December 16, 1996

To:
The Right Honorable J. Bolger
Prime Minister
New Zealand
Fax 64-4-473-7045

The Honorable Winston Peters
Deputy Prime Minister
New Zealand
Fax 64-4-499-4809

Copies To:
Dr. Gilliam Durham
Director of Public Health
New Zealand
Fax 644-496-2340

Dear Prime Minister:

I write to you with a sense of urgency that has overcome my personal preference to stay with science and avoid political controversy.

The subject is Rabbit Hemorrhagic Disease (RCD in Australia). Even though efforts to import this sometimes deadly disease into New Zealand have the facade of "due process", from my vantage point it appears that the program has become fixated on how to use or misuse "science" to manipulate the public including the farmers, the media, and the decision makers, to orchestrate RHD approval. The scientific evidence provides documentation removing all doubt that spreading this sometimes deadly and always unpredictable disease agent for biological control is a risky and foolish thing to do. Unfortunately, this evidence which is so necessary for sound responsible decision making has been discounted, or covered up. Much documentation of this is appended and more information is provided in the submissions of others to the MAF. Specifically, please see the submissions of Professor Yvonne van Roy, Victoria University, Commercial Law Group; Dr. Neil Cherry, Lincoln University; and Dr. David Matson, Center for Pediatric Research in the U.S.

As a scientist, I am ever hopeful that when scientific data is used as evidence for important decision making, then that data will be presented in a balanced, clear and revealing way. This has not been the case with the special interest groups promoting the importation and use of Rabbit Hemorrhagic Disease.

The following points demonstrate this and show the possible dangers of Rabbit Hemorrhagic Disease while reaffirming that New Zealand has a God-given opportunity to benefit by observing rather than participating in the massive uncontrolled and uncontrollable biological experiment which is now coming unraveled at all levels across the Australian continent. Again, from my vantage point, the leadership of New Zealand has an obligation to insure that the people of your beautiful land do not come under the same sword of Damocles that RHD has placed over the Australians.

1. Human Health Aspects: The applicant groups promoting RHD importation into New Zealand cite lack of information from 41 countries where Rabbit Hemorrhagic Disease is present and allude to this as data supporting a supposition of no human infection. Such data simply does not exist. There have been reports on but two studies that attempt to test a link between Rabbit Hemorrhagic Disease, human infection and human health issues. One in Mexico and one in Australia. In Mexico, individuals exposed to Rabbit Hemorrhagic Disease were examined and one individual was reported to have developed RHD antibodies but clinical illness was not reported. This provided laboratory evidence but not proof of human RHD infection. In Australia, the human health status and RHD antibody levels were compared between groups exposed to RHD and those not exposed. The Australian report released for general information and sent on to New Zealand stated there was no evidence of adverse human health effects and no antibody to RHD in the human population. If this statement contains errors, and it almost certainly does, then the moral/legal implications for science, science reporting, and political expedience become very troubling.

By making a simple comparison based on person-months for people exposed to RHD versus people not exposed to RHD, as one of your New Zealand environmental epidemiologists (Dr. Neil Cherry) has done using the Australian data, the RHD exposed human population was shown to have a numerical but not a statistically significant increase in reported bouts of hepatitis, skin disease, and bleeding disorders. But, the more disturbing by far was a finding showing that at a statistically highly significant level (0.001), the people exposed to RHD reported increased diarrhea and vomiting, influenza-like illness and neurologic symptoms. It is known that all of these conditions can be caused by infections with various caliciviruses in either humans and/or animals. In other words, by rightly interpreting data from the most extensive study to date, RHD was shown to have a statistically significant human health effect, where overall illness was three times higher in people exposed to RHD. This means according to the Australian's own data that there is a 99.9% chance that RHD is infecting Australians and is causing clinical illness. Meanwhile, the pro-RHD groups in Australia and the RCD Import Application claims on page 51 that this same study using these same data shows "no scientific evidence that rabbit calicivirus" (isn't this the same as RHD/RCD virus?) "infects humans or poses any risk to human health." The Australian groups further state that it is safe for people and pets to eat RCD infected rabbits. Something is very wrong here and the stakes are very high in terms of human health risk and societal well-being.

