How will the new Vaccine Protocol affect Pets and their Owner:
PACFA (Pet Animal Care and Facilities Act) is a regulation system for animal facilities to ensure proper care and sanitation of animals for groomers, daycare/boarding, any facility that sells pets, and more. It creates a standard that all pet facilities must follow and every year each facility gets renewed for the license as well as randomly inspected.
PACFA has announced that they are proposing changes to their vaccine mandate; if these changes are approved, they will be announced in March of this year. Many professionals in the pet industry (groomers, Trainers, Pet Advocates and Daycare/Boarding)] do not want the vaccine mandate that PACFA is currently proposing, and believe it is overstepping their jurisdiction as a regulatory body.
The new mandate will require all grooming, daycare, boarding facilities to monitor our clients vaccine records.These facilities must have a copy in file that show the pet is up to date in order for us to provide service. Veterinarians only need to have proof of Rabies, all other shots are not considered mandatory. All pets must be up to date on Rabies, Bordetella, Parvo, and Distemper. The client must either bring a hard copy or email a copy of this information, or a signed note from a Veterinarian declaring an exemption from any vaccine.
We want to educate our clients about what could change in the near future, and ask them to support us in maintaining their rights to chose a vaccine plan that works for their pets.
Below is an attached statement from a local Colorado veterinarian, as well as a statement from a local pet daycare and boarding facility. Both give education on the vaccines as well as the lack of information given in the mandate. Names have been redacted to protect identities.
Letter from a Colorado Veterinarian:
To Whom It May Concern,
2/8/2025
I would like to address 19.5.3 of PACFA's proposed changes. I understand the proposed rule's basic premise, but I feel it is an overstepping requirement. Every business assumes a certain amount of risk, but it should be up to the individual businesses to make those decisions not something that should be legislated.
Some thoughts to consider:
1) Rabies is the only vaccine required by law, so you are setting different rules for groomers and boarding facilities than you are for dog parks, rescue organizations, or even veterinarians.
2) What is considered a valid vaccine? Can the breeder or the individual owner administer it? Do you have a specific protocol to be considered up to date? Is that yearly or every 3 years? If it is mail-order, would a layperson know the length of time the vaccine is licensed for?
3) Does the type of vaccine make a difference? Or are the mail order vaccines acceptable? Are lay people knowledgeable enough to determine?
4) What documentation will be considered (see #2)?
5) The veterinarian community does not consider Bordetella a core vaccine, so why would it be required? Would up-to-date mean yearly or every six months? Would an intranasal and injectable vaccine both be acceptable?
6) Vaccination does not replace common sense, good cleaning, and appropriate isolation techniques. Education would be a better use of time.
7) The rule does not address those individuals who prefer to rely on titers versus vaccines. This is not always due to risk to the animal but often a matter of choice. It would go against the general consensus in the veterinarian community that titers are a viable option.
8 ) Isolation in most grooming salons is often limited to non-existing. If they specialize in older, non-vaccinated dogs (which are very low risk for disease based on age), the groomers's ability to service the clients would be limited.
9) Considering the incubation times of most of these diseases, you would have to consider a waiting period after the vaccine to reasonably apply the rule for the true safety of the pets. This would be greatly limiting in training for young puppies, considering they are not fully vaccinated until 16 weeks of age.
10) Many grooming (mobile and house call) and training facilities only deal with one dog at a time and are at a very low risk of needing a strict vaccination policy. A cleaning protocol would be much more appropriate. I am a firm believer that every groomer, boarding facility, and training business should have a vaccine policy to protect themselves, but I do not feel it should be legislated. If nothing else, give the facilities a higher rating if they have a good policy or records but do not require it of all the facilities (similar to how AAHA handles their inspections). The overall risk is low if the animals are being screened as they come in, and the vaccines do not guarantee that an outbreak may not occur.
A letter from Julie McLean, the owner of Zen Doggy Den
“As a pet care facility owner with over 17 years of industry experience, I feel compelled to address the Department of Agriculture's proposed PACFA regulations regarding mandatory vaccinations for dogs in grooming, daycare, and boarding facilities. While the intention behind these regulations may be to protect pet health, the proposed mandates raise significant concerns about business autonomy, effective health management approaches, and most importantly, the welfare of pets and their families.
