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Our Letter To APHIS, August 2001
 August 27, 2001
Kimberley M. Smith
United States Department of Agriculture
Animal Plant Health Inspection Service
Veterinary Services, Emergency Programs
4700 River Road, Unit 41
Riverdale, MD 20737-1231
Dear Ms. Smith,
Thank you for offering to answer our questions. The following questions outline our concerns.
How was the change Dr. Crom advised us of, deeming Rabbits to have livestock status, arrived at? We were told repeatedly last year that this was not the case. In fact as late as March of 2001 USDA officials advised the Coalition that the status of Rabbits was not livestock. We would not question this decision if we felt it was one made for the sake of expediency in light of the desire to curtail the current outbreak. What leads to the concern is the definition of the title given to the notices APHIS has sent out, Emergency Management Warning. This being defined as an "ongoing incident with almost certain impact on APHIS." Unless Rabbits continue to be considered livestock, we do not see an impact on APHIS.
In a recent comment an APHIS stated "we believe that the combination of detergent and regular amount of bleach in a load of laundry would be sufficient to kill the virus." What research has been conducted to prove this theory?
In the first warning a statement was made "All trace outs from the initial Utah premises are complete." Does this include wildlife that may have come in contact with the infected Rabbits, ie, mice? Was contact with other humans who themselves may or may not be Rabbit caretakers charted? Will they all be contacted and advised to disinfect materials that have come in contact with the virus? Has the USDA decided that Rabbit to Rabbit contact is the only relevant contact to be considered when attempting to halt spreading the virus?
What steps are being taken to ascertain the source? Have samples been sent again to Dr. Cappuci to determine the strain? If not is such planned? Considering the brick wall that was reached during the last "outbreak," will you consider sending it to other labs for a more precise end result? If an outbreak of FMD, (Foot and Mouth Disease), were to occur, we seriously doubt APHIS would accept an unknown source so easily.
Have any steps been taken to insure that Rabbit Feed remains safe? Many feeds use bone meal. Do we know, through research, that all bone meal, or other animal products, used in feeds is safe? We would normally assume that the feed is so thoroughly heated that the virus would not survive. Some feeds also contain digestive enzymes that would have no value if heated. The use of cattle feed containing any products derived from cattle has been banned in the U.S. to protect U.S. livestock from BSE, (Bovine Spongiform Encephalopathy). Should such precautions not be taken in regards to Rabbit feed as well? If not, what research can you cite to support your position?
Why is APHIS failing to close our borders to Rabbits and or Rabbit products from countries that are known to be infected? We were told several times, the last comment in March, 2001, that the USDA has no jurisdiction over Rabbit imports. If that is the case should not the FDA be involved in ascertaining the safety of imports? Please note that we understand that the FDA is concerned with Human Health issues. We are also aware that the USDA, the FDA and the CDC all work together regarding West Nile Virus. Your website has celebrated this. Please further note that we understand that RHD is not globally recognized as a zoonotic disease. To accept the hypothesis that it is not, we would need to see valid scientific research validating such a theory.
There is, in fact, evidence to the contrary
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. I have heard the arguments from Plum Island scientists, one's Dr. Cappuci mirrored, that no laboratory workers have shown signs of infection. Laboratory settings are very sterile, carefully controlled environments. No one has conducted studies focusing on the workers who create vaccines. These workers infect a number of Rabbits by filling their environment with the virus and then collect the dead bodies, both processes highly expose them to the virus. Has any research charted their health? The only assay those who argue against zoonosis seem to accept as relevant is dead bodies.
