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Below is a copy of my letter to Rhode Island's Public Health Veterinarian, who responded that he is "planning to convene that body to review current regulations and protocols" and that he will present my petition.

WHAT YOU CAN DO

Now is the time for concerned Rhode Island pet owners to contact their legislators about changing the state's rabies law to the national 3 year standard. To find your legislator, click on this link: Rhode Island General Assembly: The State of Rhode Island General Assembly

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February 18, 2009

Dr. Scott Marshall Dr. David R. Gifford, Director
State Public Health Veterinarian Department of Health
Division of Agriculture 3 Capitol Hill
235 Promenade Street Providence, RI 02908
Providence, RI 02908-5767

RE: Chapter 4-13-30 Rules and Regulations Governing the Suppression of Rabies

Greetings Drs. Marshall and Gifford:

On behalf of The Rabies Challenge Fund and concerned Rhode Island pet owners who have contacted us, I am writing to alert you to the fact that Rhode Island’s rabies regulations (Title 4, Chapter 4-13-30) requiring that dogs and cats receive boosters “not more than twenty-four (24) months have elapsed since the most recent vaccine” is contrary to the recommendations of all the national veterinary medical associations as well as the labeled specifications of all rabies vaccines licensed by the United State Department of Agriculture (USDA).

The Center for Disease Control’s National Association of State Public Health Veterinarian's (NASPHV) Compendium of Animal Rabies Prevention and Control 2008 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).” They specifically warn that, (n)o laboratory or epidemiologic data exist to support the annual or biennial administration of 3- or 4-year vaccines following the initial series.” Also endorsing the NASPHV’s Rabies Compendium are the American Veterinary Medical Association (AVMA)[1] and the American Animal Hospital Association (AAHA).[2]

Requiring Rhode Island’s pet owners to pay for medically unnecessary rabies vaccinations at least every 24 months, from which their animal derive no benefit, raises ethical and legal issues which may violate Chapter 6-13.1 of Rhode Island’s Deceptive Trade Practices as well as the Veterinary Practice Act (Chapter 5-25) when veterinarians are compelled to administer 3 year vaccines (there are no 2 year rabies vaccines licensed by the USDA), off-label every 2 years in order for their clients to comply with state law.

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.

The labels on rabies vaccines state that they are for “the vaccination of healthy cats, dogs…,” and there are medical conditions for which vaccination can jeopardize the life or well-being of an animal. A medical exemption clause inserted into the new 3 year Rabies Law being considered would allow veterinarians to write waivers for animals for whom medical conditions preclude vaccination. The State of Maine inserted such an exemption into the 3 year rabies protocol, 7 M.R.S.A., Sec. 3922(3), it adopted in 2004 as follows:


A. A letter of exemption from vaccination may be submitted for licensure, if a medical reason exists that precludes the vaccination of the dog. Qualifying letters must be in the form of a written statement, signed by a licensed veterinarian, that includes a description of the dog, and the medical reason that precludes vaccination. If the medical reason is temporary, the letter shall indicate a time of expiration of the exemption.

B. A dog exempted under the provisions of paragraph 5 A, above, shall be considered unvaccinated, for the purposes of 10-144 C.M.R. Ch.251, Section 7(B)(1), (Rules Governing Rabies Management) in the case of said dog’s exposure to a confirmed or suspect rabid animal.


The Rabies Challenge Fund strongly urges Rhode Island to amend the Rules and Regulations Governing the Suppression of Rabies to conform to the national standard set by the CDC’s NASPHV’s Compendium of Animal Rabies Prevention and Control and respectfully requests that medical exemption language be inserted into the law.

Sincerely,

Kris L. Christine
Founder, Co-Trustee
THE RABIES CHALLENGE FUND
About the Rabies Challenge Fund

cc: Rhode Island Legislature
Governor Donald L. Carcieri
Attorney General Patrick C. Lynch
Dr. W. Jean Dodds
Dr. Ronald Schultz

continued below
 

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Discussion Starter #2
continued from above

--------------------------------------------------------------------------------
[1] American Veterinary Medical Association, Veterinary Biologics, June 2007, “Rabies Vaccination Procedures”

[2] 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.

[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.
 

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Discussion Starter #3
RI-- Board OKs Change in Rabies Policy 5/1/09

Board OKs Change in Rabies Policy Providence Journal News Digest May 1, 2009 News Digest | Rhode Island news | projo.com | The Providence Journal


"PROVIDENCE –– The Rhode Island Rabies Control Board has approved a change in policy that could pave the way for regulations that will allow the vaccination of dogs and cats every three years, rather than every two years.

The rabies board also voted its support for regulatory language that would empower veterinarians to exempt certain pets from vaccination requirements under special circumstances, Marshall said. "
 

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RHODE ISLAND 3 Year Rabies Regulations

At the end of April 2009, Rhode Island's Rabies Control Board approved a change to allow for a 3 year protocol, yet no date has been set for it to become effective. Concerned pet owners should contact their legislators The State of Rhode Island General Assembly and the Chair of the Board, State Veterinarian Dr. Scott Marshall at 401-222-2781 [email protected] to insist this policy change becomes effective.

RHODE ISLAND - Board OKs Change in Rabies Policy Providence Journal News Digest May 1, 2009 News Digest | Rhode Island news | projo.com | The Providence Journal "PROVIDENCE –– The Rhode Island Rabies Control Board has approved a change in policy that could pave the way for regulations that will allow the vaccination of dogs and cats every three years, rather than every two years. "
 

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RI Rhode Island Rabies Control Board Meets 2/22 at 9:30

RHODE ISLAND Rabies Control Board meets February 22 at 9:30 a.m. Room 370, Division of Agriculture, 235 Promenade Street, Providence-- New 3 year rabies regulations to be discussed. http://sos.ri.gov/documents/publicinfo/omdocs/notices/13/2010/84585.pdf Concerned pet owners should make every effort to attend this meeting and ask their friends to do the same.

If you cannot attend the meeting, but want to voice your opinion, please contact the Chair of the Board, RI State Veterinarian, Dr. Scott Marshall at [email protected] phone: (401) 222-2781 ext. 4503 and ask that the regulatory change to the 3 year protocol be made effective as soon as possible.
 

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Rhode Island -- 3 Year "Transition Policy" announced by State Vet 2/21/10

New R.I. Rabies Regulations Close to Approval, Providence Journal 2/21/10 New R.I. rabies regulations close to approval | Health | projo.com | The Providence Journal

"New rules, expected to go into effect about March 16, change the mandatory vaccination period from two to three years.

In the meantime, the state veterinarian, Dr. Scott Marshall, has created a transitional policy so that pets now protected aren’t reimmunized unnecessarily just because the old regulations have not yet expired. "


If you have questions about the transition policy, contact Dr. Scott Marshall at [email protected] phone: (401) 222-2781 ext. 4503
 
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