# TEXAS Rabies Law--Bell County



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

*PERMISSION TO CROSS-POST* 

A debate over the annual county rabies protocol in Bell County, Texas has erupted (see 6/7/09 Temple Daily Telegram *Bell County eyes rabies ordinance change: Required shots could switch from yearly to every three years* http://www.tdtnews.com/story/2009/06/07/58450 6/2/09 story on Channel 25 ABC News *Bell County Rabies Debate Continues* http://www.kxxv.com/global/story.asp?s=10467503 , *Killeen Takes Closer Look at Rabies Vaccinations* KCEN Channel 9 News 6/4/09 http://www.kcendt.com/?p=12086, Killeen Daily Herald stories *Regulations for rabies vaccination under debate* http://www.kdhnews.com/news/story.aspx?s=33495 and *County debates changing rabies law* http://www.kdhnews.com/news/story.aspx?s=33636) and it is urgent that any and all concerned pet owners contact the county officials below to urge them to change the protocol to the national 3 year standard. A copy of my letter to County officials is below. Texas state law recognizes the 3 year rabies vaccines licensed by the USDA and at least one town's 3 year protocol is overridden by the County order. 

*What You Can Do to Help* 

Contact the Bell County Commissioners, County Attorney and/or District Attorney via phone, e-mail, or fax (contact information is below) and tell them it is time for them to adopt the 3 year rabies protocol recommended by all the national veterinary medical associations and adopted by all the states. Please share this action alert with all the pet-owners you know. 

*County Commissioners:* Phone 1-800-460-2355 or 254-939-3521 Fax: 254 - 933-5179 Richard Cortese [email protected]; Tim Brown [email protected]; Eddy Lange [email protected]; John Fisher [email protected] 

*County Attorney* Richard Miller Phone 1-800-460-2355 or 254-939-3521 Faxes 254-933-5150 and 254-933-5176 
*District Attorney* Henry Garza [email protected] fax: 254-933-5179 phone Phone 1-800-460-2355 or 254-939-3521 

May 26, 2009 

Bell County Commissioners 
County Attorney Richard Miller 
District Attorney Henry Garza 
101 East Central Avenue 
Belton, TX 76513 

*RE: BELL COUNTY ANNUAL RABIES VACCINATIONS ORDER* 

Greetings Messrs. Cortese, Brown, Lange, Fisher, Miller, and Garza: 

Bell County should amend the outdated section (4.01) of its Animal Control County Order governing rabies vaccinations which requires annual rabies boosters following the initial puppy and kitten series of shots and institute a 3 year rabies immunization protocol conforming to the national standard adopted by all the states, including Texas, and recommended by the Center for Disease Control's (CDC) National Association of State Public Health Veterinarians as well as the American Veterinary Medical Association. 

The CDC's National Association of State Public Health Veterinarian's _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."* 

It is recognized that most, if not all, currently licensed annual rabies vaccines given annually are actually the 3-year vaccine relabeled for annual use -- Colorado State University's *Small Animal Vaccination Protocol* for its veterinary teaching hospital states: *"Even with rabies vaccines, the label may be misleading in that a three year duration of immunity product may also be labeled and sold as a one year duration of immunity product."* According to Dr. Ronald Schultz of the University of Wisconsin School of Veterinary Medicine, whose canine vaccine studies form a large part of the scientific base for the 2003 and 2006 American Animal Hospital Association's (AAHA) Canine Vaccine Guidelines, as well as the World Small Animal Veterinary Association's 2007 Vaccine Guidelines, *"There is no benefit from annual rabies vaccination and most one year rabies products are similar or identical to the 3-year products with regard to duration of immunity and effectiveness."* [1] 

Bell County's code requiring annual rabies boosters may have been intended to achieve enhanced immunity to the rabies virus by giving the vaccine more often than Texas state law and 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 annual rabies shots needlessly expose dogs and cats 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."* 

