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This information was supplied by:

Kris L. Christine
Founder, Co-Trustee
The Rabies Challenge Fund
(May 16, 2010)



On 12/21/09 California State Public Health Veterinarian, Dr. Ben Sun (916) 552-9744, designated ALL COUNTIES in California as "rabies areas" for 2010 http://www.cdph.ca.gov/HealthInfo/discond/Documents/2010_LHD_Rabies_Declaration_Letter.pdf.    

The declaration states:  "The Director of the Department of Public Health has declared all counties in California as 'rabies areas' in 2010.  This declaration is based on the ongoing cyclic nature of rabies in California wildlife, and the resulting threat of exposure to domestic animals, livestock, and humans."

An April 5, 2010 amendment to AB2000 http://www.leginfo.ca.gov./pub/09-10/bill/asm/ab_1951-2000/ab_2000_bill_20100405_amended_asm_v98.html  which seeks to add a medical exemption clause for sick dogs in designated "rabies areas," would included the following language:  "(2) A dog exempt from the canine antirabies vaccination shall be kept quarantined as directed by the local health officer, until the dog's medical condition has resolved and the administration of the canine antirabies vaccine occurs."

This bill is currently in the Senate Rules Committee for consideration.

Under current law, the Department of Public Health is authorized to require annual rabies vaccinations in designated "rabies areas," which includes ALL counties in California for 2010.  With the passage of AB2000 as amended on April 5th, dogs with medical exemptions would be required to be quarantined, which could be in an off-site pound or facility as determined by the local health officer, until their medical condition resolves or they are given a rabies vaccine.

At the bottom of this action alert is a copy of the letter I sent on behalf of The Rabies Challenge Fund on this issue.

What You Can Do to Help

Call the Senate Rules Committee and call or send an e-mail to all its members telling them to withdraw Paragraph (2) of the amendment pertaining to quarantining medically exemption animals and strike language in Section 121690 (b) of the law authorizing the Health Department to impose annual or biennial rabies vaccinations in "rabies areas."

The phone number for the California Senate Rules Committee is (916) 651-4120  
Chair of the Committee is Senator Darrell Steinberg e-mail: Senator.Steinberg@senate.ca.gov  Phone: (916) 651-4006
Vice-chair Sam Aanestad Senator.Aanestad@senate.ca.gov (916) 651-4004
Gilbert Cedillo Senator.Cedillo@senate.ca.gov (916) 651-4022
Robert Dutton Senator.Dutton@senate.ca.gov (916) 651-4031
Jenny Oropeza Senator.Oropeza@senate.ca.gov (916) 651-4028
Bill Co-Sponsor Assembly Member Curt Hagman Assemblymember.Hagman@assembly.ca.gov (916) 319-2060

Letter from The Rabies Challenge Fund

May 15, 2010
Senator Darrell Steinberg, Chair
Senate Rules Committee
State Capitol, Room 205
 Sacramento, CA  94248-0001
RE:     Amended Rabies Bill AB2000

Greetings Senator Steinberg:

            The Rabies Challenge Fund Charitable Trust respectfully requests that the Senate Rules Committee withdraw Paragraph (2) of the April 5th amendment to AB2000 which mandates that “A dog exempt from the canine antirabies vaccination shall be kept quarantined, as directed by the local health officer, until the dog's medical condition has resolved and the administration of the canine antirabies vaccine occurs.”   This amendment seeks to address a public health threat which does not exist in the canine community, and which will, if passed, pose a life-threatening risk to dogs whose health is already compromised.

            California’s Department of Public Health (CDPH) statistics clearly demonstrate that bats and other wildlife pose the greatest rabies threat to the public, not dogs.  From 2001 through 2008, the CDPH reported 2 cases of human rabies contracted in the state, both of which were transmitted by bats.  Further, according to data contained in the annual Reported Animal Rabies by County and Species issued by the CDPH, from the period of 2001 through May 7, 2010, (throughout which time all counties had been designated “rabies areas”), dogs were among the species with the least number of rabies cases in California.  During the cited surveillance period 1,440 bats, 462 skunks, 74 foxes, 11 cats, and 5 dogs were reported as rabid.  

            The Center for Disease Control documented 32 cases of domestically-contracted cases of human rabies in the U.S. from 1995 through 2008 – 30 illnesses were transmitted by bats, 1 by fox, and 1 by raccoon.   Since 1995, there have been no reported cases of human rabies from exposure to an indigenous dog in this country, and no demonstrated need exists for the California Legislature to pass harsh rabies regulations targeting dogs.   

