"Cujo's Law" - AB 272

  Rabies Vaccination of puppies in California may soon be required at the tender age of three months

 

By Geneva Coats, R.N.

Secretary, California Federation of Dog Clubs

A bill, dubbed by its sponsor as "Cujo's Law", is awaiting a vote of the California Assembly. This bill would mandate that puppies receive rabies vaccination at three months old.

This bill has provoked vigorous opposition from dog groups and animal welfare groups. Dr. W. Jean Dodds, a California veterinarian, and Co-Trustee of the Rabies Challenge Fund Charitable Trust, is one of the veterinary professionals most knowledgeable on the subject of immunology and vaccination. Dr. Dodds has personally and repeatedly contacted members of the assembly to voice concerns over this bill since February. California Federation of Dog Clubs wrote a letter of opposition to this bill in March, 2013. Despite our request to be listed among the opponents of the bill, our letter was ignored and we were not included on the opposition list.

Despite much protesting and all the evidence presented regarding how bad this bill is, it passed merrily along out of both the Assembly Agriculture and Assembly Appropriations committees by unanimous vote!

As most dogs breeders are aware, vaccination of puppies at an early age flies in the face of science and is counter to the advice of the medical community. Early-age vaccination is often ineffective due to the interference of maternal antibodies. This would mean that a large percentage of young dogs in the community would be presumed immune to rabies after an ineffective early-age vaccination, when in

fact they are not immune and could, in theory, acquire and transfer rabies to humans.

There have been some gross misrepresentations and inaccuracies relating to AB 272.

• Proponents have claimed that it does not mandate rabies vaccination at the age of three months. However, the text of the bill clearly does mandate a rabies vaccination at the age of three months.
• 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. Thirteen (13) states require that dogs be vaccinated by the age of 4 months; one (1) state requires vaccination by 5 months; and six (6) require vaccination by the age of 6 months, 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 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."
• Puppies are finishing up their initial vaccination series of distemper, hepatitis, and parvovirus at 12 weeks (3 months) of age. According to vaccination expert Dr. W. Jean Dodds, 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.
• Dr. Karen Ehnert, acting Director of Veterinary Public Health, 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." This is completely disingenuous, as currently there is no law prohibiting anyone from vaccinating their puppy for rabies at the age of three months should they choose to do so.
• Dr Ehnert claims that "the past two years we have seen a 4 -5 fold increase in bat rabies in LA County, with some areas being hot spots." Yes, there have been increased cases of bat rabies, but there has been no escalation in canine rabies corresponding to the increase in bat rabies. 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 2011—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.
• The sole amendment of April 19 was to eliminate the provision to refer to the bill as 'Cujo's Bill.' This coming from a veterinary organization? Are politicians now being paid for lame attempts at stand-up comedy? This original lead-in statement to the bill clues us in to the fact that there is quite an anti-dog bias evident in the intent. No wonder the politicians advancing this ridiculous agenda don't care to hear about how our dogs' health might be adversely affected....they just plain DON'T CARE!

The politicians have ignored our pleas and are woefully ignorant to the dangers of this bill. One assemblywoman, ASM Joan Buchanan, has promised to speak on the Assembly floor AGAINST AB 272 but she claims that there has been little noise about this, including letters, faxes, or phone calls. I don't suppose emailed information from experts in the field like Dr. Dodds counts for anything. And of course, letters from organizations have been left off the opposition list, seemingly in a deliberate manner.

Rabies remains a very serious world wide health threat, causing on average 55,000 human deaths per year. Most of these sad cases happen in Africa and Asia. But for those of us living in the California, the chances of a dog transmitting rabies to a human are much less than the odds of being struck by lightening or winning the Powerball lottery. In a state of nearly 40 million people, we have had three, count 'em, THREE cases of canine rabies in the state in the last four years, and one of those was in a dog recently imported into Los Angeles from Mexico.

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. If you live in California please call your assemblymember TODAY as the bill may be voted on as early as Thursday April 25^th.