September 15, 1997

Invited Comment on Proposed Deregulation of Rabbit Haemorrhagic Disease/Rabbit Calicivirus

To:
Honorable Simon Upton, Minister of Biosecurity
through Karen Joyce, Ministry of Agriculture

Copies to:
Honorable Winston Peters, Deputy Prime Minister
Honorable Nick Smith, Minister for Conservation

AN OPEN LETTER

From:
Professor Alvin W. Smith, Head
Laboratory for Calicivirus Studies

Has the Honorable Minister of Biosecurity and those in Cabinet who advocate legalizing the current illegal spread of RHD considered the following?

1. What is New Zealand's responsibility under international treaties addressing the wanton spread of contagion?

RHD has spread as an epidemic crossing national borders and continents into 40 nations. All have gone to considerable expense first to prevent its' introduction; then, when this failed, to control it's effects or eradicate it. The remaining nations of our global community all have attempted to prevent RHD introduction with the exception of Australia, and now seemingly New Zealand. Both of these nations, Australia through a kangaroo court type legalization and New Zealand by turning a blind eye to the clandestine and criminal introduction of the haemorrhagic agent, followed by Ministry level encouragement for the illegal spread of the disease. The epidemics which advocate groups in both of these countries have wantonly created within their borders has greatly multiplied the probability of haemorrhagic disease spreading to other countries. The greater the environmental burden of RHD the more efficient the spread and diseases are not stopped by, nor do they respect, national boundaries. The "go it alone" and cavalier disregard for responsible global citizenship demonstrated by RHD advocates smacks of a fortress mentality or isolationism that is at odds with the words (now seemingly very empty) of the Federated Farmers Policy Handbook (October 1996) "The achievement and maintenance of a disease-free status for New Zealand animals and plants must be accorded the highest priority by the Government and regulatory agencies in order to protect public health and export markets. The introduction of threatening exotic diseases must be prevented..."

2. Has the legal challenge to existing regulatory safeguards become so perverted and so self-serving that the meanings of the words "safe" and "effective" are to be redefined to mean whatever is useful for some special interest group? Such words surely are not just toys in word games where their meaning and the intent they fostered in the drafting of various animal safety acts and biosecurity acts and regulations is to be stripped away by redefinition. And this to satisfy special interest groups intent on legalizing their own criminal acts and using the established authority of a constitutional government to accomplish this?

Look at the words of the Honorable Simon Upton, Minister of Biosecurity in his 9 September 1997 letter. He states "Cabinet has decided that, given that rabbit calicivirus" (my parentheses - he means Rabbit Haemorrhagic Disease) "is now widely distributed in New Zealand" (my parentheses - he means purposefully and knowingly spread as a criminal act) "it would be desirable to promote responsible, safe, and effective use of the virus." Who could disagree that it would be desirable to promote responsible, safe, and effective use of RHD? But what empty words. There is no amount of "spin" that can overcome a fundamental truth. Simply stated there is no "responsible, safe, and effective use" of RHD when used as a biologic agent and this has a solid base in the scientific information now available. Please examine the three words "responsible" use, "safe" use, and "effective" use on a basis of scientific evidence and facts.

Responsible Use:

This should mean use in a way proven not to be harmful i.e., safe and known to result in common benefit, i.e., beneficial. Lacking this, responsible use should mean NO USE. In New Zealand responsible use has no meaning at all. A raw soup composed of diseased rabbit parts thought to contain a highly contagious virus that kills by causing massive liver failure and hemorrhage is prepared in the kitchens of homes using food processing utensils. This is mixed with nondiscriminate baits such as grains and carrots and broadcast over the country-side, sometimes by air drop. The government now entertains making this a legal and "responsible" act when the origins of the infectious agent are unknown, the content of the mix is unknown, the dosages delivered are unknown, the species being exposed are unknown, the doses needed to infect non-rabbit species are unknown, the contamination of soils and waters and the persistence of the viruses under these conditions are unknown, and the effect on the hated rabbits is even unknown. It is an untested and unapproved method of using RHD even in Australia where it is registered only as an injectable.

Knowing all of this, officials have given "side-door" approval and a "wink" to an outlaw operation within their own nation and now suggest redefining the epitome of "irresponsibility" as legally "responsible." And what about "safety" as a component of "responsible" use?

