NOTE: Full Text of this letter is not included on this site.
April 11, 1997
To: RCD (Rabbit Hemorrhagic Disease) Application
Ministry of Agriculture
PO Box 2526
Wellington, New Zealand
From: Professor Alvin W. Smith
Head, Laboratory for Calicivirus Studies
College of Veterinary Medicine
Oregon State University
Corvallis, Oregon 97331
Fax 541 737 2730, Ph 541 737 2318
Subject: Invited Response to Reviewers's Reports on the Application to Import RCD/RHD
Dear Ministry:
The attached invited response is an open document as have been all my submissions on RHD.
The document is divided into an introductory section under the heading of Editorial Comment,
followed by Specific Issues raised in some individual reviewers reports, and then a Conclusion.
My intent is crystal clear. It is to advise, based on my expertise as a
scientist/virologist/calicivirologist and on the unacceptable risk placed on non-target species
including humans, that the RHD agent not be introduced into New Zealand. Further, it is my
intent to provide decision makers with the information necessary to fully justify not importing
RCD/RHD into New Zealand.
If there is any lingering doubt that releasing Rabbit Hemorrhagic Disease in New Zealand would
be a wrong and risky act, then it is self evident that issues of concern have not been adequately
taken into account. In their own way, each of the twelve reviewers confirmed just how little is
known of the RHD agent, and that critical information is lacking. Not one of the twelve reviews
could be considered an endorsement of this proposed nationwide, open-air, uncontrollable,
infectious disease experiment.
"The question of whether or not the virus(1) should be introduced." The entire RHD/RCD
program comes down to this single question. And it is this question that the chief decision maker
(Chief Veterinary Officer) instructed the panel of twelve selected reviewers (which did not
include any experts having primary interest and established research credentials in the study of
caliciviruses) to not address. Thus the way seems to have been cleared to render a decision
completely unencumbered by the recommendations of calicivirus experts. How has such a
distorted decision making process evolved where (if New Zealand follows the Australian model)
critical information can be cast to the winds and selected bits of misinformation substituted to
support a wrong decision? The two following points dealing with the history of RHD
information management particularly in Australia seems to offer answers.
(1) A preparation of infected rabbit livers causing RHD and known to contain at least one
viral agent, a calicivirus.
1. The Logic of Rabbit Control: Invariably, in Australia and New Zealand, when it is
concluded that rabbits need to be controlled it is also concluded that RHD must be used
as a means to do this. These two entirely separate issues have been linked as if the
decision to import RHD rests solely on whether or not rabbits need to be controlled.
Written as a resolution it would go something like this: Whereas New Zealand (Australia)
has feral rabbits, and whereas rabbit numbers can reach pest proportions, and whereas
rabbit numbers should be controlled, therefore be it resolved that RHD be imported and
released. This lapse in logic continues to be a favored and oft repeated justification
supporting importation of RHD. The pie-in-the-sky solution which promotes attributes of
RHD that do not exist and discounts possible dangers and failures is being put forth
without providing the dirty little details that this is an irreversible decision and one where
New Zealanders and their children's children from hence forth will be living with the
result. There must be assurances that RHD is efficacious, there must be guarantees that
it will not harm non-target species, and there must be proof that it will not infect humans
or impact human health. RHD fails each of these tests. So why have these critical
failings not been acknowledged and clearly stated by both the applicant group and those
managing the application?
2. Information Management: The answer to the above question becomes apparent when
viewed in the context of a decision management twist which assigns high value to
information from less credible sources. Thus, expert opinion on critical issues is
neutralized or countered with unfounded arguments based on wishful thinking or worse
yet, simple lack of knowledge or truth. An example of this is seen in the Taylor Baines
report where arguments were not weighed and much important information was simply
passed off as complex scientific argument and not even considered. From this, we see
emerging a decision-making system based on confrontation and word games rather than
information built on careful evaluation of credible evidence and research data. In this
way, issues such as calicivirus host specificity, potential risk to humans from calicivirus
exposures and the inadequacy of vaccines and diagnostic reagents for non-target species
all are treated in the context of a "spin-game" rather than a scientific debate.
Misinformation can then be (and in Australia has been) substituted for real data to
orchestrate outcomes desired by officials advocating RHD release. Australias'
justification of these irresponsible actions involves RHD's so-called escape from
Wardang Island and the need to then declare RHD an agent organism so it could be
released as a matter of national policy to preclude litigation for damages caused by the
spread of an exotic disease agent.
For the remainder of this critique, I wish to direct my attention to factors of host specificity,
safety, and the potential health risk for humans which could arise as a result of intermittent,
continuous, or massive exposure to any calicivirus including RHD. If there remains lingering
doubt about the potential risks of RHD affecting non-target species, then what follows must be
treated as new information and it must be reiterated that the issues of host specificity, safety, and
human health risks that I have raised have not been adequately taken into account.
