Complaint To The Texas Veterinary Board of Medical Examiners
Dear Board Members,
I assert that the present practice of marketing of vaccinations by Veterinarians for companion animals without informed consent and where there is no benefit to the pet constitutes fraud by misrepresentation, fraud by silence, theft by deception, and undue influence. I allege this is a common practice on the part of over 90% of Veterinarians engaged in companion animal practice in this state.
I hereby file a complaint about the fraudulent marketing practices by Veterinarians in the State of Texas for violation of the Texas Penal Code and the Rules of Professional Conduct, Rule 573.26 which states: Licensed veterinarians shall conduct their practice with honesty, integrity, and fair dealing to clients in time and services rendered, and in the amount charged for services, facilities, appliances and drugs.
I. Recommending, administering, and charging for Canine Corona virus vaccinations
for adult dogs is fraud by misrepresentation, fraud by silence, theft by deception, and undue influence given the literature that states:
1. Dogs over eight weeks of age are not susceptible to canine corona virus disease.Canine corona virus has never been demonstrated to cause disease in adult dogs.
2. The argument that dogs that develop parvovirus enteritis concurrently with corona virus infection will develop worse symptoms than a dog that develops parvovirus alone is without merit. If dogs over eight weeks of age are immunized against canine parvovirus they will not develop symptoms of canine corona virus disease. Addition of an unnecessary antigen to the vaccine will result in increased risk of adverse reactions.
3. Immunologists doubt that Canine Corona virus vaccine works, as it would require secretory mucosal IgA antibodies to protect against corona virus infection, and a parenteral vaccine does not accomplish this very well.
4. The American Animal Hospital Association, the American Veterinary Medical Association Council on Biologic and Therapeutic Agents and Twenty-two Schools of Veterinary Medicine including Texas A&M University do not recommend canine corona virus vaccine.
5. Gastroenterologists at Schools of Veterinary Medicine including Dr Michael Willard at Texas A&M University have stated that they have only seen one case of corona virus disease in a dog in ten years.
6. On at least one occasion large numbers of dogs have died from adverse reactions to corona virus vaccine.
7. A reasonable client would not elect corona virus vaccination for an adult dog if
presented this information.
References:
Dogs over 8 weeks of age do not develop disease from canine corona virus.
1. Wolf, Alice M., Vaccinations-what’s right? What’s not? Compendium on CE, Schering-Plough Animal Health, 1999, pg. 32,33.
2. Paul, Michael A., Vaccinations-what’s right? What’s not? Compendium on CE,Schering-Plough Animal
Health, 1999, pg. 32,33.
3. Schultz, Ronald D., “Are we vaccinating too much?” JAVMA, No. 4, August 15, 1995, pg. 421.
4. Schultz, Ronald D., “Current and future canine andfeline vaccination programs”, Veterinary Medicine, March 1998, pg. 251.
5. Klingborg, Hustead, Curry Galvan, AVMA Council On Biologic and Therapeutic Agent’s report on cat and dog vaccines, JAVMA, Vol 221, No 10, Nov 15, 2002.
6. Paul, Michael, Report of the American Animal Hospital Association Canine Vaccine Task Force: 2003 Canine Vaccine Guidelines, Recommendations, and Supporting Literature, AAHA Foundation, March 2003
7. Ford, Richard B, Vaccines and Vaccinations, The Veterinary Clinics of North America, Volume 31, No 3, May 2001
8. Wilson RB, Holladay JA, Cave JS, A Neurologic Syndrome Associated with the Use of Canine Coronavirus-Parvovirus Vaccine in Dogs, compendium on CE, 8,1986, 117-124.
II. Recommending, administering, and charging for re- administration of modified live vaccines like Canine Distemper, Canine Parvovirus, Feline Panleukopenia, injectable Feline Rhinotracheitis, and injectable Feline Calicivirus on an semi-annual, annual, or bi-annual basis is theft by deception, fraud by misrepresentation, misrepresentation by silence, and undue influence given the literature that states:
1. The American Veterinary Medical Association, Council on Biologic and Therapeutic Agents has advised the USDA Center for Veterinary Biologics that there is no scientific data to support label claims for annual re-administration of modified live vaccines, and label claims should be backed by scientific data.
