California Assembly Bill AB 272 Could Threaten Your Pet's Life

Story at-a-glance

  • California Assembly Bill AB 272 is proposing new vaccine legislation that will require puppies in California to receive the rabies vaccine at 12 weeks rather than 16 weeks. Analysis of the bill indicates significant important factual errors have been conveyed to legislators about the impact of the bill on California's dogs if it passes, and the motivations behind its introduction.
  • Dr. Jean Dodds, Dr. Becker, other members of the veterinary community and countless pet owners are very concerned about this proposed bill, for the sake of California’s puppies, and also because other states often follow California’s lead.
  • A primary concern is that too-early rabies vaccination can interfere with residual maternal antibodies, with the result that puppies presumed to be immunized against the disease, will not be.
  • Another concern is that adding the rabies vaccine around the same time dogs receive their “puppy shots” can significantly increase the risk for serious adverse vaccine reactions.
  • Dr. Becker and Dr. Dodds encourage pet owners to get informed and involved by visiting the Rabies Challenge Fund website.

By Dr. Becker

Today I’m interviewing a very special guest, Dr. Jean Dodds, about new rabies vaccine legislation proposed in California that also has the potential to spread to other states – including the one you live in.

Proposed California Legislation Requires Too-Early Rabies Vaccine for Puppies

I asked Dr. Dodds to first explain what California Assembly Bill AB 272 is all about. She responded that the bill was proposed by public health officials in Los Angeles County to lower the rabies vaccine age requirement for puppies in the state of California from 16 weeks to 12 weeks. One of the problems with the bill is that it was introduced by a new assembly member. In fact, it was likely his first bill, and it contained factual errors.

Dr. Dodds and other members of the veterinary and pet owner communities who don’t want to be required by law to vaccinate dogs earlier than they really need it were very concerned about the bill.

Who Is Behind the Legislation – and Why?

I asked Dr. Dodds how the idea for the bill even came about – was it being pushed by California veterinarians? Dr. Dodds replied that it’s a rather curious situation, because in fact, most California veterinarians aren’t aware of a need, nor do they believe there’s a need to move up the timing of a puppy’s first rabies vaccination. (But Dr. Dodds did find it a bit disconcerting that the DVM who heads the California Veterinary Medical Board said in 30 years of practice he’s never seen an adverse reaction to a rabies vaccine. She found that quite astounding.)

The idea for the legislation seems to have originated with the acting director of the public health group in L.A. County, Dr. Karen Ehnert, a veterinarian. Apparently there’s been some concern about the increase in cases of bat rabies in the county, but according to Dr. Dodds, the numbers don’t add up.

Dr. Ehnert has stated there were 4.5 times as many cases of bat rabies as normal, when the number is actually only 2.5 times more. Regardless, as Dr. Dodds makes clear, there have been no cases of dog rabies in the Los Angeles area since 2010. Further, there were only three cases of dog rabies in all of California from 2007 to 2010, and some of those involved animals that came in from out of state.

California Seems Confused About Rabies Requirements in Other States

One of the things Dr. Dodds and others are worried about is that the bill presented to the legislature claims California is only one of two states that doesn’t require rabies vaccination at 12 weeks for dogs. This is absolutely NOT correct. There are only 12 states that suggest rabies vaccination at 12 weeks, and they don’t mandate it – only suggest it. There are 14 states that mandate the vaccine at 16 weeks of age, one state at five months, and several at six months.

The remaining states rely on the rabies compendium, which does not say puppies should be vaccinated at 12 weeks. On the contrary, the rabies vaccine licensure states that puppies can be vaccinated at 12 weeks, but it does not recommend nor require it at 12 weeks.

I mentioned to Dr. Dodds that when I read about the cases of bat rabies and related stats, the species to be concerned about would seem to be cats, not dogs. She agrees and adds that if there’s legislation needed, it should involve insuring cats are also vaccinated for rabies. According to the statistics, there were a high number of cats positive for rabies in L.A. County, but AB 272 doesn’t address cats.

I asked Dr. Dodds what other types of misinformation she uncovered in the bill. She replied that the bill makes it sound as though if the age for vaccinating puppies for rabies isn’t lowered, rabies will become rampant in the population. Another problem is that the rabies compendium was misinterpreted to say that dogs MUST be vaccinated at 12 weeks, when what it actually says is puppies could be vaccinated not earlier than 12 weeks. Not only do rabies vaccinations NOT have to be done at 12 weeks, most states don’t vaccinate that early, and Dr. Dodds would not recommend that timing for any state.

