May 5, 2006

Greetings Senators and Assemblypersons:

            I am writing to strongly urge you to vote NO on Senate Bill S02164 and Assembly Bill A04253 which would legally mandate that New York boarding kennels and grooming facilities require proof of vaccination “against distemper, hepatitis, para influenza, leptospirosis, parvo and bordetella during the previous year”  for dogs and “against feline viral rhinotracheitis, feline calicivirus,or feline panleuopenia within the past year” for cats engaging their services.

Requiring proof of annual vaccination with vaccines with much longer proven durations of immunity is ill-advised and reckless – it would put companion animals at needless risk of adverse reactions without boosting their immunity and incur unnecessary expense to their owners.  Veterinary medical schools do not recommend annual booster vaccinations for distemper, hepatitis, parvovirus, and feline panleukopenia, so why would the New York Legislature introduce bills that do?  It would be akin to requiring New York residents to be vaccinated annually against polio and/or tetanus.

The core canine distemper, hepatitis, and parvo vaccines (see Duration of Immunity to Canine Vaccines by Dr. Ronald Schultz http://www.cedarbayvet.com/duration_of_immunity.htm) have demonstrated durations of immunity beyond 7 years.  The American Animal Hospital Association’s (AAHA) 2003 Canine Vaccine Guidelines (http://www.leerburg.com/special_report.htm) states on Page 18 that:  “We now know that booster injections are of no value in dogs already immune, and immunity from distemper infection and vaccination lasts for a minimum of 7 years based on challenge studies and up to 15 years (a lifetime) based on antibody titer.”  They further state that hepatitis and parvovirus vaccines have been proven to protect for a minimum of 7 years by challenge and up to 9 and 10 years based on antibody count. 

The first entry under Appendix 2 of the AAHA Guidelines (http://www.leerburg.com/special_report.htm) “Important Vaccination ‘Do’s and Don’ts” is “Do Not Vaccinate Needlessly – Don’t revaccinate more often than is needed and only with the vaccines that prevent diseases for which that animal is at risk.”  They also caution veterinarians: “Do Not Assume that Vaccines Cannot Harm a Patient – Vaccines are potent medically active agents and have the very real potential of producing adverse events.”

            The American Veterinary Medical Association’s (AVMA’s) Principles of Vaccination (http://www.avma.org/issues/vaccination/vaccination.asp) states that “Unnecessary stimulation of the immune system does not result in enhanced disease resistance, and may increase the risk of adverse post-vaccination events.” (page 2)  They elaborate by reporting that: “Possible adverse events include failure to immunize, anaphylaxis, immunosuppression, autoimmune disorders, transient infections, and/or long-term infected carrier states.  In addition, a causal association in cats between injection sites and the subsequent development of a malignant tumor is the subject of ongoing research.”

            Perhaps New York’s Legislators have been confused by vaccine manufacturer’s labels.  According to AVMA’s Principles of Vaccination (http://www.avma.org/issues/vaccination/vaccination.asp), “..revaccination frequency recommendations found on many vaccine labels is based on historical precedent, not on scientific data … [and] does not resolve the question about average or maximum duration of immunity [Page 2] and..may fail to adequately inform practitioners about optimal use of the product…[Page 4] .”   As the Colorado State University Veterinary Teaching Hospital states it:  “…booster vaccine recommendations for vaccines other than rabies virus have been determined arbitrarily by manufacturers.”

            In an April 3, 2006 Newsday article by Denise Flaim entitled

Annual Vaccinations May Harm Your Pet, one of the world’s leading experts on veterinary vaccines, Dr. Ronald Schultz, is quoted as follows regarding vaccine labels:  "The label means nothing," Schultz says simply, noting that vaccines licensed for one year and three years are often the same product. "The label has an arbitrary and capricious annual revaccination requirement, and it takes an act of Congress to take it off" - literally. Schultz says the Department of Agriculture has applied to remove the language, a legislative process that he estimates will take seven years.

On Page 5 of the 2000 Report of the American Association of Feline Practitioners (http://www.aafponline.org/resources/practice_guidelines.htm (click on “Feline Vaccination Guidelines”), they state under “Feline Panleukopenia” that “Both serologic and challenge exposure data indicate that a parenteral FPV vaccine induces immunity that is sustained for at least 7 years.  Therefore, following the initial series of vaccinations and revaccination 1 year later, cats should be vaccinated no more frequently than once every 3 years.” 

            Again, I urge you all to VOTE NO on SB02164 and A04253.  If you have any questions or would like me to e-mail you a full copy of the AAHA Guidelines, please e-mail me.

Respectfully submitted,

Kris L. Christine

Alna, ME  04535

cc:  Dr. W. Jean Dodds

       Dr. Ronald Schultz