2. It is the consensus of immunologist that a modified live virus vaccine must replicate in order to stimulate the immune system. With repeat administration of a MLV vaccine antibodies from a previous vaccination will block the replication of the new vaccinate virus. The immune status of the patient is not enhanced in any way. There is no benefit to the patient. The client is paying for something with insignificant or no effect, except that the patient is being exposed to unnecessary risk of an adverse reaction.
3. A temporal association has been demonstrated between vaccinations and the development of Immune Mediated Hemolytic Anemia.
4. It has been demonstrated that the duration of immunity for Canine Distemper virus is 7 years by challenge, and 15 years by serology; for Canine Parvovirus is 7 years by challenge, for Feline Panleukopenia, Rhinotracheitis, and Feline Calicivirus is 7.5 years by challenge.
References:
1. HogenenEsch Harm, Dunham Anisa D, Scott-Moncrieff Catharine, Glickman Larry, DeBoer Douglas J, Effect of vaccination on serum concentrations of total and antigen-specific immunoglobulin E in dogs, AJVR, Vol 63, No. 4, April 2002, pgs. 611-616.
2. Wolf, Alice M., Vaccinations-What’s right? What’s not? Compendium on ContinuingEducation, Schering-Plough Animal Health, 1999, pg. 32.
3. Wolf Alice, Vaccines of the Present and Future, Proceedings of the World Animal Veterinary Congress, Vancouver 2001.
4. Schultz, Ronald D., “Are we vaccinating too much?” JAVMA, No. 4, August 15,
1995, pg. 421.
5. Schultz, Ronald D., “Current and future canine and feline vaccination programs”, Veterinary Medicine, March 1998, pg. 243.
6. Schultz, Ronald D, Duration of Immunity to Canine Vaccines: What We Know and What We Don’t Know, Proceedings – Canine Infectious Diseases: From Clinics to Molecular Pathogenesis, Ithaca, NY, 1999, 22.
7. Schultz, Ronald D, The Vaccine Controversy: What Vaccines Do Cats and Dogs Really Need and How Often Do They Need To Be Vaccinated? Department of Pathobiological Sciences, School of Veterinary Medicine, University of Wisconsin-Madison.
8. Larson L J, Sawchuck S, Bonds M D, Schultz RD, Comparison of Antibody Titers Among Dogs Vaccinated, One, Two, Three Years Previously, Proceedings of 80th Meeting of the Conference of Research Workers in Animal Diseases, CRWD, Chicago, IL, 1999.
9. Gorham, J.R., “Duration of vaccination immunity and the influence on subsequent prophylaxis” JAVMA 149:699-704; 1966
10. Phillips, Tom R. and Schultz, Ronald D, “Canine and Feline Vaccines”, Current Veterinary Therapy XI, ed. Kirk and Bonagura, pg. 202, 205, WB Saunders Co, Philadelphia, PA 1992.
11. Klingborg Donald, Principles of Vaccination, AVMA Council on Biologic and Therapeutic Agents, Policy on Biologics, April 2002
12. Paul, Michael, Report of the American Animal Hospital Association Canine Vaccine Task Force: 2003 Canine Vaccine Guidelines, Recommendations, and Supporting Literature, AAHA Foundation, March 2003
13. Ford, Richard B, Vaccines and Vaccinations, The Veterinary Clinics of North America, Volume 31, No 3, May 2001
14. Tizard Ian, Use of serologic testing to assess immune status of companion animals, JAVMA,Vol 213, No 1, July 1, 1998.
15. Scott FW, Cordell MG, Long – term immunity in cats vaccinated with an inactivated trivalent vaccine, AJVR, May 1999, Vol. 60, No. 5.
16. Lappin MR, Andrews J, Simpson D, Jensen W, Use of Serologic Tests to Predict Resistance to Feline Herpesvirus 1, Feline Calcivirus, and Feline Parvovirus Infection in Cats, JAVMA, 220[1]: 38-42 Jan 1,2002
III. Ordinances by Counties and Municipalities requiring annual rabies vaccination are illegal, as they require the client to purchase something with no effect. The recommendation of annual rabies vaccination for dogs and cats with three- year duration of immunity vaccine is theft by deception, fraud by misrepresentation, misrepresentation by silence, and undue influence given that:
1. Rabies vaccine has been licensed by the USDA as a three- year vaccine. Rabies vaccine has been proven to have a minimum duration of immunity of three years by challenge to the USDA, seven years by serology by Dr Ron Schultz, and 4 years for cats and 5 years for dogs by challenge by Aubert.