Risks of Too-Early Rabies Vaccinations

Next I asked Dr. Dodds to talk about her concerns about vaccinating puppies too early in life.

She explained that at 12 weeks, puppies are at a critical age for socialization. This is around the time they leave their litters and go to new homes. They are also receiving combination vaccines for core diseases like distemper and adenovirus, and in some regions they’re also receiving Lyme, leptospirosis and/or other non-core vaccines. They’re getting what are called “combo-wombo” vaccines at the critical age of 12 weeks when the immune system is just beginning to mature and may be unable to handle the immunological challenge of multiple vaccines.

Puppies at this age are getting lots of vaccinations, leaving their litters, going to new homes, adjusting to new environments including new food, and possibly the presence of children and other pets. Now we want to take these poor puppies and give them another very strong, neurogenic vaccine at the same time – a vaccine that can be affected and neutralized by residual maternal immunity. This is worrisome. This is not the time, in Dr. Dodds view or mine, to give an additional vaccination on top of the other vaccines and all the other changes puppies are dealing with.

How Residual Maternal Immunity Can Affect Vaccines

I asked Dr. Dodds to explain what happens when a puppy is vaccinated while there is still the potential for maternal antibody interference.

She explained that when you give a vaccine antigen, which is the protein of the virus or bacteria you’re immunizing against, you actually neutralize any existing antibody directed specifically against that same antigen. So let’s say that at 12 weeks, a puppy still has residual distemper virus immunity from the mother. If you give that puppy the distemper virus vaccine, it will neutralize some of the existing immunity against the virus, leaving the animal vulnerable until the new antibodies from the vaccine take over.

For distemper, that window of vulnerability can be relatively short. For parvo, it can be much longer. Parvovirus 2c, the new virulent strain in the U.S., is highly contagious and can be very serious in young puppies. We don’t want to create a vulnerability window by vaccinating puppies with existing maternal immunity and then assuming they are fully protected. They must receive the vaccine after 16 weeks for that assurance.

Other Risks Associated with Too-Early Rabies Vaccination

I asked Dr. Dodds if she has any other concerns about rabies vaccines in puppies under 16 weeks of age. Her response was that vaccines are not “sterile water.” They’re full of adjuvants and other substances that stimulate the immune system. They contain fetal calf serum. They contain activators. The purpose of vaccines is to stimulate the immune system in a very powerful way so it will produce antibodies.

When we’ve got young puppies who are going through all kinds of life changes – physical and psychological – their immune systems will be suppressed to some degree by the stress of all they are experiencing for the first time. We don’t want to overdo vaccinations at this critical time if we don’t have to.

So it’s possible that a puppy with residual maternal immunity against rabies who receives a rabies vaccination too early may wind up unprotected against the disease. And if for some reason that dog doesn’t receive a follow-up vaccination a year later, he could live his whole life unprotected from rabies. Since the whole point of vaccinations is to provide protection against disease, it doesn’t make any sense to time vaccines such that immunity may not be achieved.

Dr. Dodds explained that some animals don’t mount very good rabies immunity. That’s why two initial vaccinations are given within 12 months to insure that all pets are actually immunized – not just vaccinated. There’s a big difference between giving a vaccination and creating immunity. I think sometimes even veterinarians forget that distinction.

Another concern is that all but two types of rabies vaccines contain thimerosal, which is mercury, and we really don’t want to give mercury to animals with their vaccines.

Dangers of Adverse Rabies Vaccine Reactions

I asked Dr. Dodds to talk about what we are looking at in terms of potential vaccine reactions if California AB 272 is passed. Because most traditional veterinarians view vaccine reactions as either anaphylaxis (type I allergic reaction) or a type II reaction involving facial swelling, trouble breathing, hives, and other visible signs of an allergic response. But there are also delayed reactions that most vets don’t really think about, and don't often associate with vaccines.

If we’re vaccinating puppies with a very strong, adjuvanted vaccine at a younger age, what should pet owners look for in terms of potential vaccine reactions?

