Currently there is a proposal before the NRA for a change of usage of RCD injectible live virus.
This RCD virus "product" can only be administered to live wild rabbits trapped by authorities and
injected with RCD virus and then let loose to infect other rabbits. The authorities now want to mix deadly live RCD
virus with baits to spread across areas where they deem rabbits to be a problem. Other animals may also
eat these grain or oat based baits (the new "bait" usage will not be a species specific method of delivery of deadly RCD virus
as is the "injectible" RCD)
Help convince the NRA to call for a Public Review of change of usage of RCD injectible live virus to RCD baits.
Ask the NRA for a public review.
A new use should be in the public domain.
Focus on the antibody response among non-target organisms.
Pose a series of key questions to the NRA which should be definitively
answered before any approval is given.
Email
Alan Norden
Permits for trial or off-label use of chemicals,NRA
anorden@nra.gov.au
Nikki Darby
Chemical Review Program,NRA
ndarby@nra.gov.au
Juanita de Silva, NRA,
jdesilva@nra.gov.au
Graham Savage, NRA,
gsavage@nra.gov.au
Or Fax
Ms Alison Turner,
Chief Executive Officer,
National Registration Authority,
Canberra,
Australia
FAX +61 2 6272.3195
Here is a sample to follow
Dear Nikki,
I would like a public review of the proposed change of usage of the RCD injectible live virus that is now being considered by the NRA.(i.e. RCD baits)
Apparently, a new use should be reviewed in the public domain.
I am most concerned about the antibody response among non-target organisms
as evidenced in the 1996 September BRS report on RCD and also
as evidenced in recent findings in New Zealand presented for discussion
at a one day conference there on the 3rd of September 1998.
I wish to know answers to the following questions before RCD baits are approved by the NRA:
1.Can the NRA ensure non-target organisms will not eat the RCD coated baits?
2.Can the NRA guarantee that RCD will never infect any other species than rabbits?
3.Can the NRA guarantee that the antibody responses seen in cats and other animals in New Zealand are not a response to infection by exposure to RCD baits?
4.Can the NRA guarantee that RCD baits left out in UV sunlight will not
cause attenuated virus that may either immunise rabbits against RCD or cause
a new form of illness in rabbits and possibly other animals that eat the RCD baits?
5.In New Zealand apparently the RCD coated baits are supposed to be retrieved after 48 hours of being applied (i.e. the left over uneaten bait is to be removed by those spreading the baits).
(i)Why is the left over RCD bait to be removed?
(ii)Will the NRA ask for left over RCD bait in Australia to be removed by the user?
(iii)How does the NRA expect end users of the product to remove uneaten oat/grain baits from the ground (an impossible task if you have ever tried picking up spilt grains from the ground)?
6.Who will be allowed access to the RCD baits (i.e. will the RCD baits be purchasable by any member of the public)?
7.Can the NRA guarantee that RCD baits will not fall into the hands of those who may add it to the food purchased by pet rabbit owners (for some perverse reason)?
8.How can the NRA guarantee stability in the open of RCD coated baits?
9.(i)Has independent testing on the RCD baits been undertaken to ensure that the virus does not mutate or attenuate on the RCD baits?
(ii)Who conducted the independent tests mentioned in 9(i)?
10.What tests were used to ensure that the RCD virus would not attenuate or mutate or weaken on the RCD baits (especially those left out over a long period of time in the open air)?
11.Is the NRA aware of the a recent publication that utilised information
obtained under the FOI Act and that this paper pointed out there was more illness in humans in Australia exposed to RCD than non-exposed
(Emerging Infectious Diseases Volume 4 Number 1 January - March 1998
Perspectives - Calicivirus Emergence from Ocean Reservoirs: Zoonotic and
Interspecies Movements)?
(i)How does the NRA propose to regulate the amount of RCD baits that humans touch if the baits are to be strewn out in the open?
(ii)How will the NRA stop children walking barefoot over RCD coated baits or accidentally eating them?
(iii)How does the NRA propose to monitor the health of people and animals that come into contact with RCD baits?
12.Is the NRA aware that according to reports from New Zealand
there are wild rabbits apparently infected by RHD who are taking weeks to die whilst their ears are rotting away? As New Zealand has been using RCD coated baits, is the NRA concerned that the
"ear-rot" rabbits may be evidence of an attenuated or mutated
RHD virus?
I hope you can answer these questions. Please also send me the protocols for a public review of the new use of RCD injectible which I believe should be in the public domain
if they are ever considered by the NRA.
Regards,
______________________
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