Rabies

Legislative Overview

Published: October 2014

Revised: April 2018, July 2018, May 2019, May 2021, July 2022, July 2023

Purpose

The purpose of this legislative overview is to describe the requirements veterinarians are expected to meet under both federal and provincial legislation in regard to the control of rabies and vaccination of animals. Answers to frequently asked questions provide further clarification. 

Overview of the Health of Animals Act (Canada) and Regulation 

The Health of Animals Act is intended to control the spread of disease between and among animals as well as transmission from animals to persons. Sections 130 – 135 of the Health of Animals Regulation address a variety of issues related to veterinary biologics and include a specific reference in section 134 regarding the sale of rabies vaccines. Section 134.2 of the Regulation prohibits the sale of rabies vaccines to non-veterinarians.

Overview of Health Protection and Promotion Act (Ontario) and Regulations

The Health Protection and Promotion Act (HPPA) is intended to provide for the organization and delivery of public health programs and services that are administered by the Ministry of Health and Long-Term Care (MOHLTC). Under the HPPA, public health units have a very broad mandate including sanitation, family counselling, health promotion and protection, and injury and disease prevention and control. Although the number of rabies incidents reported each year in Ontario is small, the disease is endemic in some animal populations and, consequently, the prevention and control of rabies in humans is one of the objectives established by the MOHLTC under the HPPA. 

Relevance to Veterinary Practice 

The HPPA contains two regulations that apply to veterinary medicine. Regulation 567 Rabies Immunization provides direction to veterinarians who carry out rabies immunizations. Regulation 557 Communicable Diseases – General sets out expectations for veterinarians regarding reporting animal bites and the management of animals suspected of having rabies. These regulations complement the requirements set out under Regulation 1093 of the Veterinarians Act. For the purposes of understanding the requirements under these regulations, within a Public Health Unit, a board of health appoints a Medical Officer of Health, to whom public health inspectors report to.

Under Regulation 557, the following expectations are described:  

• A veterinarian must report to the local Medical Officer of Health, immediately, any knowledge of a bite from a mammal or any contact with a mammal that may result in rabies in persons, including the name and contact information of the exposed person;
• A veterinarian must comply with a request from a Medical Officer of Health or public health inspector to examine a dog or cat or ferret for evidence of rabies and to confine, and/or isolate the animal for at least 10 days, if necessary, to determine if it is remains free of symptoms of rabies. The Medical Officer of Health or public health inspector may also request that a veterinarian confine and isolate an animal at a pound or veterinary hospital for at least 10 days;
• A veterinarian must comply with a request from a Medical Officer of Health or public health inspector to examine a horse, cow, bull, steer, calf, sheep, pig, or goat for evidence of rabies and to confine, and/or isolate the animal for at least 14 days at the location that the animal is normally housed, if necessary, to determine if it remains free of symptoms of rabies. The Medical Officer of Health or public health inspector may also require that the animal in question be confined and isolated at a veterinary hospital if they are of the opinion that the person caring for the animal is unlikely to confine and isolate it; 
• A Medical Officer of Health or public health inspector may be required to test animals that have died or were euthanized during a 10-day post-exposure confinement period as a means of preventing victims of animal bites to have to undergo post-exposure rabies vaccines. Under Regulation 557, this test may be done with or without the animal owner’s consent;
• A Medical Officer of Health or public health inspector may require the destruction of any animal at any time for the purpose of having a laboratory examination to determine if the animal is in the infective stage of rabies. In the case of a dog, cat or ferret, this only applies where the dog, cat or ferret is unclaimed or where permission is given by the owner for the destruction of the dog, cat or ferret.

Frequently Asked Questions

The following questions and answers are intended to provide veterinarians with additional information regarding rabies immunization. 

Biting Incidents and Reporting  

Are veterinarians required to report all bites and contact incidents by an animal? 

