January 2, 2012

Dear Board Members and Rabies Vaccination Committee Members,

We would like to take this opportunity to reiterate our opposition to the Board's/committee's scientifically unfounded endorsement of veterinarians administering a 3 year Rabies vaccine every 2 years. We would also like to clarify a point discussed at the last committee meeting regarding "importation and interstate movement of animals".

A story was shared at the meeting about an owner traveling with her canine companion from England to France recently. This owner could have been spared a costly and inconvenient trip back to get yet another Rabies vaccination for her dog, and the dog risked an adverse event and the possible risks of over-vaccination because her American veterinarian issued a 2 year certificate instead of the 3 year that should have been issued. The committee took issue with this. We would like to point out that veterinarians issuing a 2 year Rabies certificate do so in defiance of the Center for Disease Control's National Association of State Public Health Veterinarian's (NASPHV) recommendations in the Rabies Compendium, as well as the vaccine manufacturers and all national veterinary medical associations and veterinary medical colleges. Given that no 2 year Rabies vaccine is licensed in the USA, 2 year certificates are not consistent here or internationally within the context of Section B3 of the CDC's Compendium which states that "all imported dogs and cats are subject to state and local laws governing Rabies and should be currently vaccinated against Rabies in accordance with this Compendium". Under 42CFR Part 71.51[c] of the Minnesota Board of Animal Health rules, Administrative Rule 1705.1090 recognizes a 3 year Rabies vaccination protocol and specifies that the Rabies vaccine should be "used in accordance with the manufacturers labeling". [c] "before interstate movement dogs, cuts, ferrets and horse should be currently vaccinated against Rabies in accordance with this Compendium's recommendations (see Part 1B1)"animals in transit should be accompanied by a currently valid NASPHV Form 51, Rabies vaccination certificate... When an interstate health certificate or certificate of veterinary inspection is required, it should contain the same Rabies vaccination information as Form 51 Minnesota dog show Premium Lists have used the BAH rule for years setting the Rabies immunization requirement for interstate travel as "the vaccination is recognized for the duration of immunity as stated on the vaccine vial and that should be entered on the certificate".

Immunologically, the Rabies vaccine is the most potent of veterinary vaccines and administering it is a potent medical treatment with both benefits and risks to the patient. Adverse events, including some potentially severe and life threatening, can be unintended consequences of vaccinations. it is medically unsound for this vaccine to be given more often than necessary to maintain. immunity. None of the national veterinary medical associations, veterinary colleges or vaccine manufacturers who set the standard of practice for Rabies vaccine administration recommend giving a 3 year vaccine more often than every 3 years. There is NO scientific data/research demonstrating that giving a 3 year duration of immunity Rabies vaccine more often than every 3 years enhances immunity or benefits the animals health in any way. Consumers should not have to pay for an unnecessary medical treatment which does not benefit, and may even harm, their animal.

The Boards declared mission is to "promote, preserve and protect the health, safety and welfare of the public and animals through the effective control and regulation of the practice of veterinary medicine". Despite being a public agency funded by taxpayers, we have reason to believe closed meetings of the committee have been held on this issue affecting Minnesotan pet owners. It was obvious the agenda was set and the survey compiled without public input which would have arisen from a public meeting.

The Board/committee does not appear to support the practice of informed consent as mandated by Minnesota Administrative Rule 9100.0700 SubPart9 "Minimum Standards of Care, Informed Consent"- "a client shall be informed by the veterinarian prior to the treatment of the treatment choices for consideration by the client". The survey the committee sent to Minnesota veterinarians did not account for the fact that some veterinarians may not even understand what informed consent is and the implications of not following the practice. Failing to disclose that a vaccine being administered has a duration of immunity of 3 years appears to constitute "unprofessional conduct" under Minnesota Administrative Rule 9100.0700 SubPart1B "engaging in conduct likely to deceive the public". Informed Consent MUST also be documented in the patient record as stated by the 2007 American Veterinary Medical Association's position statement "Informed Consent". We would also like to remind the Board/committee that telling clients "the city requires it", I like giving this vaccine every 2 years" and "we do this become clients might be over due" does NOT qualify as informed consent. Failure to obtain informed consent not only carries potential legal liabilities, it may also violate Minnesota consumer protection laws. This Board is a consumer protection agency and has the moral and regulatory authority to protect pet owners and their animals from deceptive veterinarians who administer a 3 year Rabies vaccine every 2 years without full/complete disclosure and informed consent. Veterinarians wishing to vaccinate more often than the vaccine manufacturers labeled instructions and the interval recommended by the CDC and national veterinary medical associations MUST give full disclosure to the client divulging the duration of immunity of the vaccine being given and the potential adverse reactions that may occur. As consumers and responsible pet owners, we need to know and have the right to know this information so we may make educated choices for our companion animals.

It is improper and unprofessional for this Board to ignore or oppose the national standard of care for Rabies immunizations set by the United States Department of Agriculture, the CDC's NASPHVs Rabies Compendium, the American Animal Hospital Association, The American Veterinary Medical Association, the American Association of Feline Practitioners, all veterinary medical colleges, including the University of Minnesota, and all Rabies vaccine manufacturers. The Board and its committee have failed to provide any scientific data/research recommending that a 3 year duration of immunity Rabies vaccine be administered every 2 years. We also find the Board unprofessional and disrespectful to all the Minnesota veterinarians who practice the 3 year protocol by their continued defense of veterinarians practicing a 2 year protocol in light of all the compelling literature.

We strongly urge the Board to issue an immediate directive to all Minnesota veterinarians stating they are to administer all Rabies vaccines in accordance with the recommendation of the CDC's NASPHV's Rabies Compendium.

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