morbidity in VAS cats if high.
These costs are just the tip of the iceberg.
Ear and skin conditions are the most common problems veterinarians deal with day to day. Often pet owners report that these begin shortly after re-vaccination and are exacerbated with every subsequent vaccine. Chronic, incurable health issues are detrimental to a dog or cat’s quality of life and longevity. Treatment is financially draining to its family.
Cui bono: who benefits?
Based on a study published in 2004 by Texas A&M College of Veterinary Medicine and Biomedical Sciences and the Texas Veterinary Medical Association, 21 million Texans owned pets. In 2003 alone, the financial outpouring of love and devotion amounted to $2.8 billion for food and veterinary medical services in addition to medicine and supplies.
This is significant economic impact by any one's accounting; all the more so when needless vaccinations with no real medical value affect your cat or dog and you're footing the bill.
Now that State of Texas Health Services has turned a deaf ear to requests for a reasonable reform and a blind eye to the multiple negative effects (read economic impact) of an unnecessary and potentially deadly medical procedure, Texas veterinary professionals can expect more pet-crazy clients to ask, "Cui bono: who benefits?"
Read TDHS proposed rule changes
Comments on the proposal may be submitted in writing to Tom Sidwa, DVM, Department of State Health Services, Community Preparedness Section, Zoonosis Control Branch, P. O. Box 149347, Austin, Texas 78714-9347, or by email to Tom.Sidwa@dshs.state.tx.us.
Read reference citations
Sign the Petition to Grant a Medical Exemption from Rabies Shots for Sick and Senior Pets
Give responsible pet owners a reasonable way to obey the law and protect the health of our companion animals.
Sign the petition
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