2. Beyond the second vaccination, no data exist to demonstrate that the immune status of the pet is enhanced. Data shows that the immune status of the pet is not enhanced. When the rabies vaccine is re-administration the client is paying for something with no benefit.
3. The National Association of State Public Health Veterinarians recommendation is for vaccination of dogs and cats for rabies at four months, one year later, and then every three years subsequently. This recommendation has been proven effective in 33 States in the United States.
4. The Texas Department of Public Health has adopted a new tri-annual policy effective in March 2003.
References:
1. The Texas Department of Public Health, White Paper on Options for rabies
vaccinations.
2. HogenenEsch Harm, Dunham Anisa D, Scott-Moncrieff Catharine, Glickman Larry, DeBoer Douglas J, Effect of vaccination on serum concentrations of total and antigen-specific immunoglobulin E in dogs, AJVR, Vol. 63, No. 4, April 2002, pg 611-616.
3. Wolf, Alice M., Vaccinations-What’s right? What’s not? Compendium on ContinuingEducation, Schering-Plough Animal Health, 1999, pg. 32.
4. Wolf Alice, Vaccines of the Present and Future, Proceedings of the World Animal Veterinary Congress, Vancouver 2001.
5. Schultz, Ronald D, Duration of Immunity to Canine Vaccines:
What We Know and What We Don’t Know, Proceedings – Canine
Infectious Diseases: From Clinics to Molecular Pathogenesis,
Ithaca, NY, 1999, 22.
6. Aubert Michel F, The practical significance of rabies antibodies
in cats and dogs, Scientific and Technical Revue, 11(3) 735,
1992 Paris, France
7. “Administration of rabies virus vaccines to cats is subject
to inconsistent state and local statutes. In some cases, the
requirements fail to consider the duration of protection
such vaccines induce; annual administration of rabies
vaccines approved for triennial administration is required in
many locals. Veterinary organizations should continue to
work with state and local governing bodies to ensure that
rabies virus vaccine regulations are consistent with the
known duration of immunity of available vaccines.”
Richards J, 2000 Report of the American Association of Feline
Practitioners and the Academy of Feline Medicine Advisory Panel
on Feline Vaccines.
8. “Local and regional regulatory authorities mandate
revaccination schedules including some that are more
frequent than necessary as demonstrated by scientific
evidence.”
Klingborg, Hustead, Curry Galvan, AVMA Council On Biologic and
Therapeutic Agent’s report on cat and dog vaccines, JAVMA,Vol
221, No 10, Nov 15, 2002.
9. “Every effort should be made to change laws that require
vaccination with this rabies product more often than every
three years since annual vaccinations cannot be shown to
increase efficacy and it is known to increase adverse events”
Paul, Michael, Report of the American Animal Hospital Association
Canine Vaccine Task Force: 2003 Canine Vaccine Guidelines,
Recommendations, and Supporting Literature, AAHA Foundation,
March 2003
IV. The recommendation for administration of Leptospirosis
vaccination in Texas without informed consent of the
incidence in the locality and the potential side effects is theft
by deception, fraud by misrepresentation, misrepresentation
by silence and undue influence given the fact that:
1. Although Leptospirosis is re-emerging as an endemic disease for dogs in some areas of the country, Leptospirosis in dogs in Texas is a very rare disease. According to the Texas Veterinary Medical Diagnostic Lab there are only an average of twelve cases of Leptospirosis documented in dogs in Texas per year. Factors to identify those dogs that are at risk have not been identified. Given that there are over 6 million dogs in Texas, the risk of leptospirosis disease to a dog is less than 2 in a million.
2. The commonly used vaccine only contains serovars Lepto. canicola, and Lepto. icterohaemorrhagiae, and no cross protection is provided against the other three serovars diagnosed in Texas. Newer vaccines containing Lepto pomona, and Lepto grippotyphosa are available. To provide protection for a dog against Leptospirosis would require two vaccines with four serovars annually.
