# URGENT--Defeat CA Rabies Bill AB 2689



## Kris L. Christine (Mar 25, 2009)

*California Rabies Bill AB 2689* AB 2689 Assembly Bill - AMENDED introduced by Assembly Member Cameron Smyth, Chair of the Local Government Committee has been referred to the Local Government Committee Assembly Committee Frameset
and *will require annual rabies vaccinations and puppies to be vaccinated at 3 months instead of 4 months of age* in "rabies areas" (portion of bill text below) as determined by the State Public Health Officer -- violation is impoundment. 

It is URGENT that ALL concerned pet owners contact the committee and tell them to reject this bill in its entirety. The Local Government Committee phone is *(916) 319-3958 *and the members contact information is listed below. 

*PERMISSION GRANTED TO POST AND CROSS-POST* this notice, please help spread the word and take action to defeat this legislation.


Cameron Smyth - Chair Rep-38 (916) 319-2038 [email protected] 
Anna M. Caballero - Vice Chair Dem-28 (916) 319-2028 [email protected] 
Juan Arambula Ind-31 (916) 319-2031 [email protected] 
Steven Bradford Dem-51 (916) 319-2051 [email protected] 
Mike Davis Dem-48 (916) 319-2048 [email protected] 
Steve Knight Rep-36 (916) 319-2036 [email protected] 
Dan Logue Rep-3 (916) 319-2003 [email protected] 
Jose Solorio Dem-69 (916) 319-2069 [email protected] 


_SEC. 2. Section 121690 is added to the Health and Safety Code, to read: 

121690. In rabies areas, all of the following shall apply:

* (b) Every dog owner, after his or her dog attains the age of three 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.*_


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## xxshaelxx (Mar 8, 2010)

I'm SO glad I don't live in California! That's just cruel! Do they want to kill our pets by over vaccination?!​


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## Kris L. Christine (Mar 25, 2009)

Below is a copy of the letter I faxed to Assembly Member Smyth regarding AB 2689.

*PERMISSION GRANTED TO POST AND CROSS-POST*

April 12, 2010

Assembly Member Cameron Smyth, Chair
Local Government Committee
State Capitol, Room 4098
Sacramento, CA 94249-0038

*RE: California Rabies Bill AB 2689* 

Greetings Assembly Member Smyth:

Assembly Bill AB 2689 which you introduced on behalf of the City of Los Angeles is ill-advised and scientifically unfounded. The bill seeks to address a problem in the canine community that does not exist, as the California Veterinary Public Health Section’s statistics in Reported Animal Rabies by County and Species make abundantly clear: bats and other wildlife pose the major threat of rabies transmission to the public, not dogs.

According to the rabies data cited above, from 2007 until April 2, 2010, there was only 1 dog reported in California with rabies, while there were 2 cats, 442 bats, 55 fox, 107 skunks, 1 coyote, and 2 raccoons confirmed rabid. This bill authorizing the State Public Health Officer to require dogs to be vaccinated against rabies more often than once every 3 years as allowed by State law and lowering the age of required puppy vaccination to 3 months will not solve the issue of rabies in wildlife – it will, however, needlessly expose dogs of law-abiding citizens to the adverse reactions of medically unwarranted rabies boosters for which expense their owners will be charged.

Mandating rabies vaccinations more often than once every 3 years 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 (50).”*

Amending Section 121690 of the Health and Safety Code to require 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.” *This amendment 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 3 year rabies vaccines currently licensed by the USDA for dogs all have a *minimum* duration of immunity of 3 years, backed by challenge studies 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] 

Lowering the age at which puppies are required to have their first rabies shot from 4 months to 3 months is 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......" *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.

By lowering the age to 3 months in "rabies areas," not only will puppies be put at increased risk for adverse reactions, but they will also be less likely to mount the desired immunological response because of passively acquired maternal antibodies and the impact of the other puppyhood vaccinations.

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 2689 in its entirety.