The results of the blood tests on these same individuals were reported by Dr. Westbury's Laboratory (AAHL) as negative yet the method used to arrive at this finding according to the Australian August 1996 Bureau of Resource Sciences report required that up to 50% of the antibody reactivity be regarded as non-specific. Only then could the test results be called negative. This is juggling the assay method to arrive at a desired result.

Furthermore, as of this writing, the laboratory values from the blood tests have not been made available to your own New Zealand Ministry of Health. There have been repeated attempts to draw these results into the public arena both in Australia and New Zealand, but without success. Surely before any valid decision can be made regarding RHD import, these test results must be made public and the purposes for this seemingly clandestine withholding of data involving human health and what appears to be the intentional misrepresentation of statistically validated occurrences of human illness in people exposed to RHD must be completely illuminated.

2. Changes in RHD: The Victoria Weekly Times confirmed in their 27 November issue that in some places in the Australian countryside, although RHD had been present, rabbit numbers have increased rather than decreased. It is not known whether this increase is due to reduced predation because of 1080 baiting of foxes, caliciviruses killing predators, or other effects such as RHD losing its' rabbit killing factors, or mutant non-lethal RHD variants providing RHD resistance as is documented in the United Kingdom and Europe, or simply unknown and unpredictable transmission factors. What is known is that now in some areas increasing rabbit populations are higher than the pre-RHD levels. Several incidents demonstrate that the Australian experiment has gone awry. In Victoria, at Woady Yallock, a) the farmers are blaming failure of the program on the Department, b) the Department places failure on the farmers baiting practices, c) laboratory results on blood samples were reported four weeks late and showed that RHD had already gone undetected through areas before RHD was released, d) the farmer representative, Mr. Justin Liddy, was quoted as saying there was a "high increase" in rabbit numbers not a decrease, e) the Agriculture Departments' RCD Program Coordinator Steve Burke is reported to be explaining the failures of RHD by saying "it is not a stand-alone rabbit control mechanism," and "there had been a lot of variations in the results", and f) an incredible quote from a CSIRO/ANZRCD Program chief spokesman, Niall Byrne, who has presented the RCD program as the ultimate safe and effective solution now stating "there are so many factors with the virus that no one can guarantee a kill". What happened to the promised 90-95% kill rates?

One year after RHD was discovered 250 km inland in the Flinders Ranges where it appeared simultaneously with the reported escape or release from the Wardang quarantine facility, the rabbits are reported to be "coming back". And now since RHD was introduced in Western Australia, rabbit shooters are reporting to members of the RSPCA that the rabbit numbers are higher than ever, and farmers have told the WA Conservation of Raptors that they do not want RHD on their property and that rabbit numbers have not decreased since RHD introduction.

Brian Cooke, the zoologist who imported into Australia the Spanish flea, which he says is species specific (only bites and feeds on rabbits would be the desired interpretation) but which is reported in his own laboratory studies to bite, feed, and reproduce on non-rabbit species, is also the principal investigator credited with the RHD concept for Australia. He is now testing rabbit populations and suggested in a recent ABC interview that as the rabbits' antibody levels against RHD diminish, then there may be a second opportunity to kill them with RHD. The tests he is using are not virus neutralizing antibody tests for RHD and therefore are not proven on a case-by-case basis to be predictive of finite levels of either susceptibility or resistance. The nationwide Australian experiment has now proven RHD to be unreliable in spreading and killing rabbit populations that have never before been exposed to RHD. How effective, how expensive, and how dangerous will these 2nd, 3rd, 4th, or 5th rounds of spreading RHD be considering the manpower, laboratory support, and most importantly, the unpredictable nature of the disease?

The current tests lack sensitivity (0.3 - 0.5 level for the indirect ELISA and 30-50% inhibition for the competitive ELISA), and are therefore simply inadequate for reliable epidemiologic studies of rabbits, humans or any other species, yet in Australia all these species are being exposed to RHD with unknown and untestable results. More sensitive ways of tracking RHD exposure, spread, and infections in all species even in the absence of frank disease must be developed. Simply judging RHD presence on the basis of a populations' disappearance or illness and dead body counts is not acceptable.