Regulation 557 requires a veterinarian to report to the local Medical Officer of Health, as soon as possible, knowledge of any bite or other animal contact that may result in rabies in a person. A veterinarian uses their professional judgement and knowledge of how rabies is transmitted to assess if there is a need to report. A veterinarian is not required to assess the likelihood of rabies disease in the biting animal. For example, transmission can occur with a bite or scratch that results in an open wound or in other situations where there is contact between an animal’s saliva, cerebral spinal fluid or brain tissue through either an open wound or mucous membranes. All of these situations in which rabies virus transmission to persons could occur must be reported. Animal blood or urine does not serve as a vehicle for the transmission of rabies virus.

An animal’s rabies vaccination status, clinical history, behaviour, and current health status does not preclude the legal requirement for a veterinarian to report a bite or other contact that may result in rabies. As a result, even provoked bites by fully vaccinated animals must be reported under Regulation 557.

Under section 5.2 of the Health of Animals Act, veterinarians are also expected to report animal to animal bites if, in the professional judgement of the veterinarian, one of the animals could potentially have rabies (e.g., demonstrates neurological signs consistent with rabies disease or is a member of a rabies reservoir species) and there is risk of rabies transmission (e.g., fight, significant contact with saliva, mutual grooming). If two animals fight and there is no reason to suspect one of them has rabies, then it does not need to be reported. Animal to animal bites or contact incidents are reported to the Ministry of Agriculture, Food and Rural Affairs when there is reason to suspect rabies. Veterinarians may submit this information to the Ministry through the online rabies response request form, found here.

What should a veterinarian do when an owner/custodian, who requests a rabies vaccine for an animal, indicates that they reported a recent bite or contact incident by that animal to public health? 

If a bite or contact incident has been reported, the Public Health Unit may have ordered the animal to be confined by the owner/custodian. If an animal is under a confinement order, the owner/custodian is violating the order by presenting the animal for rabies vaccination. If a contact incident has been reported to the Public Health Unit, a veterinarian, prior to carrying out the rabies vaccination, should contact the Public Health Unit to confirm whether or not a confinement order has been placed on the animal to be vaccinated. If a confinement order has been issued, the animal should not be vaccinated until the Public Health Unit releases the animal from confinement.

Is a veterinarian required to report a bite or contact incident when an owner/custodian indicates no report was made to the Public Health Unit? 

If a veterinarian determines that a recent bite or contact incident by the animal has not yet been reported by the owner of the animal, the veterinarian must report their knowledge of the bite or contact to the Public Health Unit, as required by Regulation 557.

Are veterinarians required to report incidents when an animal bites a veterinarian or auxiliary staff at a veterinary clinic? 

A veterinarian must follow the same reporting requirements for bites or other contact incidents with animals that could result in the transmission of the rabies virus to a person inclusive of when these incidents occur in a veterinary facility.

When reporting a bite or contact incident to the Public Health Unit, does the veterinarian have to obtain client consent to release medical record information? 

Client consent is not required to release medical record information when doing so is required or authorized by law. This includes release to a Public Health Unit for investigation of a real or potential rabies exposure.

If a veterinarian is contacted by the Public Health Unit about an animal they have treated that is being investigated for a real or potential rabies exposure, the veterinarian does not require client consent to release medical record information about the animal.

When should veterinarians ask questions about biting incidents? 

Asking questions about biting or other contact incidents that occurred within the 10 days preceding a planned rabies vaccination is part of the screening process that is undertaken prior to the administration of a rabies vaccine. This information should be sought whether the planned vaccination is part of a rabies Program or a regular clinic visit.

Veterinarians should also ask questions about biting or other contact incidents that occurred within the 10 days preceding euthanasia of an animal.

What should a veterinarian do when an owner/custodian, who requests euthanasia for an animal, indicates that the animal has been involved in a bite or contact incident? 

A veterinarian must contact their local Public Health Unit as soon as possible to report the bite or contact incident and obtain further instructions. Where an animal is not experiencing pain and suffering, or a veterinarian can alleviate pain and suffering to keep the animal comfortable, the euthanasia procedure should be postponed until instructions are received from the Public Health Unit.