Sincerely,

Kris L. Christine
Founder, Co-Trustee
THE RABIES CHALLENGE FUND
Duration of Immunity Study for Rabies Vaccine - Rabies Challenge Fund
[email protected]

cc: Dr. W. Jean Dodds
Dr. Ronald D. Schultz

--------------------------------------------------------------------------------
[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.


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## PUNKem733 (Jun 12, 2009)

That's OK, I'll ignore that law. Not too much longer until I'm out of this retarded, ass backwards state.


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## Kris L. Christine (Mar 25, 2009)

*UPDATE--CA BILL AB 2689* -- Public response has caused Assembly Member Smyth's office to withdraw the language in AB 2689 lowering the age of puppy vaccination from 4 months to 3 months in "rabies areas." However, as the law currently stands, the State Public Health Officer can require annual rabies vaccinations in "rabies areas." Please call *(916) 319-2038, (916) 319-3958, *or the committee members them an e-mail (contact information below) and ask them to strike the language in the current law (121690) authorizing the State Health Officer to impose annual rabies vaccinations in "rabies areas." 

Below is a copy of my e-mail to AM Smyth's assistant, Kevin O'Neill. To access the law in question, go to this link Find California Code , click on "Health and Safety Code" and enter 121690 for the keyword .

*PERMISSION GRANTED TO POST AND CROSS-POST* this notice, please spread the word and take action to change this law. 


Cameron Smyth - Chair Rep-38 (916) 319-2038 [email protected] 
Anna M. Caballero - Vice Chair Dem-28 (916) 319-2028 [email protected] 
Juan Arambula Ind-31 (916) 319-2031 [email protected] 
Steven Bradford Dem-51 (916) 319-2051 [email protected] 
Mike Davis Dem-48 (916) 319-2048 Assemblymember[email protected] 
Steve Knight Rep-36 (916) 319-2036 [email protected] 
Dan Logue Rep-3 (916) 319-2003 [email protected] 
Jose Solorio Dem-69
(916) 319-2069
[email protected] 



----- Original Message ----- 
From: Kris Christine 
To: Kevin.O'[email protected]
Sent: Wednesday, April 14, 2010 1:00 PM
Subject: Re: AB 2689 (Smyth)


Greetings Mr. O'Neill,

Thank you for your e-mail. There is conflicting language within the Health and Safety Code as it stands, and this is a good opportunity to resolve this. What The Rabies Challenge Fund objects to in the proposed amendment is the lowering of the age of puppy vaccinations to 3 months and the authority given (or reaffirmed) to impose annual rabies vaccinations in "rabies areas". 

Within the language of the current law as it stands is the following below allowing for a 3 year dog license in "rabies areas" as long as the license period shall not extend beyond the remaining period of validity for the *current rabies vaccination* -- this does not state period of validity for an annual rabies vaccination.

As outlined in the letter we submitted to you, there is no scientific or epidemiological data supporting the authority given to the State Public Health Officer to impose annual rabies vaccinations for dogs in "rabies areas," and it goes against the recommendations of the Center for Disease Control's recommendations in their Rabies Compendium. While you are revising AB 2689 to keep the 4 month puppy vaccination provision, we respectfully request that you also revise subsection (a) so that there is no authority given to impose annual vaccinations.

Regards, 
Kris L. Christine
Founder, Co-Trustee
The Rabies Challenge Fund
[email protected]


*"121690.* In rabies areas, all of the following shall apply:

(g) In addition to the authority provided in subdivision (a), the ordinance of the responsible city, city and county, or county may
provide for the issuance of a license for a period not to exceed three years for dogs that have attained the age of 12 months or older and have been vaccinated against rabies. The person to whom the license is issued pursuant to this subdivision may choose a license period as established by the governing body of up to one, two, or three years. However, when issuing a license pursuant to this subdivision, the license period shall not extend beyond the remaining period of validity for the current rabies vaccination. A dog owner who complies with this subdivision shall be deemed to have complied with the requirements of subdivision (a)."