The alarm has been sounded by Dr. David Matson, Dr. Fransicso Parra, Dr. Estabon Domingo,
Dr. David Cubitt, Dr. Wally Clark, Dr. Neil Cherry, Dr. A.R. Bellamy, Dr. Margaret Croxton,
Dr. Lance Jennings, Dr. C.H. Sissan, the New Zealand Association of Scientists, the New
Zealand Ministry of Health, and myself. To further emphasize the consequences of the freezing
out of information such as has been occurring we turn to "Words that Matter", a 1996 book by
Judith Anderson. In her chapter on Frozen Words she quotes Plutarch addressing Platos'
writings:
"In a certain city, words congealed with the cold the moment they were spoken, and
later, as they thawed out, people heard in the summer what they had said to one
another in the winter; it was the same way with what was said by Plato to men still in
their youth; not until long afterwards, if ever, did most of them come to perceive the
meaning, when they had become old men."
Then Ms. Anderson adds her own succinct flourish, "frozen words that do not thaw until their
relevance has passed." What follows are cold facts, cold words, and these must not remain
frozen, for their relevance is now.
1. The origins (mutation or non-rabbit host) of RHD in China in 1984 remain unknown.
2. The genetic determinants and mechanisms resulting in a rapid and bloody RHD induced
death are unknown.
3. The modes of RHD transmission across ocean channels and between continents are
unknown.
4. The mechanisms of RHD transmission, which is sometimes rapid and sometimes leap-frog (hundreds of kilometers), are unknown.
5. The reason for failure of RHD to transmit even under contact conditions in fenced
enclosures (Wardang Island) are unknown.
6. The host range of RHD is virtually certain to extend well beyond rabbits (Geelong
experiment showing 2-17 fold antibody increases in 11 test species using purported
subimmunogenic virus doses) but remains unknown.
7. Diagnostic reagents for RHD lack the specificity and sensitivity to carry out adequate
epidemiologic assays, particularly in non-rabbit species including humans.
8. RHD vaccines for rabbits in Spain are reported over time to have become less protective.
9. RHD vaccines are not available to protect any non-rabbit species at risk, including
humans.
10. RHD has not been shown (using proven and acceptable scientific methods) to be caused
by a calicivirus alone; therefore, the infectious makeup of RHD is unknown.
11. RHD cannot be propagated in cell culture. Yet, that was a stated essential CSIRO
requirement to be met before infectivity studies were to be carried out (1994 BRS report).
12. RHD may have already impacted human health (see Dr. Cherrys' Report #1000) and the
extent of the suspected threat to human health is unknown.
13. In Australia, RHD is uncontrollable, unpredictable, and often unreliable as a rabbit
control agent. Thus, the reality of RHD now loose in the countryside has turned virtually
every Australian/New Zealand RHD program prediction and pronouncement into a
statement of foolishness.
Thirteen very cold facts and each a solid red stop light to warn against this blind rush into
a microbial minefield which the applicant group is promoting for New Zealand.
To substantiate the credibility of these thirteen statements by scientists see submission numbers
179, 376, 391, 483, 673, 722, and 1000. In addition see Dr. Alvin Smiths' open letter to Prime
Minister Bolger 16 December 1996.
There is a flaw in the review mechanism that, if left unaddressed, simply defaults the entire
decision making process. This is done by claiming that critical information is not new
information if previously mentioned, and only so-called new information is relevant. Therefore
information to provide a more full understanding of the old issues of safety, host switching, and
possible human health threat can be said to be not relevant. This freezes all the data and
evidence out of further consideration if the Applicant Groups can make the point that any
information not favorable to their cause addresses issues that are not new. This ploy was carried
out in Australia by the National Registration Authority (NRA). They used out-of-hand rejection
of unwanted input (#376), and this same tactic is seemingly being considered by MAF when it is
said that information does not address new issues thus making relevant data no longer eligible for
consideration.
In a political setting this may be a preferred way of attaining ones' personal objectives and it may
even be legitimate if numerous more-or-less equal alternatives are available. But in the world of
science where alternatives are not equal, this is as silly as manufacturing lead airplanes shaped
like basketballs simply because some person in authority owns a lead mine and prefers spheres to
airfoils, and then justifies that decision by proclaiming that the laws for specific gravity and
Bernoulli lift are not new information therefore they are irrelevant.
For RHD the unknowns are overwhelming. The available evidence is heavily weighted to
indicate that RHD is not host specific, is a risk to other species, and could present a human health
threat. To argue the current science of RHD otherwise, whether one chooses to label the
information old or new, is begging a ride on a lead airplane shaped like a basketball.
The New Zealand decision makers must resoundingly reject this flawed and dangerously
misleading Rabbit Hemorrhagic Disease Import Application. Evidence supporting such a
rejection is overwhelming and compelling and must not be left frozen until its' relevance has
passed.
Alvin W. Smith, DVM, PhD
Head, Laboratory for Calicivirus Studies
Oregon State University