What should a veterinarian do if they cannot reach someone at the Public Health Unit to report a bite or contact incident involving an animal that is suffering and euthanasia is the most humane course of action? 

If a veterinarian determines that euthanasia is the most humane course of action for an animal who has been involved in a bite or contact incident, they may proceed to euthanize the animal. The veterinarian should retain the animal’s body and notify the Public Health Unit as soon as possible as rabies testing may be required.

Administration of Vaccines  

Can a veterinarian delegate rabies immunization to an auxiliary?

Ontario Regulation 567 recognizes that a veterinarian may delegate rabies immunizations to auxiliaries working in or from an accredited facility who are competent to perform the immunization. However, only a veterinarian is permitted to sign a rabies certificate. 

How should a veterinarian proceed when presented with an animal from outside of Ontario?

When presented with an animal from outside of Ontario, a veterinarian should confirm:

1. If a licensed rabies vaccine from Canada or the United States was administered,
2. That the certificate of immunization meets the requirements listed in Ontario Regulation 567, and
3. The reimmunization interval.

Animals vaccinated outside of Canada and the United States require reimmunization for rabies once they arrive in Ontario regardless of certificate or expiry date to be compliant with Ontario Regulation 567.  Valid for dogs, cats, ferrets, horses, cattle, and sheep only.

Can a domestic animal that has bitten a person in the last 14 days be vaccinated?

Do not vaccinate cats or dogs or ferrets that have bitten a person in the last 10 days (14 days for animals other than cats or dogs or ferrets), regardless of the potential that the animal may have been exposed to rabies. Any domestic mammal that has bitten a person must undergo a 10-14 day observation period imposed by Public Health to rule out human exposure to rabies virus. After the 10-14 days, the animal can and should be vaccinated as indicated.

Can an animal owner or breeder purchase the rabies vaccine and administer it to their animal?

Animal owners and breeders cannot purchase rabies vaccines. Section 134.2(1) of the Health of Animals Regulations, CRC 296 expressly prohibits the sale of rabies vaccines to anyone other than a veterinarian. The federal Minister of Agriculture may permit exceptions for remote areas without access to veterinary services or for a temporary emergency veterinary clinic. Normally, permission is granted to remote municipalities and remote First Nations communities rather than individuals or run by provincial wildlife officials.

Can a rabies titre replace a rabies vaccination?

No. Rabies titres cannot serve as proof of an animal’s current vaccination status, and do not meet the legal requirement for vaccination of animals. There are no laboratory tests (i.e. rabies titres) that can be used to establish exemption from the requirement for an up-to-date rabies vaccination status. Exemptions can only be issued on the basis of an animal’s physical condition which would preclude safe (re-)immunization.

 A client has declined to have their pet vaccinated against rabies. Is the veterinarian required to report non-compliance?

Veterinarians do not have a duty to report a client’s non-compliance with having their animal(s) vaccinated against rabies. It is also not a veterinarian’s responsibility to enforce public health regulations. A veterinarian should advise animal owners what the legal requirements for rabies vaccination are within the province of Ontario. Veterinarians can set policies for their own veterinary practices regarding rabies vaccination status of an animal(s) prior to providing veterinary services as a safety measure for their staff. If such a policy is in effect, clients should be made aware of it.

Records 

Under what circumstances can a veterinarian issue a Statement of Exemption? 

Regulation 567 of the Health Protection and Promotion Act enables a veterinarian to issue a Statement of Exemption to the requirement for rabies vaccination under specific conditions. If, based on the history or assessment, a veterinarian determines that the physical condition or history of significant previous adverse vaccine reaction of an animal is such that it cannot be safely (re)immunized, the veterinarian will provide a Statement of Exemption to the owner/custodian of the animal. A copy should be kept in the animal’s medical record for a period of three years from the date of issue.

Can the Certificate of Immunization suffice for the record required under Regulation 1093? 

The Certificate of Immunization may serve as the record if all of the information required under both Regulation 567 and Regulation 1093 is included.

What is the procedure for replacing a lost Certificate of Immunization? 