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## Kris L. Christine (Mar 25, 2009)

Below is a follow-up e-mail we have sent on AB 2689. Please continue to call Assembly Member Smyth's office at (916) 319-2038 or the Local Government Committee at (916) 319-3958 and request that they remove the authorization to impose annual rabies vaccinations.

PERMISSION GRANTED TO POST AND CROSS-POST

----- Original Message ----- 
From: Peter & Kris Christine 
To: Kevin.O'[email protected]; [email protected] 
Sent: Monday, April 19, 2010 6:35 AM
Subject: California Rabies Bill AB 2689


Greetings Mr. O'Neill,

Regarding The Rabies Challenge Fund's request and conversations with the staff in your office about withdrawing the authorization given under 121690 Section (b) of the current law to the State Public Health Officer to impose annual rabies vaccinations in areas they determine to be "rabies areas" -- this easily could be accomplished in AB 2689 by striking the clause "at intervals of time not more often than once a year, as may be prescribed by the department". No additional language would need to be added, no new bill would need to be drafted or introduced, and the conflict with language contained in Section (g) would be resolved.

As you are aware from the data Dr. Jean Dodds, Dr. Ronald Schultz, and I have forwarded on to you, there is no benefit from annual rabies vaccination, and it goes against the recommendations of all the national veterinary medical associations, which recommend a 3 year booster schedule as the best way to prevent and control rabies.

It is our hope that you will be able to make this one further revision to AB 2689.

Regards,

Regards, Kris
Kris L. Christine
Founder, Co-Trustee
The Rabies Challenge Fund
[email protected] 

(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.


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## Kris L. Christine (Mar 25, 2009)

*UPDATE AB 2689: *Assembly Member Smyth's Chief of Staff, Kevin O'Neill sent me the following in an e-mail 4/19/10 regarding AB 2689 indicating that although they did withdraw the change requiring puppies that be vaccinated at 3 months in "rabies areas," they would not strike authorization for the State Health Officer to impose annual rabies vaccinations. Thanks to all of the pet owners who took time to contact the Committee members, there has been a partial victory. In order to remove the authorization given to the State Health Officer to impose annual rabies vaccinations in "rabies areas," a new bill will need to be introduced in the next legislative session.

From Mr. O'Neill's e-mail: *"The main intent of AB 2689 was to modernize the code to make the flow of rabies vaccinations between owners and local governments more efficient. The only reason we had originally agreed to place the age change from 4 to 3 months for rabies vaccinations in the bill was because it was sold to us as conformity language that would bring California in line with the rest of the country. Once we realized that this piece was controversial and that a lot of disagreement exists about whether changing the age to 3 months is appropriate, we decided to drop that from the bill because our main interest is simply in modernizing the code. 

Likewise, changing existing and long standing code regarding the frequency of vaccinations is another controversial issue and is such a large issue that it should really be in a bill on its own, not in a bill aimed at modernizing the code. I would have offered the same advice regarding changing the age of vaccination from 4 to 3 months had I known that significant controversy surrounded that issue. "*


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## JayJayisme (Aug 2, 2009)

Man I've got to get out of this stupid nanny State. This is why my dogs aren't licensed and never will be as long as I can avoid it. 

Why is this even an issue? Why is it on the political radar? Isn't the spread of rabies through canines extremely rare these days? This sounds like something a veterinarian industry lobbying group would come up with. Another "follow the money" law.

Thanks for your efforts Kris. It must be like rolling boulders uphill sometimes.

Jay


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## hayduke (Mar 26, 2010)

It would seem that such a law based on NO SCIENTIFIC EVIDENCE could be easily fought in court.
Even Hawaii has revised its totally unscientific imprisonment of dogs for MONTHS when the incubation period for rabies is 2 weeks, and now requires only antibody titers for importation of dogs


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## Kris L. Christine (Mar 25, 2009)

hayduke said:


> It would seem that such a law based on NO SCIENTIFIC EVIDENCE could be easily fought in court.


Yes, if someone had the money and will to file a suit.


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