            Further, The Rabies Challenge Fund asks that the Committee strike the following bolded, underlined language in the current law under Section 121690 (b) which is reiterated in AB2000 as follows:  “(b)  Every dog owner, after his or her dog attains the age of four months, shall, at intervals of time not more often than once a year, as may be prescribed by the department, procure its vaccination by a licensed veterinarian with a canine antirabies vaccine approved by, and in a manner prescribed by, the department, unless a licensed veterinarian determines, on an annual basis, that the dog may have a potentially lethal reaction to the canine antirabies vaccine. is currently immune compromised or has a documented medical record of a preexisting condition, including, but not limited to, an immune mediated disease, or a serious adverse reaction to a prior canine antirabies vaccine.”          

Mandating rabies vaccinations more often than once every 3 years, even in designated “rabies areas,” goes against the recommendations of all the national veterinary medical associations, including the American Veterinary Medical Association [1] and the Center for Disease Control’s National Association of State Public Health Veterinarian’s Compendium of Animal Rabies Prevention and Control 2008 which states that, “Vaccines used in state and local rabies control programs should have at least a 3-year duration of immunity. This constitutes the most effective method of increasing the proportion of immunized dogs and cats in any population.”

Section 121690 (b) of the Health and Safety Code may violate California’s Consumer Protection Law by requiring pet owners to pay for a veterinary medical procedure from which their animals derive no benefit and may be harmed.  The section of the law requiring biennial or annual rabies boosters in “rabies areas” may have been intended to achieve enhanced immunity to the rabies virus by giving the vaccine more often than the federal 3-year licensing standard, but, more frequent vaccination than is required to fully immunize an animal will not achieve further disease protection.  Redundant rabies shots needlessly expose dogs 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 3 year rabies vaccines currently licensed by the USDA for dogs all have a minimum duration of immunity of 3 years proven by challenge studies (the definitive standard in vaccine research) conducted according to the licensing standards set forth in USDA Title 9 Part 113.209.   Serological studies performed by Dr. Ronald Schultz of the University of Wisconsin School of Veterinary Medicine show a minimum duration of immunity of 7 years.  According to the Center for Disease Control, "A fully vaccinated dog or cat is unlikely to become infected with rabies…. In a nationwide study of rabies among dogs and cats in 1988,….no documented vaccine failures occurred among dogs or cats that had received two vaccinations. " [2]

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 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).” [8] According to the 2003 AAHA Guidelines, "...killed vaccines are much more likely to cause hypersensitivity reactions (e.g., immune-mediated disease)." [9]
On behalf of The Rabies Challenge Fund Charitable Trust and the many concerned California pet owners who have requested our assistance, I strongly urge you to withdraw Paragraph (2) of the April 5th amendment to AB2000 and strike the language in the current law cited in the bill authorizing the CDPH to impose annual or biennial rabies boosters in “rabies areas.”  
Kris L. Christine
Founder, Co-Trustee
cc:       W. Jean Dodds, DVM
            Ronald D. Schultz, PhD
            Assembly Member Curt Hagman

[1] American Veterinary Medical Association, Veterinary Biologics, June 2007, “Rabies Vaccination Procedures”
[2]  Immunization Practices Advisory Committee, Rabies Prevention—United States, 1991 Recommendations of the Immunization Practices Advisory Committee, Center for Disease Control Morbidity and Mortality Weekly Report March 22, 1991/40(RR03);1-19
[3] Dodds, W. Jean Vaccination Protocols for Dogs Predisposed to Vaccine Reactions, The Journal of the American Animal Hospital Association, May/June 2001, Vol. 37, pp. 211-214
[4] Duval D., Giger U.Vaccine-Associated Immune-Mediated Hemolytic Anemia in the Dog, Journal of Veterinary Internal Medicine 1996; 10:290-295
[5] American Veterinary Medical Association (AVMA) Executive Board, April 2001, Principles of Vaccination, Journal of the American Veterinary Medical Association, Volume 219, No. 5, September 1, 2001.
[6] Vascelleri, M. 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.
[7] 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.
[8] Vascelleri, M. 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.
[9] American Animal Hospital Association Canine Vaccine Task Force. 2003 Canine Vaccine Guidelines, Recommendations, and Supporting Literature, 28pp. and ibid. 2006 AAHA Canine Vaccine Guidelines, Revised, 28 pp.


Kris L. ChristineFounder, Co-TrusteeThe Rabies Challenge Fund


            More information and regular updates on The Rabies Challenge Fund and the concurrent 5 and 7 year challenge studies it is financing can be found at the fund’s website designed by volunteer Andrea Brin at:  

The information contained on this site is in no way intended to replace that of proper veterinary advice, diagnosis or treatment.
It is meant to provide resource, so that we can better understand canine health related issues.