In mentioning the above, we would also like to know if humans who were in contact with the Rabbits tested? During the conference call, held last year, we asked the same question. The answer given was that all that such tests might find is the presence of Norwalk viruses. We do not know if this statement was founded in ignorance or an expectation that we were ignorant. In an attempt to clarify this, I spoke with Dr. Oliver Williams in August of 2000. He informed me that if indeed the tests revealed antibodies to Caliciviruses , it would not be possible to determine if they were in fact antibodies to RHD as opposed to other Caliciviruses. Does the Emergency Operations staff have access to educational materials regarding monoclonal antibody tests? We would be glad to provide such. Monoclonal Antibody testing would assist in determining the specific member of the Caliciviridae family found. (Please note, the Coalition was wrong in regards to the availability of Monoclonal Anitbody Tests in relationship to RHD and Norwalk Viruses. An admission of the mistake and an apology was offered in October, 2001 in an Update)
The absence of specific symptoms does not guarantee a lack of infection. A Mexican worker developed antibodies to RHD in the eradication efforts in Mexico
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. Other Caliciviruses once thought not to be zoonotic have gone on to cause infection and disease symptoms in humans
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. Caliciviruses have created long term clinical illness in primates
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. Norwalk viruses, the Caliciviruses accepted as a human infective agent, have been linked to caliciviruses known to infect other species
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. It is possible to sight a multitude of research papers that indicate the cross species infective potential of this family of viruses. As well as papers citing the propensity for changing disease symptoms. Much of this comes from the USDA's own research. Ignoring that potential in RHD, the deadliest virus on the planet, is playing a fools game. At this point the Rabbit Community is willing, in large part, to ignore the implications of the research that has been done due to a lack of knowledge of such research. Please note that will not long be the case. We are educating the public. We, and others, are calling for more in depth research by agencies other than your own. The cross species infectivity potential and reality of Caliciviruses in total has been available for at least a decade, some of it your own.
Which brings up the question of why Caliciviruses that are endemic in US livestock are ignored
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? This becomes a great concern because the origin of RHD has never been determined. Yes we know it started in China. But How? Why? We also know that here in the U.S. Caliciviruses have been isolated in Rabbits along with Parvoviruses
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. RHD could easily have been created by a combination of the two viruses
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. If RHD started in China because both viruses were present in the first infected Rabbits environment, should we not be concerned that both are present in the US?
Is the USDA willing to speak out against the deliberate release of RHD in baits in Australia? We realize that Australia represents an important trade entity as part of the Pacific Rim trading countries. And in light of the threat posed to our economy by the European Union, harming this trade relationship through unfriendly comments may not be a desired course of action. But enough is enough. How does the USDA justify ignoring the release of this deadly virus all other countries on the planet have emphatically sought to eradicate? Perhaps it will be claimed that we are not in the habit of interfering with the agricultural policies of other nations. This would have been an acceptable statement prior to the FMD outbreak in Europe. The USDA has its finger in many agricultural concerns across the globe. Why not this one?
At the conclusion of the initial outbreak, APHIS officials requested policy recommendations from the Rabbit community. No response was offered. How were the individual recommendations viewed by the agency? Were any found to be compatible with APHIS policy? Which recommendations were not acceptable? Have any of those recommendations been adopted as goals of the USDA?
Once sorted through, the acts accepted as compatible with APHIS policy requested through the policy recommendations would require legislation and funding. Has any thought been given to the type of legislation and the amount of necessary appropriations?
The above question calls to mind the fact that several questions were sent to Barbara Bischoff prior to the conference call that was held. Ms. Bischoff was asked for answers to those questions twice. The first time we were told we would have the answers prior to the conference call. They were not provided. We were eventually told that there was no funding available to provide the answers to those questions. Is there some time line we could use to ascertain when the brick walls will be put in place? Is there a dollar amount attached to providing the answers to each individual question? Are all Rabbit interest groups given a certain allotment?
During the initial outbreak, Dr. Chris Hayhow of ARBA was informed by phone of the occurrence of RHD in Iowa at least 24 hours before any other Rabbit interest groups were notified. This appears to have happened again. Has Dr. Hayhow made special arrangements with APHIS that other groups are not eligible for?