By requiring pet owners to pay for a yearly veterinary medical procedure from which their animals derive no benefit and may be harmed, the county's current rabies immunization code may violate the Texas Deceptive Trade Practices Act (Title 2, Chapter 17) and may place veterinarians in the uneasy position of violating Title 4 Chapter 801Subsection 402 (12) of the Veterinary Licensing Act, which cites as grounds for license denial or disciplinary action any veterinarian who *"performs or prescribes unnecessary…treatment."* 

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,"*[2] auto-immune hemolytic anemia,[3] 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.[4] [5] 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,"* [6]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)."*[7] According to the 2003 AAHA Guidelines, *"...killed vaccines are much more likely to cause hypersensitivity reactions (e.g., immune-mediated disease)."* [8] 

County officials should note data indicating that compliance rates are no higher in areas with annual rabies immunization requirements than in those with triennial protocols. A 2002 report compiled by the Banfield Corporation for the Texas Department of Health on rabies vaccination rates determined that a *"comparison of the one-year states and the three-year states demonstrates no difference in the delinquency rates" and that, "A paucity of scientific data exists to demonstrate a clear public health benefit of a one-year vaccination protocol versus a three-year vaccination protocol."* [9] 

On behalf of The Rabies Challenge Fund and the Bell County pet owners who have contacted us, we strongly urge you to amend Section 4.01 of the Bell County Order governing Animal Control and Rabies Vaccinations to conform to the 3-year national standard recommended by the Center for Disease Control's National Association of State Public Health Veterinarians and endorsed by the American Veterinary Medical Association. 

Sincerely, 

Kris L. Christine 
Founder, Co-Trustee 
THE RABIES CHALLENGE FUND 
www.RabiesChallengeFund.org 

cc: Dr. W. Jean Dodds 
Dr. Ronald Schultz 
Belton, Harker Heights, Killeen, Salado, and Temple City Officials 
Justin Cox 

*continued*


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

*continued*


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[1] Schultz, Ronald D.; What Everyone Needs to Know about Canine Vaccines, October 2007, http://www.puliclub.org/CHF/AKC2007C...20Vaccines.htm 

[2] 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 

[3] Duval D., Giger U.Vaccine-Associated Immune-Mediated Hemolytic Anemia in the Dog, Journal of Veterinary Internal Medicine 1996; 10:290-295 

[4] 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. 

[5] 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. 

[6] 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. 

[7] 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. 

[8] 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. 

[9] Texas Department of Public Health, Zoonosis Control; The White Paper, Options for Rabies Vaccination of Dogs and Cats in Texas, 2002


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

*Animal Advisory Committee Works to Revamp Rabies Policy*

Update: July 23, 2009 article in the _Killeen Daily Herald_ on efforts to change the annual rabies ordinance in Bell County, Texas: *Animal Advisory Committee Works to Revamp Rabies Policy* http://www.kdhnews.com/news/story.aspx?s=34716 

"Killeen's animal advisory committee can't change the annual rabies vaccination policy - so it's going to the source. 

The committee is sending representatives to the Bell County Commissioners Court and the Killeen City Council in an effort to change the county's policy on rabies vaccinations."


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

*Killeen Daily Herald 7/29/09--Rabies shots only needed every 3 years*

*Rabies shots only needed every 3 years*_ Killeen Daily Herald _7/29/09http://kdhnews.com/news/story.aspx?s=34835

Members of Killeen's Animal Advisory Committee took a stand against Bell County's current pet rabies vaccination policy at Tuesday's City Council's workshop.

After hearing presentations from two veterinarians, the Killeen City Council reached a *unanimous* consensus to support the committee's appeal to the county for prolonging rabies vaccinations to once every three years instead of annually.


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

*TEXAS, Bell County New Rabies Rule*

*TEXAS: Bell County Relaxes Rabies Shots Requirements  *Temple Daily Telegram 2/8/11 http://www.tdtnews.com/story/2011/02/08/72249/ 

_"the county has essentially adopted the state standard, which allows an attending veterinarian to determine, together with the pet owner, how often the shots are needed. "_


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