3. Although humans can develop Leptospirosis, the spread of Lepto. from a dog to a human has never been documented and is thought to be a very low risk.
4. Given that the risk of an adverse reaction, a reasonable client would not elect vaccination of their pet for leptospirosis if provided with the above information.
References:
1. Angulo, A. B. DVM, MS, PhD, ACVM, College Station, Texas, Personal phone conferences. (Antec samples are all sent to the TVMDL, Idexx samples are sent to Michigan and Texas results are not available.)
2. Klingborg, DJ, Hustead DR, Curry-Galvin E, AVMA Council on Biologic and Therapeutic Agents’ Report on cat and dog vaccines, JAVMA, Vol. 221, No 10, Nov 15, 2002, pg 1401- 1407.
3. Wolf Alice, Vaccines of the Present and Future, Proceedings of
the World Animal Veterinary Congress, Vancouver 2001
V. The recommendation of Lyme disease vaccine for dogs residing
in Texas without informed consent is fraud by
misrepresentation, misrepresentation by silence and undue
influence given the literature that states:
1. Eighty per cent of Lyme disease cases in the U. S. are found in
nine New England States, Minnesota and Michigan.
2. The Texas Department of Health reports an average of 70 human
cases of Lyme disease in Texas annually, many of which were
acquired when people traveled outside of the State.
3. Julie Rawlings reported in her research on the incidence of the
Lyme disease organism in Texas State Parks for the Texas
Department of Health, that the Borrelia buorgdorferi organism is
not present in sufficient amounts in the suitable tick vector for
dogs to be at risk of Lyme disease in Texas.
4. Texas A&M College of Veterinary Medicine has not documented one
case of Lyme disease in a dog. Screening of shelter dogs by
Dr Alice Wolf has not demonstrated one case.
5. Dr Jacobson, Cornell University (ret) has documented a temporal
relationship between Lyme vaccine and the development of
polyarthritis in dogs.
6. A reasonable client would not elect Lyme disease vaccine for their
pet if given this information on the risk vs. benefit of the vaccine.
References:
1. Klingborg, DJ, Hustead DR, Curry-Galvin E, AVMA Council on Biologic and Therapeutic Agents’ Report on cat and dog vaccines, JAVMA, Vol 221, No 10, Nov 15, 2002, pg 1401- 1407.
2. Greene CE, Schultz RD, Ford, R, Canine Vaccination, Veterinary Clinics of North America: Small Animal Practice, Vol 31, No 3, May 2001, pg 473- 492.
3. Jacobson RH, Chang YF, Shin SJ, Lyme disease; laboratory diagnosis of infected and vaccinated symptomatic dogs, Seminars in VET Medicine and Surgery; Small Animal, 11(3); 172-82 Aug 1996.
5. Schultz, Ronald D., “Current and future canine and feline vaccination programs”, Veterinary Medicine, March 1998, pg.
6. Wolf Alice, Vaccines of the Present and Future, Proceedings of the World Animal Veterinary Congress, Vancouver 2001
VI. Injection site fibrosarcoma is a fatal type of cancer caused by
vaccines. Clients should be informed of the risk of a vaccine
causing an injection site fibrosarcoma. The vaccination of a
cat without informing the customer of the risk of an injection
site fibrosarcoma is fraud by omission of a material fact. .
Although any injection can result in a fibrosarcoma,
adjuvanted vaccines have been determined to be at least five
times a higher risk of causing an injection site fibrosarcoma. Clients
should be advised of safer alternatives including reduced
vaccination schedules, intranasal vaccines, and non-adjuvanted
vaccines. The recommendation for vaccination of cats without
informed consent is fraud by misrepresentation, misrepresentation
by silence, and undue influence as well as cruelty to animals given
the literature that states:
1. Vaccines have been incriminated as a cause of Injection Site Fibrosarcoma in cats.
2. Adjuvanted vaccines have been demonstrated to be at higher risk.
3. It is estimated that 1:20,000 cats vaccinated develop vaccine-associated fibrosarcoma.
4. Injection site fibrosarcomas are 100% fatal if untreated. The prognosis, even with surgery, radiation and chemotherapy is very poor.