For years ARBA's official statements, regarding the elimination of RHD from the US in the case of an outbreak, centered on cooperation with eradication. In the first statement released, announcing the Iowa "outbreak," Dr. Hayhow stated that he would be holding a conference call with USDA that Friday regarding the possibility of vaccines being made available. In that Dr. Hayhow has refused to communicate with other Rabbit groups, works for a private company that manufactures vaccines, has served on USDA committees set up to rewrite the codes that govern the use of vaccines, we would like to know if there is in fact some "inside" workings that are guiding the Rabbit community towards what would be normally considered an early use of vaccines? Did the conversation he foretold take place and what were the results?
In June of 2000 on Promed Mail, Dr. Torres was quoted as saying that the Iowa outbreak may have originated from a source in Mexico. Was this a mis quote?
In the same quote, Dr. Torres spoke of the dangers that RHD posed to other animals as laboratory Rabbits may not be available for use in the creation of vaccines. We also know that interest groups concerned with supplying Rabbits for use in laboratories have actively sought congressional support for changing the status of Rabbits to livestock so as to insure protection from FAD, (Foreign Animal Disease). Is the USDA seeking such status for Rabbits, in part, because of these efforts?
The Iowa incident and the latest outbreak seem to have involved either breeders or caretakers with a limited interest in the longevity of the Rabbits that were exposed. Thousands of potentially healthy Rabbits were euthanized this time. Does APHIS understand that should an outbreak occur within the rescue community, in an environment created for companion or pet Rabbits, or among many of the small breeders who breed exclusively for pet or show, that such a blanket kill would be unacceptable? The Coalition could not support such an action and would seek intervention through the courts. Though the science of eradication as a first line defense is sound, and one that we have supported, it is not an effective defense if not utilized in conjunction with other measures. RHD has existed for seventeen years and the save the efforts in Mexico, the USDA has done nothing to stop it from entering our country. Even after promises to undertake educational efforts, little has been done. In a letter to this author received on March of 2001, Acting Director Farouk Hamdy claimed that the USDA had provided information for us to include on our websites. Considering the scope of information included on our website, as well as the fact that such was in place before the Iowa incident, the information you have provided for the internet could easily have been derived from information we provided. As far as on site education, the only effort has been Barbara Bischoff's attendance at the ARBA convention. This seems like an incredible waste of effort. There are many Veterinarians within the ARBA membership which could have provided the same information. This was an obvious public relations effort. If APHIS truly wanted to educate the masses, Veterinarian Conferences, Humane Organization's Conferences and 4H or Future Farmers Conferences would have gone a lot farther. Have any of the multitude of Vets working for APHIS written articles for the Journal of Veterinarian Medicine, AVMA's publications or the like? Have travelers to RHD infected countries been advised of the danger? Once again we ask, have safeguards been placed at the borders? If APHIS is unwilling to pursue efforts such as this, the agency cannot expect us to hand healthy Rabbits over to it should another outbreak occur. The public would not expect Dog or Cat caretakers to do so. What are your plans in the case of such an occurrence? Will this mean that a vaccine will be made available? Unlike the recent eradication of the herd of Sheep in Vermont who were suspected of carrying TSE, we have medical remedies available.
Finally, after calling the agency for answers regarding policy and being turned over to a Public Relations person, we are aware that we are to be handled. Does the agency, after reading this letter, understand that we are not writing so that we can be handled? We are here to protect Rabbit from RHD. Does APHIS still want to work with us to do so? If so, what does APHIS want to do?
We look forward to your reply.
Thank you,
diane of The Sanctuary
"
I am the voice of the voiceless;
Through me the dumb shall speak, Till the deaf world's ear be made to hear
The wrongs of the wordless weak.
And I am my brother's keeper;
And I will fight his fight;
And speak the word for the beast and bird
Till the world sets things right."
--Ella Wheeler Wilcox, 1850-1919
  
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