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.
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: http://www.rilin.state.ri.us/
PERMISSION GRANTED TO CROSS-POST
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) and the American Animal Hospital Association (AAHA).
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.”
Auto-immune hemolytic anemia, 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.   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.
Kris L. Christine
THE RABIES CHALLENGE FUND
cc: Rhode Island Legislature
Governor Donald L. Carcieri
Attorney General Patrick C. Lynch
Dr. W. Jean Dodds
Dr. Ronald Schultz
 American Veterinary Medical Association, Veterinary Biologics, June 2007, “Rabies Vaccination Procedures”
 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.
 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
 Duval D., Giger U.Vaccine-Associated Immune-Mediated Hemolytic Anemia in the Dog, Journal of Veterinary Internal Medicine 1996; 10:290-295
 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.
 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.