Dr. Dodds responded that she wishes she had a dollar for every frantic call she gets from a pet owner or veterinarian about an adverse reaction from a rabies vaccination. Many vets, including those at veterinary teaching hospitals, get confused about just what you described – the type I/type II more immediate reactions vs. delayed reactions.

In fact, according to Dr. Dodds there were two puppies in New Jersey that had severe rabies vaccine reactions seven days post-vaccination. Most delayed reactions occur between seven and 21 days after vaccination, but some don’t occur for up to 45 days. These two puppies were referred to a veterinary teaching hospital in the Northeast, and the owners were told the problem couldn’t be a rabies vaccine reaction because it was too long after the shots were given.

What you see very often with delayed reactions in young puppies are very disturbing symptoms like seizures or severe, adverse temperament changes such as irritability, snapping, or acting dazed. These puppies can exhibit odd behaviors like “fly-snapping” and staring at the ceiling. The seizures are of course very worrisome, because many people assume young puppies with seizures have congenital epilepsy. In fact, there have been instances where veterinarians have told owners they bought their dog from an irresponsible breeder who breeds epileptic dogs, when in fact the animal is having a delayed adverse reaction to a rabies vaccination. Dr. Dodds even knows of veterinary neurologists who don’t recognize the symptoms as an adverse vaccine reaction.

As Dr. Dodds explains, vaccine reactions can destroy joints, cause high fevers, and even cause the animal to scream out in pain when touched. They can destroy red blood cells and platelets. They can destroy the liver. But the scariest reactions involve neurological behavioral changes. Some of these puppies wind up abandoned or euthanized when all that was needed was detoxification support to address the rabies vaccinosis reaction.

Dr. Dodds feels very uncomfortable that veterinarians and pet owners are not being taught to recognize the adverse effects of rabies and other vaccines. Distemper vaccine reactions can also involve neurological signs, especially if the vaccine contains modified live virus -- the Rockborn strain of virus – that is known to produce post-vaccinal encephalitis. So we’re talking about post-vaccinal encephalitis from adjuvanted rabies vaccines with lots of immune system stimulants as well as from modified live distemper virus vaccines.

Pet Owners CAN Make a Difference!

Hopefully in states with this type of rabies vaccine legislation in the works, pet owners will get involved – because this will impact everyone’s pet. Another thing to keep in mind is if you’re forced to have your dog vaccinated for rabies at 12 weeks, you’ll want to be in touch with a holistic vet who can provide detoxification support.

Dr. Dodds also suggests visiting the Rabies Challenge Fund website. Dr. Dodds and Kris Christine are the co-trustees of the fund. Kris Christine has worked tirelessly to get uniform acceptance of a three-year booster requirement for rabies vaccines throughout the U.S. The site contains a wealth of information on pending and existing legislation and instructions on how to write to your congressional representatives to help them understand or learn more about the issue. (You can find your legislators here, and we encourage you to contact them to oppose AB 272.) For CA AB 272 information, including Dr. Dodds’ email exchanges with Dr. Karen Ehnert, visit this page of the Rabies Challenge Fund site.

Will the California Bill Influence Other States?

Dr. Dodds pointed out that in Michigan, as another example, there’s an unscheduled bill before the Agriculture Committee to require commercial puppy mills to vaccinate dogs for rabies at 12 weeks. The rest of the puppy population can wait until 16 weeks of age. This makes no sense. Puppies in these mills live in overcrowded, sometimes truly horrendous conditions. Why would we stress these animals even more by giving them a too-early rabies vaccine?

I asked Dr. Dodds if she thinks states beyond California will begin reviewing their rabies vaccine policies. She made the point that California tends to lead these initiatives … and it seems to be leading in the wrong direction on some issues lately.

Dr. Dodds wanted to make one final point about the situation in California. She wants to remind pet owners that 40 percent of dogs in California have never received a rabies vaccination. Nobody knows where these dogs are – they are unlicensed and unvaccinated. Californians need to focus on where those animals are, because they jeopardize everyone – animals and humans alike. Rather than have responsible pet owners vaccinate their dogs earlier, the focus should be on this very large population of unlicensed, unvaccinated, “missing” dogs.

I certainly agree. As Dr. Ronald Schultz always says, the animals that are vaccinated need fewer vaccines. And those that aren’t need immunologic protection.