5. The American Association of Feline Practitioners and the AVMA Vaccine Associated Sarcoma Task Force recommend reduced vaccination schedules and alternative non-adjuvanted and intranasal vaccines.
6. A reasonable client would not elect unnecessary or unsafe vaccines for their cat if given this information.
References
1. O’Rourke Kate, Progress made in feline sarcoma research, JAVMA, Vol. 220, No 6, March 2002.
2. Bergman P, Hendrick MJ, Macy D, McGill LD, Starr RM, Van Kampen KR, Feline Sarcoma and Vaccination, Veterinary Forum, March 1999,40-47.
3. Bergman PJ, Etiology of feline vaccine-associated sarcomas, JAVMA, 1998,213, 1424-1425.
4. Kass PH, Barnes WG, Spangler WL, Epidemiologic evidence for a Causal Relationship Between Vaccination and Fibrosarcoma Tumorigenesis in Cats, JAVMA, 1993,203, 396-405.
5. Meyer EK, Vaccine Associated Adverse Events, Veterinary Clinics of North America; Small Animal Practice, Vol 31, No 3 May 2001, pg 473-492.
6. Gaskell R, Gettinby G, Graham S, Skilton D, Veterinary Products Committee working Group on Feline and Canine Vaccination, Department for Food & Rural Affairs, Nobel House London, UK, May 2001
7. Ford, Richard, Vaccines & Vaccinations Change is in the Wind, Merial Ltd, 2003
VII. The recommendation for vaccination of cats with Feline
Infectious Peritonitis vaccine is fraud by misrepresentation,
misrepresentation by silence, and undue influence given the
literature that states:
1. Feline Infectious peritonitis is a rare disease.
2. Eight percent of adult cats carry the normal flora a virulent Feline Corona Virus. On rare occasions this Corona Virus mutates to become a virulent feline Infectious Peritonitis Virus. Every mutation is a different variant and there no cross protection. This vaccine does not and cannot work.
3. Independent studies have not confirmed the manufacturers claims for efficacy.
4. Twenty- two Schools of Veterinary Medicine, The American Veterinary Medical Association Council on Biologic and Therapeutic Agents and the American Association of Feline Practitioners does not recommend this vaccine.
5. A reasonable client would not elect this vaccine if given this
information.
References:
1. Kennedy M, Boedecker N, Gibbs P, Kania S, Deletions of the 7a ORF of feline
corona virus associated with an epidemic of FIP, Vet Microbiology, 81(3): 227-34, Aug. 8, 2001 Department of Comparative Medicine, U of Tenn, CVM.
2. Kiss I, Kecskemeti S, Tanyi J, Klingeborn B, Belak S, Prevalence and genetic pattern of feline coronavirus in urban cat populations, Vet J 159, (1); 64-70, Jan 2000.Veterinary Institute of Debrecen, Hungary, Harcourt Publishers Ltd, 2000.
3. Vennema H, Poland A, Hawkins F, Pedersen NC, A comparison of the genomes of FECV and Feline Infectious Peritonitis viruses, Feline Practice, 23,40-44,1995.
4. Herreewegh AA, Maher M, Hedrich HJ, Haagmans BL, Egberink
HF, Persistence and Evolution of Feline Corona virus in a closed
5. Richards J, Rodan I, Feline Vaccine Guidelines, Veterinary
Clinics of North America, Small Animal Practice, Vol 31, No 3,
6. Rohrbach Barton W, Legendre A M, Epidemiology of Feline
Infectious Peritonitis Among Cats Examined at Veterinary
Teaching Hospitals, JAVMA 218, (7): 111-15 April 1, 2001.
7. Vennema H, Genetic drift and genetic shift during feline
coronavirus evolution, Vet Microbiology 69(1-2); 139-41 1999
Sept 1.
8. Gunn-Moore DA, Gunn-Moore FJ, Gruffydd-Jones TJ, Harbour
DA, Detection of FeCoV quasaspecies using denaturing
gradient gel eletrophoresis, Vet Microbiology 69(1-2): 127-30
Sept 1, 1999.
9. Kida k, Hohdatsu T, Fuji K, Koyama H, Selection of antigenic
variants of the S glycoprotein of FIP virus and analysis of
antigenic sites involved in neutralization, J Vet Med Sci.
61(8): 935 – 8 Aug 1999
10. Vennema H, Poland A, Foley J, Pederson NC, Feline Infectious
peritonitis viruses arise by mutation from endemic feline
enteric coronaviruses, Virology 234(1): 150-7, March 30,1998.
11. Kennedy MA, Brenneman K, Millsaps RK, Black J, Potgieter LN,
Correlation of genomic detection of feline coronavirus with
various diagnostic assays for feline infectious peritonitis, J Vet
Diagn Invest 10(1); 93-7, Jan 1998.
12. Herreweigh AA, Mahler M, Hedrich HJ, Haagmans Bl, Egberink
HF, Horzinek MC, Rottier PJ, de Groot RJ, Persistence and
evolution of feline coronavirus in a closed cat-breeding
colony, Virology 234(2): 349-63, Aug 4 1997.
13. Mochizuki M, Misutake Y, Miyanohara Y, Higashihara T, Shimizu
T, Hodatsu T, Antigenic and plaque variations of serotype II
feline infectious peritonitis coronavirus, J Vet Med Sci, 59(4):
253-8, April 1007.
14. Klingborg DJ, Hustead DR, Curry-Galvin EA, AVMA Council on
Biologic and Therapeutic Agent’s report on cat and dog
vaccines, JAVMA Vol 221, No 10,pg 1407. November 15,
2002
15. 2000 Report of American Association of Feline Practitioners
and Academy of Feline Medicine Advisory Panel on Feline
Vaccines, pg. 15 & 16.
VIII. The recommendation of Feline Immunosupressive virus (FIV) vaccine is fraud by misrepresentation, misrepresentation by silence, and undue influence given the literature that states:
1. The virus in the vaccine is Clade A & D. The predominate Clade
found to cause FIP disease in the United States is Clade B.
Cross protection is poor.
2. A reasonable client would not elect this vaccine for their cat if
given this information.
References:
1.Yamamoto, Janet K, Torres Barbara A, Pu Ruiyi, Development of
the dual-type feline immunodeficiency virus vaccine, AIDScinece
Vol. 2, No 8, 26 April 2002.
2. Pu Ruiyi, Dual-subtype FIV vaccine, AIDS 15, pg. 1225-37, July
6, 2001 (Pub Med)
IX The recommendation for annual Feline Leukemia vaccine for
indoor only cats, or adult cats without informed consent is
theft by deception, fraud by omission of material facts, and
undue influence given the literature that states;
1. Cats over one year of age are resistant to Feline leukemia virus whether they are vaccinated or not.
2. Although the duration of immunity of Feline Leukemia vaccine
is controversial, twenty- two Schools of Veterinary Medicine,
and the American Association of Feline Practitioners
recommend this vaccine for at-risk adult cats only.
References:
1. Klingborg DJ, Hustead DR, Curry-Galvin EA, AVMA Council on Biologic
and Therapeutic Agent’s report on cat and dog vaccines, JAVMA
2. Hoover EA, Feline leukemia virus infection: Age related variation in response to infection, Journal of the National Cancer Institute, 57, 365. (1776)
3. Hofmann-Lehmann R, Recombinant FeLV Vaccine: Long-term protection effect on course and outcome of FIV infection, Veterinary Immunology Immunopathology, 4691- 2); 127-37 May 1999
4. 2000 Report of American Association of Feline Practitioners and
Academy of Feline Medicine Advisory Panel on Feline Vaccines.
X. The recommendation of blood tests for antibody titers on dogs
and cats in order to determine if re-administration of vaccine is
indicated is fraud by misrepresentation, misrepresentation by
silence, and undue influence given the literature that states:
1. The duration of immunity to infectious disease agents is controlled by memory cells, B & T lymphocytes. Once programmed, memory cells persist for life. The presence of memory cells is not taken into effect when testing for antibody titers.
2. Even in the absence of an antibody titer, memory cells are capable of mounting an adequate immune response in an immunized patient. A negative titer does not indicate lack of immunity, or the ability of a vaccine to significantly enhance the immune status of a patient.