Safe Use:

Much has been written about this and some hard data is now available. Dr. Novotony just published observations in a prestigious peer-reviewed journal reporting that RHD is not host-specific. This had previously been reported in China. In Australia, eleven of 34 test species receiving token exposure (in comparison to the amount of virus they contact during natural exposure) developed antibody responses ranging in increases of up to 17 fold in just 14 days. The most acceptable and rational explanation is that some were infected but none of these experiments were repeated to confirm this. Why? Isn't it because properly designed and executed experiments would have been virtually certain to confirm infections in at least some of these species? Of most interest here to New Zealand on Page 151 of the Import Application we see written this statement: "The development of antibodies by the Kiwi parallels results from other species tested in Australia suggesting that birds in general are more likely to produce antibodies to RCD antigen than are mammals." If one breaks this "science-babble" code it simply means "we think birds are more susceptible to RHD infection than non-rabbit mammals." Specifically, this is because antibody response in birds to only 180,000 molecules of virus capsid protein that is, the 1,000 rabbit lethal dose administered (180 molecules/virus, i.e., 1,000 infective virions) would be likely to occur only if the virus infected the birds and multiplied. This would increase the number of protein molecules, thereby subjecting birds to much higher doses and causing an antibody response. New Zealand with her avian treasury of unique species will surely be especially sensitive to this compelling piece of evidence. Don't forget that at AAHL, RHD was transmitted to a sentinel rabbit in a test cage housing birds experimentally infected with RHD.

There are also anecdotal accounts of RHD having spread to other species but these have not been properly investigated. In a display animal show in Western Australia, rabbits died of RHD and at the same time the guinea pigs also died with signs of bleeding. There have been numerous reports of crashing populations of birds of prey, as well as cat and fox populations in RHD infected areas. In Tasmania, concurrent with RHD passing through an area, an entire colony of bandicoots disappeared.

Safety regarding human infection is even more troubling. The available data has been re-examined in various ways and continues to show increased illnesses associated with RHD exposure. Furthermore, in Mexico, one exposed worker developed antibodies (most likely the result of infection), 4 of 5 calicivirus groups are now known to cause disease in humans, and the official language has changed from "RHD will not affect humans" to "the risk of human infection is low." We are never told what "low" means. Is it one in hundreds, thousands, or millions? Scientist will affirm that when a person becomes infected, the progeny virus shed by that person will be much better adapted to a new human host. Therefore, once an event in a new host occurs, the law of odds for the virus to infect others of the same species shift by quantum leaps. These are the scientific facts and the genesis of virtually every new epidemic. Political positioning may result in some decision makers disregarding them, but the facts don't change and don't go away. Now, what about "responsible" use as it relates to effective use?

Effective Use:

One of the requirements for any biological product registration is proof of efficacy. There are now many documented accounts of RHD failure to control or reduce rabbit numbers in Australia even on it's initial spread. In other words, it's effect is less reliable than most critics of the program predicted. So much so that the chief proponent in Australia, Brian Cooke, was reported in the New Zealand press as openly admitting to Dr. O'Hara that he will not recommend further spread in Australia ostensibly because of poor performance. But, one must also be aware that the likelihood of RHD spread to non-rabbit species is quite high and knowledge of such events having taken place could also cool Dr. Cooke's enthusiasm for further spread of the biologic agent he has advocated for rabbit control.

In New Zealand, we hear rumors of weeks of spreading the disease and of lacing 1080 treated carrots with RHD where kill rates could appear quite high from the 1080 effect alone. In short, the effectiveness of the RHD approach to rabbit control is completely unreliable.

Therefore, when a product is unreliable for the intended effect, and shown by existing research evidence to not be safe, how does the New Zealand Government Cabinet "promote responsible, safe, and effective use of the virus?"

To return to the direct quote of the Minister of Biosecurity, he continues "people will not be forthcoming with information if they feel they are under legal threat. There needs to be a good flow of reliable information." There are several observations here. Information on the human health threat could only be obtained through the Freedom of Information Act. Additional bits of that data are still being withheld. The people were deceived regarding the result and meaning of the evidence for cross-species transmission and human health risk. There has been no in-depth attempt to trace natural exposure resulting in probable infection in either animals or people. The diagnostic tools for doing the needed epidemiologic work-ups on non-rabbits and human exposures are very unreliable, but still are not being routinely used to document unwanted effects. All of this, plus the disease itself is unreliable.

Shouldn't we all be asking why the Honorable Minster of Biosecurity feels the need for "a good flow of reliable information" when he has disregarded a huge flow of reliable information simply because it does not support his pre-determined position?

RHD should not be legalized. Authorities in New Zealand should not be stampeded into believing RHD is reliable or even effective as a biologic agent where it's lethal effect may be purposefully confused with that of 1080 simply to cover-up poor performances. Furthermore, if the criminals (is that the right word for those who purposefully break the laws of the land?) who have spread and continue to brag of spreading the disease are stopped, and if the MAF would initiate intense control efforts, there is still a chance that RHD could be controlled or eradicated in New Zealand.

As an outsider, I can only watch with much sorrow and in utter amazement as this crumbling of law and order takes place in a country that loves law and order even more than my own. And I can only pray that somehow truth and honor will prevail, that your carefully crafted laws will be upheld, and those in the government and in the country-side who have grabbed control to institute policies based on utter ignorance and personal greed will be accorded their just rewards.

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