This article was originally printed in the March/April 2025 issue of the California Veterinarian magazine.

California Health and Safety Code section 121690(b) requires dog owners to obtain a rabies vaccination for dogs between three and four months of age, and then in accordance with the vaccine label instructions thereafter, unless granted an exemption by local rabies health authorities.

In addition, California Health and Safety Code section 121700 requires that rabies vaccinations be sold only to veterinarians. By limiting the sale of rabies vaccinations to veterinarians, the law ensures a method of tracking rabies prophylactic activities for public health purposes. Because of these two laws, many assume that only veterinarians may administer rabies vaccinations and sign rabies vaccination certificates. However, this is not the case.

In California veterinary practices, registered veterinary technicians (RVTs) and veterinary assistants also may administer rabies vaccinations provided that certain requirements are met, and sign certificates as a  designee of the veterinarian.

Administering the Rabies Vaccine

California Code of Regulations (CCR), Title 16, Sections 2034, 2036, and 2036.5 outline the supervisory requirements of veterinarians as well as the tasks that can be performed by RVTs and veterinary assistants in a veterinary practice setting.

Administering vaccinations falls within a broad class of work functions called “auxiliary health care tasks.” The law allows these defined tasks to be performed by paraprofessional staff provided that some degree of supervision is provided. In specific relation to administering rabies vaccinations, the California Veterinary Medical Board (CVMB) states the following:

“A California licensed veterinarian can administer the rabies vaccine or can delegate the administration of the rabies vaccine, to either a Registered Veterinary Technician (RVT) or veterinary assistant. A RVT and/or veterinary assistant can administer the rabies vaccination under either direct or indirect supervision of the California licensed veterinarian.”

Ultimate responsibility for the administration of rabies vaccinations falls to the supervising veterinarian. The California Department of Public Health (CDPH) is the final authority in rabies laws and regulations.

According to the CDPH: “The veterinarian whose signature is on the rabies certificate retains legal responsibility that the person administering the vaccine is appropriately trained in vaccine storage, handling, administration, and management of adverse events. Rabies vaccines should be administered in accordance with the specifications of the vaccine product label or package insert.”

It is incumbent upon the veterinarian to first establish a Veterinarian-Client Patient Relationship (VCPR) for the purpose of administering the rabies vaccine prior to delegating the task to an RVT or veterinary assistant. Provided that the VCPR requirement is met, the task of vaccinating animals for rabies can be delegated to staff under supervision.

Rabies Vaccination Certificates
According to CCR Title 17, Section 2606.4, dog owners must have an official rabies vaccination certificate in order to obtain a rabies registration tag. Official rabies vaccination certificates must include:

a. the name, address, and telephone number of the dog’s owner;
b. the description of the dog, including breed, color, age, and sex;
c. the date of immunization;
d. the type of rabies vaccine administered;
e. the name of the manufacturer; and
f. the lot number of the vaccine used.
g. The rabies vaccine certificate must be signed with either the signature of the veterinarian who administers the vaccine, or with a signature authorized by the veterinarian. The vaccination certificate must include the veterinarian’s printed name, address, and telephone number.

A sample rabies vaccination certificate that meets specified requirements can be accessed at nasphv.org/Documents/ RabiesVacCert.pdf or by scanning the QR code.

For more information on rabies vaccination, visit cvma-watchdog.net and access “Rabies Information” under the Regulatory Compliance Resources section.