3. A positive titer has not been demonstrated by challenge studies to indicate immunity.
4. The client is paying for a test where the Veterinarian can make no claims as to the significance of a positive or negative test result.
5. A reasonable client would not elect to pay for this test if given this information.
References:
1. Wolf, Alice M., Vaccinations-what’s right? What’s not? Compendium on CE, Schering-Plough Animal Health, 1999, pg. 32,33.
2. Klingborg Donald, Principles of Vaccination, AVMA Council on Biologic and Therapeutic Agents, Policy on Biologics, April 2002.
3. Wolf Alice M, Just the Facts About Vaccs: Frequently Asked Questions About Current Vaccination Recommendations and Practice Guidelines, Proceedings from the North American Veterinary Conference, 13, 1999, pg. 681.
4. 2000 Report of American Association of Feline Practitioners
and Academy of Feline Medicine Advisory Panel on Feline
Vaccines, pg. 15 & 16.
5. Klingborg, DJ, Hustead DR, Curry-Galvin E, AVMA Council on
Biologic and Therapeutic Agents’ Report on cat and dog
vaccines, JAVMA, Vol 221, No 10, Nov 15, 2002, pg 1401- 1407.
6 . Paul, Michael, Report of the American Animal Hospital
Association Canine Vaccine Task Force: 2003 Canine Vaccine
Guidelines, Recommendations, and Supporting Literature, AAHA
Foundation, March 2003
The Texas State Board of Veterinary Medical Examiners has reviewed this complaint and found nothing inaccurate or untrue. Despite my repeated requests over the last four years, the
Texas State Board of Veterinary Medical Examiners has failed to take any reasonable and demonstrated action to stop the deceptive trade practices and fraud in the marketing of vaccinations for companion animals. The open letter to Veterinarians approved by the Board February 13, 2003(Enclosed) cannot reasonably be expected to stop Veterinarians from the prevailing fraudulent protect the people of Texas, and whereby it is provided in the Texas Administrative Code Title 22, Part 24, Chapter 577, Subchapter B, Rule 577.16: Responsibilities of the Board (a) The Texas Board of Veterinary Medical Examiners is responsible for establishing policies and promulgating rules to establish and maintain a high standard of integrity, skills, and practice in the profession of Veterinary medicine in accordance with the Veterinary Licensing Act. The Licensing Act clearly provides for the Board to prohibit the prescribing of unnecessary medications. I hereby assert that the Texas State Board of Veterinary Medical Examiners is negligent in its responsibilities.
The Texas State Board of Veterinary Medical Examiners Board has ignored my repeated requests to deny approval of Continuing Education credit where a conflict of interest exists. CE credits should not be allowed for seminars provided by paid employees of drug companies. Pfizer Animal Health, Fort Dodge Animal Health, and Meriel have provided seminars, which are fraudulent by omission of material facts, misrepresent the scientific data, and thereby influence Veterinarians to continue deceptive trade practices in the marketing of vaccines. (A separate complaint will be filed with your office and the Federal Trade Commission alleging false advertising on the part of these three companies.)
The people of the State of Texas have pay over $360 million dollars per year for vaccinations that are unnecessary and potentially harmful to their pets. Over 2,000 pets die every year from adverse reactions to unnecessary vaccinations. A survey by the American Animal Hospital Association shows that less than 7% of Veterinarians have updated their vaccination recommendations, in spite of the fact that these new recommendations have been published twice in every major Veterinary Medical Journal since 1995.
I am not asking that the Veterinarians of the State be punished. I am requesting that the fraudulent marketing of vaccines and harming of clients pets be stopped.
A reasonable solution would be for the Attorney Generals office to request an Assurance of Voluntary Compliance on the part of each Veterinarian engaged in companion animal practice in the State, agreeing to stop the marketing of vaccines without informed consent, and where no benefit has been scientifically demonstrated.
A reasonable solution would be for the Texas State Board of Veterinary Medical Examiners to request an opinion from the Attorney General on these issues, and for the
Texas State Board to issue a policy statement in the Board Notes indicating a Board policy requiring informed consent, and prohibiting deceptive practices as I have outlined above