Regulation 567 requires a veterinarian to retain a copy of the original signed Certificate of Immunization. A veterinarian should retain a paper copy or scanned electronic version of the original in order to provide a true copy of the certificate when asked to provide a replacement certificate. New certificates should not be issued. 

Other Issues 

What animals must be vaccinated in Ontario? 

Under Regulation 567, all dogs, cats, and ferrets three months of age or older must be vaccinated. Every horse, cow, bull, steer, calf, sheep, or other livestock for which a rabies vaccine licensed for use in Canada is available must also be immunized against rabies, unless the animal is accessible only to the person(s) who is responsible for its care and control. The owner/custodian of an animal required to be vaccinated against rabies as listed in the regulation must have either a current Certificate of Vaccination or a current Statement of Exemption issued by a veterinarian for that animal.

Does the Medical Officer of Health have the authority to require a veterinary hospital to confine an animal suspected of rabies? 

Yes. Under Regulation 557 the Medical Officer of Health or a public health inspector has the authority to require a veterinary hospital to confine a cat or dog or ferret for at least 10 days and a horse, cow, bull, steer, calf, sheep, pig, or goat for at least 14 days if the Medical Officer of Health or public health inspector is of the opinion that the animal may be rabid and in their opinion the person caring for the animal is unlikely to confine and isolate the animal.

How is a veterinarian or veterinary facility compensated when the Medical Officer of Health orders an animal to be examined, confined or isolated or destroyed? 

Regulation 557 directs the municipality in which the owner/custodian of the animal resides to compensate a veterinarian for the costs of veterinary services ordered by a Medical Officer of Health or a public health inspector.

Legislative Authority 

Health Protection and Promotion Act, R.S.O. 1990, c H.7, s 96(4)(f)  

R.R.O. 1990, Reg 557, s 2, s 3(1-5) (Health Protection and Promotion Act)  

R.R.O. 1990, Reg 567, s 4-8 (Health Protection and Promotion Act)  

C.R.C., c 296, SRO/91-525, Health of Animals Regulations, s 134.2(1) [Health of Animals Act, (Canada)] 

Resources  

The following sample documents can be found at the College’s website:  

Sample Certificate of Rabies Vaccination 

Sample Statement of Exemption from Rabies Vaccination  

For Additional Information  

For Matters Related to Human Exposure to a Potentially Rabid Animal:  

Contact your local public health unit, or: 

Heather McClinchey, MSc, DVM, MPH 

Veterinary Consultant  

Ministry of Health, Office of Chief Medical Officer of Health, Public Health, Health Protection & Surveillance Policy and Programs Branch 

Email: Heather.McClinchey@ontario.ca  

For Matters Related to Domestic Animal Exposure to a Potentially Rabid Animal, with NO Human Exposure: 

Dr. Maureen Anderson  

Lead Veterinarian 

Animal Health and Welfare, Ontario Ministry of Agriculture, Food and Rural Affairs

Telephone: (226) 971-2994 

Email: maureen.e.c.anderson@ontario.ca  

For Assistance with or to Report a Case of Potential Rabies Exposure in a Domestic Animal:  

Submit a request for assistance online at Rabies Response Request Form.  

If you require assistance with completing the online form due to limited internet access or due to any other accessibility issue, please contact the OMAFRA Agricultural Information Contact Centre at 1- 877-424-1300 (option 1) during business hours (weekdays 8:30 AM - 4:30 PM).  

Animal Health Lab, University of Guelph 

Telephone: (519) 824-4120 ext. 54530 

Website: https://www.uoguelph.ca/ahl  

Local Public Health Units 

https://www.health.gov.on.ca/en/common/system/services/phu/locations.aspx  

_{College publications contain practice parameters and standards which should be considered by all Ontario veterinarians in the care of their patients and in the practice of the profession. College publications are developed in consultation with the profession and describe current professional expectations. It is important to note that these College publications may be used by the College or other bodies in determining whether appropriate standards of practice and professional responsibilities have been maintained. The College encourages you to refer to the website (www.cvo.org) to ensure you are referring to the most recent version of any document.}