In light of all the RHD program failures, controversies, and unpredictable virus behavior, Dr. Harvey Westbury, who heads the Australian Animal Health Laboratory at Geelong where the scientific studies on RHD transmission, diagnostic reagent development, host specificity and human antibody were carried out, now states in his E-mail message of 11 November 1996 "we are not doing any more work with RCD, indeed our RCD team has been disbanded....". For whatever reason and by edict of whomever controls these things, he says his laboratory at AAHL is no longer working on RHD. This is unbelievable.

In Australia, an uncontrollable, entirely unpredictable, often deadly, but sometimes silent virus has been introduced and purposefully spread across an entire continent. RHD's origins in China a decade ago remain unexplained. RHD's mechanisms and genetic make-up resulting in a rapid and bloody death are not known. RHD's mode of transmission, across open bodies of water and between continents has not been revealed nor have the reasons for RHD's frequent failure to transmit between rabbits inside experimental pens been determined. RHD's host range is undefined and can be expected to change constantly and unexpectedly. Compelling evidence demonstrates human health effects. Diagnostic reagents currently in use are worthless for detailed tracking of RHD and doing reliable epidemiology on all species at risk, including humans. There are no vaccines for any of these species at risk except for rabbits and these vaccines are crude, ground-up diseased rabbit-liver preparations. The RHD agent has not even been propagated in laboratory cell cultures, and the disease has not been proven, using accepted research methods (Kochs' postulates), to be caused by a calicivirus alone, yet Dr. Harvey Westbury, the chief research virologist who has been involved in studying RHD and declaring it safe and efficacious for killing rabbits, tells us that his program has been disbanded by Australia and he is no longer working on the disease. Does New Zealand really want to buy into this Pandoras' Box where the benefits have been greatly misrepresented and oversold and the dangers simply brushed aside.

3. Secret Expert Panel Report: I understand that the New Zealand MAF used a panel of experts to evaluate the RHD import application, then when these experts' names and some of their less than favorable evaluations were forced to be made public, through the Freedom of Information laws, MAF disbanded this panel, disregarded their findings, and appointed another confidential or secret panel, three whose names have now also become public. It appears that not one of these known individuals is a calicivirologist, although RHD is said to involve a calicivirus. However, one of them, Dr. Robert Shope, a professor of pathology from the University of Texas, Medical Branch, Galveston, Texas (U.S.) is a well-respected, internationally known arbovirologist, and epidemiologist.

Could I suggest that you acquire the input you need from a panel you choose? This would not be a group that in the balance had been "hand-picked" and then provided carefully screened information to achieve a pre-selected result as seems to be the intent based on the instructions provided by MAF to the first and the second MAF "Expert Panels". Ideally, a Prime Ministers' special panel to answer the simple question "should a wild calicivirus genotype be used as a biologic weapon against any animal species" could be drawn from a committee of many years standing that is already functioning as the most internationally accepted and respected group of calicivirologists in the world. This is the International Committee on Taxonomy of Viruses, the Calicivirus Working Group. The individuals on this committee past and present are as follows:

I feel sure that corporately or as individuals this group would be willing to address questions of RHD safety, possible human risk, possible cross-species transmission, possible vaccines and their potential long-term effectiveness for humans and other animals, diagnostic tools and their uses in epidemiology and overall the advisability of using caliciviruses as a biological control agent for any unwanted species on any continent or in any country. By not importing and releasing RHD, New Zealand can retain a freedom of options that otherwise will be lost forever, and you can be reasonably certain that once you have had these issues examined by experts who understand and can bear witness to the fickle, unstable genetic structure of the caliciviruses and their erratic behavior in known hosts (not only rabbits), this entire RHD/RCD program for rabbit control in New Zealand will be given the same well deserved fast, quiet and painless death it is purported to give the rabbits.

Sincerely,

Alvin W. Smith, DVM, PhD

Head, Laboratory for Calicivirus Studies

Courtesy copy to:

Australian Prime Minister

Enclosures: Professor Alvin W. Smiths' New Zealand Submission (partial) on the RCD/RHD Application and Disease/Risk Analysis pages 1-33.