Dr. W. Jean Dodds' letter of support for "Molly's Bill", AB 2000, and her refutation of the California Department of Public Health's opposition

Unfortunately there are still too many veterinarians (as well as pet owners) who do not recognize that there are possible side effects from administering the Rabies vaccine to dogs. Additionally, only healthy animals should ever be vaccinated, that's why it is so important to provide a medical exemption clause in any legislation that mandates vaccination.

The following is Dr. W. Jean Dodds' letter of support for "Molly's Bill", AB 2000, and her refutation of the California Department of Public Health's opposition:

PERMISSION GRANTED TO CROSS-POST

June 14, 2010

The Honorable Curt Hagman
California State Assembly
State Capitol, Room 4116
Sacramento, CA 95814

Re: CA Assembly Bill AB2000

Dear Assembly Member Hagman:

I learned today from your staff person, Saulo Londono, that the California Department of Public Health (CDPH) has officially opposed your sponsored bill AB 2000. This decision by the CDPH is a huge step backwards for veterinary health care professionals, like myself, who need to be able to justify exemption from rabies vaccine boosters on a case-by-case basis. Your bill AB 2000 would permit a safe alternative for dogs whose illnesses were caused by a rabies vaccine, as well as those too sick to tolerate the rabies vaccine because of terminal cancer, kidney/liver failure, grand mal seizures, and other chronic diseases.

The CDPH letter of June 8, 2010 states that “there is no scientific evidence that rabies vaccines are associated with severe or a high rate of vaccination reactions.” This statement is just false. The letter goes on to state that “Modern rabies vaccines are safe and effective”, and that “ A recent study published by the U.S. Department of Agriculture (USDA) found that rabies vaccines used for dogs ---- do not result in a high frequency or unexpected pattern of adverse events.” On the contrary, this same cited study found:


Rabies Vaccines and the USDA/CVB

Rabies vaccines are the most common group of biological products identified in adverse event reports received by the USDA’s Center for Veterinary Biologics (CVB). Currently, 14 rabies vaccines are labeled for use in dogs. Before licensure, a product must be shown to be safe through a combination of safety evaluations. The field safety trial is the most comprehensive evaluation and has the objective of assessing the safety of the product in its target population under the conditions of its intended use. However, safety studies before licensure may not detect all safety concerns for a number of reasons, as follows: insufficient number of animals for low frequency events, insufficient duration of observation, sensitivities of subpopulations (e.g. breed, reproductive status, and unintended species), or interactions with concomitantly administered products.


Reporting Adverse Vaccine Reaction to Manufacturer and the Government

There is no mandatory reporting of adverse reactions in veterinary medicine. The 2007 World Small Animal Veterinary Association (WSAVA) Vaccine Guidelines states that there is: "gross under-reporting of vaccine-associated adverse events which impedes knowledge of the ongoing safety of these products." WSAVA 2007 Vaccine Guidelines http://www.wsava.org/SAC.htm,

Despite the serious under-reporting of vaccine-associated adverse reactions, the 2008 Report from the USDA’s CVB [JAVMA 232:1000-1002, 2008], states that between April 1, 2004 and March 31, 2007, they "requested manufacturers of rabies vaccines to provide adverse event report summaries for their products. During this period, nearly 10,000 adverse event reports (all animal species) were received by manufacturers of rabies vaccines. Approximately 65% of the manufacturer's reports involved dogs."

The USDA/CVB 2008 Report further states that "Rabies vaccines are the most common group of biological products identified in adverse event reports received by the CVB." During the 3-year period covered in this report, the CVB received 246 adverse event reports for dogs in which a rabies vaccine was identified as one of the products administered.

The following clinical terms were listed “to describe possibly related adverse events in dogs vaccinated against rabies “ and reported to the USDA/CVB between April 1, 2004-March 31, 2007. For 217 adverse event reports – the clinical term is followed by the % of dogs affected:

Vomiting-28.1%; facial swelling-26.3%; injection site swelling or lump-19.4%; lethargy-12%; urticaria-10.1%; circulatory shock-8.3%; injection site pain-7.4%; pruritus-7.4%; injection site alopecia or hair loss-6.9%; death-5.5%; lack of consciousness-5.5; diarrhea-4.6%; hypersensitivity (not specified)-4.6%; fever-4.1%;, anaphylaxis-2.8%; ataxia-2.8%; lameness-2.8%; general signs of pain-2.3%; hyperactivity-2.3%; injection site scab or crust-2.3%;, muscle tremor-2.3%; tachycardia-2.3%; and thrombocytopenia-2.3%.

The overall adverse report rate for rabies vaccines was determined to be 8.3 reports/100,000 doses sold. Adverse events considered possibly related to vaccination included acute hypersensitivity (59%); local reactions (27%); systemic reactions, which refers to short-term lethargy, fever, general pain, anorexia, or behavioral changes, with or without gastrointestinal disturbances starting within 3 days after vaccination (9%); autoimmune disorders (3%); and other (2%).