## The Real Impact on Pet Owners and Their Dogs
The proposed mandates would have far-reaching consequences that extend beyond simple regulatory compliance. Many pet owners would face difficult, even impossible, choices:
- Dogs with medical conditions that prevent vaccination would be barred from professional grooming and socialization services
- Pets would be forced to leave trusted care providers they've known for years
- Families would lose access to their preferred professional pet care services
- Dogs with vaccination sensitivities or health issues would face social isolation due to being banned from group settings
- Pet owners would be stripped of their right to make informed medical decisions for their pets in consultation with their veterinarians
## Unintended Consequences
Perhaps most concerning is how these mandates could drive pet owners toward less regulated alternatives:
- Families may feel forced to seek unlicensed, home-based pet care options
- These unofficial providers operate outside PACFA's oversight and aren't subject to any safety standards or facility inspections
- The very regulations intended to protect pets could push them into potentially riskier situations
- The loss of professional oversight could lead to decreased overall safety in the pet care industry
## Current Landscape vs. Proposed Changes
Currently, facility owners have the discretion to set their own vaccination requirements based on their experience, knowledge, and specific facility needs. Many already require vaccinations like rabies, distemper/parvo, and bordetella. The proposed mandate would remove this decision-making ability from business owners, standardizing requirements across all facilities regardless of their unique circumstances or approaches to pet health.
## Experience-Based Insights
My journey in the pet care industry has provided valuable insights into vaccination effectiveness and facility health management. When choosing to open my facility in Colorado, one of the key factors was the state's respect for pet owners' and business owners' autonomy in making health-related decisions. This freedom allows us to implement evidence-based policies that work best for our specific environment and clientele.
## The Bordetella Example
The bordetella vaccine provides an excellent case study for why blanket mandates may not achieve their intended outcomes. Through my work with holistic veterinarians and years of industry observation, I've learned several key points about this particular vaccine:
- Effectiveness rates are notably low
- Many vaccinated dogs still contract the illness
- Some facilities have reported increased bordetella rates after implementing mandatory vaccination policies
- The virus is constantly evolving, making vaccine efficacy unpredictable
## Our Current Approach
At my facility, we've developed a balanced and flexible approach that prioritizes both health and choice:
- We don't require the bordetella vaccine
- We accept titer testing for immunity verification
- We honor vaccine exemptions from licensed veterinarians
- We empower clients to make informed decisions about their pets' health
## Why Choice Matters
The current system of allowing business owners to set their own vaccination policies works because:
1. It enables facilities to adapt their requirements based on their specific circumstances and experience
2. It allows for diverse approaches to pet health management
3. It respects the varying needs and health situations of individual pets
4. It maintains the crucial relationship between pet owners, veterinarians, and care facilities
5. It preserves the bond between pets and their trusted care providers
## Moving Forward
While pet health and safety should always be our industry's primary concern, mandating specific medical procedures across all facilities may not be the most effective approach. Instead, we should focus on:
- Supporting informed decision-making by pet owners and facility operators
- Maintaining flexibility in health management approaches
- Encouraging ongoing education about pet health and disease prevention
- Preserving the autonomy of business owners to implement effective policies for their specific circumstances
- Protecting the right of pet owners to make medical decisions in partnership with their veterinarians
The proposed PACFA mandates, while well-intentioned, represent an overreach that could potentially harm the very pets they aim to protect. By forcing owners away from regulated facilities and removing their ability to make informed medical choices for their pets, these mandates could create more problems than they solve. We must carefully consider whether standardizing these requirements across all facilities truly serves the best interests of our pets, their families, and the industry as a whole.
-Julie McLean
Certified Master Dog Trainer
Owner of Zen Doggy Den”
If you would like to sign the petition to leave vaccinations up to the pet owners and their vets,
Sign the petition below
Pet Owners Petition:
https://www.change.org/petownersagainstvaccinemandate
Groomers and Pet Facility Owners: