As we have discussed before, state and local rabies vaccination laws are fairly straightforward, and that these laws involving rabies vaccination status often need to be updated as applied to the local rabies exposure risk. This blog post will not address any required proof of rabies vaccinations at boarding kennels and grooming facilities, because they are generally standardized. Rather, we will address existing ambiguous state and local laws surrounding these facilities and their vaccination requirements.
We do believe these laws are well-intended. Nobody wants a canine parvovirus or distemper virus outbreak. However, they are frequently vague, poorly written, open to interpretation, and can cause outright confusion and frustration.
First, Don’t Blame the Facility…
Companion pet caregivers, boarding facilities, and groomers are simply obeying the laws so they do not lose their operating license. Indeed, many states require reporting of outbreaks of parvovirus or distemper at these facilities. So, ensuring that dogs are vaccinated makes sense.
However, the facilities need to be able to tell you exactly which vaccines are required by law, and what they personally require due to insurance purposes or otherwise. Additionally, they should provide the exact law to you via e-mail, their website, or a printed copy.
Also, Keep in Mind…
A state may have a law, but a municipality may have additional laws. Further, a state may not have a law, but a municipality does.
Vague Law #1: New York City
Canine Distemper, Adenovirus, Parainfluenza, Parvovirus and Bordetella Vaccinations Dogs Only
- Boarding kennels, training establishments and pet shops that provide boarding, training and/or grooming must:
- Keep proof of current vaccinations for all animals serviced. (Proof can be a medical record, invoice, veterinarian statement or receipt either provided by the owner or emailed or faxed from the dog’s veterinarian.)
- Keep on file a veterinarian’s letter confirming the status of any dog that is unable to be vaccinated for medical reasons.
- Facilities that provide grooming services only must:
- Keep proof of current vaccinations for all animals serviced. (Proof can be a medical record, invoice, veterinarian statement or receipt provided by the owner, or emailed or faxed from the dog’s veterinarian.) OR
- Get a sworn statement from the owner that the dog has been vaccinated. (This must include the name and contact information of the veterinarian who gave the vaccines.)
- Keep on file a veterinarian’s letter confirming the status of any dog that is unable to be vaccinated for medical reasons.
Vague Law #2: Iowa
67.7(1) Boarding kennels and commercial kennels.
- Records shall be made and retained for a period of 12 months for each animal boarded, groomed or trained. Records shall include the following:
(1) Owner’s name, address, telephone number and email address;
(2) Identification of animal;
(3) Duration of animal’s stay;
(4) Service(s) provided;
(5) Any illnesses which have occurred and veterinary treatment the animal received; and
(6) Written documentation of the animal’s vaccinations or vaccination exemptions from a veterinarian. - All dogs and cats transported into boarding kennels and commercial kennels regulated under Iowa Code, chapter 162 shall have been vaccinated against distemper, parvo and rabies, unless exempted by Iowa Code, section 351.42 or the direct written recommendation of a qualified veterinarian. Vaccine records and exemptions must be kept on file for a period of 12 months for each animal boarded, groomed, or trained.
- Vaccine titers shall not be accepted as a form of vaccine verification. Vaccine records and written vaccine exemptions shall be kept on file. Acceptable forms of documentation for vaccine verification include the following:
(1) Written documentation of vaccination from a veterinarian;
(2) A rabies certificate signed by a veterinarian. - Animals exhibiting symptoms of disease shall be promptly examined and treated by a veterinarian.
Iowa Law: Cat Distemper and Parvo?
Cats cannot contract canine distemper, but may contract newer mutations of canine parvovirus-2 (CPV-2) in very extreme and unlikely conditions. Cats do contract feline panleukopenia (FPL), which is a parvovirus and commonly referred to as feline distemper or feline parvo. A vaccine against FPL exists and provides cross-protection against CPV-2.
What does “current” mean?
The New York City law specifies, “current vaccinations”. What does “current” mean? Does it mean the most current round of these vaccinations? Does it mean these vaccinations have to be done within a specific time before grooming or boarding?
The vaccines against distemper, parvovirus and adenovirus-2 provide sterilizing immunity for 5-7 years. The vaccines against Bordetella do not convey sterilizing immunity and have to be boosted every 6-12 months. Parainfluenza also does not convey sterilizing immunity and the duration of immunity from the vaccine is essentially unknown.
Iowa’s law does not mention “current”. It simply states that dogs and cats need to be vaccinated against canine distemper, canine parvovirus, and feline panleukopenia. In our opinion, that means at some point in their life. However, groomers and boarding kennel operators may still ban your cat or dog because many of the veterinarian medical records automatically apply a date that expires one year from the last vaccination against any virus or bacterium with the exception of rabies.
Another stipulation of Iowa’s law states “the direct written recommendation of a qualified veterinarian” could be used to bypass the “expiration” date. New York City’s law regarding boarding kennels is stricter, “Keep on file a veterinarian’s letter confirming the status of any dog that is unable to be vaccinated for medical reasons.” However, the grooming law in New York is more relaxed.
What to do?
First, know the law in your area particularly if you have a companion pet that needs to be groomed. Indeed, it’s best to know now, before you may need to board your companion pet in an emergency or after a roll in dog poo.
Talk to the regulatory agency (usually a State Department of Agriculture) to find out its interpretation and enforcement of the law.
Speak with the boarding kennels or groomers to find out what additional vaccines they require beyond the law.
You can also speak with your veterinarian about receiving written documentation per the law or for moving their expiration date of a particular vaccine such as feline panleukopenia, canine parvovirus, canine distemper, and canine adenovirus. If anything, you could argue that even the American Animal Hospital Association states, “After the primary puppy series of vaccinations, a booster should be administered within 1 yr. Thereafter, interval boosters every 3 yr are recommended; annual boosters are not necessary.”
Also, try to ensure that your veterinarian is stocked on the vaccines you need to meet the minimum standards for the law, in case they insist on revaccinating annually or triennially.
Iowa will not permit a serum antibody titer test result to exempt a companion dog or cat from the vaccinations. However, an adequate titer test result may give the veterinarian confidence to write a justified medical exemption. Remember, an immunized companion animal with a positive serum antibody test for the clinically significant canine parvovirus, distemper virus or adenovirus-2 has so-called ‘sterilizing immunity’ and is protected from infection.
References
“Article 161.” Health Code and Rules, NYC Health, https://www.nyc.gov/site/doh/about/about-doh/health-code-and-rules.page. Accessed 3 Dec. 2023.
Dodds, W Jean. “Early Life Vaccination of Companion Animal Pets.” Vaccines vol. 9,2 92. 27 Jan. 2021, doi:10.3390/vaccines9020092, https://www.mdpi.com/2076-393X/9/2/92.
“Rule 21.67.7.” Iowa Legislature, https://www.legis.iowa.gov/law. Accessed 3 Dec. 2023.