While there may be no contraindications listed on the label for canine rabies vaccines, the labeling instructions on vaccine products clearly instruct veterinarians to only vaccinate healthy dogs. I submit that the dogs for which medically justified exemptions from rabies boosters are sought are not healthy.

The CDPH “believes that passage of AB 2000 could increase the risk to the public health by allowing dogs to be exempted from current rabies vaccination requirements.” This statement lacks credibility, as the number of dogs eligible for exemptions statewide would be small and such exemptions require that a primary care veterinarian justify them on a case-by-case basis. To deny these animals the opportunity to avoid serious or even fatal adverse events from rabies vaccines just encourages pet owners to break the law to save their pets from harm. They would then join the approximate 50% of pet owners in our State that fail to vaccinate their dogs at all. It is those that flaunt the law and never comply that we should seek out, rather than penalizing the few unfortunate pets and owners whose dogs cannot tolerate rabies boosters.

Finally, the CDPH letter states “ Standard veterinary immunization protocols already exist to prevent vaccine adverse reactions.” I know of no such standard protocols, and further, one often cannot predict which animals will react adversely without a prior history of reaction or family predisposition.

Sincerely,

W. Jean Dodds, DVM
Co -Trustee, Rabies Challenge Fund Charitable Trust;
President, Hemopet

Five common misconceptions about multivitamin supplements for dogs

 I'm frequently asked by clients and readers if they should add a multi-vitamin product to their dog's diet, since many (often self-proclaimed) experts push their use, often because they are marketing one product or another themselves.

Here's a look at claims often made about "complete" an/or "balanced" multi supplements:

1. A supplement needs to be "balanced"

This statement doesn't make sense because the goal of supplementation is to provide nutrients that are in short supply in the regular diet - which can vary quite a bit from one food product to another, depending on ingredients. In other words, we want to adjust what's already provided in the food by adding what's lacking or in short supply to create a good overall balance. A supplement that is "balanced" in itself may add more of what's already plentiful in the diet but still not help achieve sufficient levels of something else.

A concrete example: the minerals copper, iron and zinc interact with each other and need to be present in the diet not only in sufficient amounts, but also in the proper ratio. Let's say we add a supplement which in itself provides a correct ratio of these 3 minerals to each other to a diet that contains an adequate amount of copper, much more iron than the dog actually needs on a daily basis, and not enough zinc.

That supposedly "balanced" supplement does nothing to fix the issue, as it adds a little bit more copper to what's already sufficient, adds even more (unnecessary) iron, and doesn't address the zinc deficiency enough to make a difference.


2. Pets need a complete multivitamin/mineral supplement in addition to commercial food

From the discussion above, you can already guess that this claim is incorrect. After investigating many different commercial foods and comparing their nutrient content to the nutritional guidelines and recommendations of the National Research Council, I have found that most minerals are supplied in an overabundance, many times more than the average dog needs on a daily basis. A few tend to come up short, but these are generally required in tiny amounts, so that not much needs to be added on a weekly basis.

The fat soluble vitamins A and D are generally present in sufficient to high amounts, and adding more is not necessarily a good idea. The content of the water soluble vitamins of the B complex varies greatly from product to product and manufacturer to manufacturer.


3. Pets eating processed foods need lots of antioxidants

I agree that antioxidants are important, but please realize that when supplied in concentrated dosages and too great of an abundance, nutrients with anti-oxidant properties actually start to act as pro-oxidants. My recommendation is to not go overboard, too much of too many "good things" isn't necessarily in your dog's best interest, especially if certain health issues are present.

Choose to supplement fresh, unprocessed foods rather than yet another thing from a bottle or jar.


4. Nutrient X and nutrient Y work together, so they are both supplied in this product

This claim brings us back to the discussion under 1. and 2. - you already understand that ultimately the balance in the final diet, composed of food items *and* supplements is important, not just what the supplement adds. Sometimes it's wiser to just add one of the two, or more of one and less of another, to get a good balance.

A concrete example: An oil blend supplement claims that it is "balanced in omega 3, 6 and 9 fatty acids". Most commercial foods, and also many homemade diets, already contain enough (or even an overabundance) omega 6 fatty acids and no shortage of omega 9 fatty acids, so adding more is (a) unnecessary and (b) won't help to create a better overall balance.

Once again, save money and only add what's really needed.


5. If adding this supplement doesn't help, at least it won't harm, so it's ok to use

I wish I could say this is true, but as you can already guess from it appearing on my little list, it's not the case. Even something as innocuous as vitamin C can cause serious problems under some circumstances.

Sometimes they even contain not only poor quality ingredients best avoided, but outright suspect substances, like the synthetic version of vitamin K, menadione.

As a rule, do not buy any supplements for which you can not obtain a detailed analysis of nutrients and an ingredient list. If a manufacturer is not willing to inform you just how much of a particular nutrient (e.g. iodine) your dog will be ingesting per recommended daily serving of the product – using the excuse that this is "proprietary information" or some such nonsense – you are better off looking elsewhere.