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Rebuttal to USDA meeting of April 1996 regarding rabies vaccination of wolves and wolf/dog crosses
Note:  This was sent out to the other scientists on the panel for their signatures.

USDA/APHIS recent (non) decision, after an entire scientific expert panel recommended the use of present day inactivated rabies vaccines on wolves and wolf-dog crosses, is irresponsible and may endanger public health by creating a vulnerable population of domestic animals susceptible to rabies living in close proximity to humans. The present day vaccines are safe and efficacious in many diverse species of mammals (dogs, cats, horses, cows, etc.) Rabies in domestic animals has declined significantly in the U.S. and Canada due in large part to successful vaccination programs1. This decline was not due to a non-approval or non-use of the vaccines available. An animal cannot be protected if it is never vaccinated.

There is no scientific evidence that a wolf's immune system is significantly different than a dog's, in fact the preponderance of evidence points to just the opposite. Documentation suggests that rabid wolves die within 4 weeks of exposure to the virus2, 3, 4, 5, similar to wolf/dog crosses6 and dogs7, 8 in this respect. Blood chemistries, hematology, serologies, and response to a variety of anesthetics are similar between dogs and wolves. Furthermore, vaccines, including rabies vaccines, used on dogs have long been routinely used on captive wolves with apparently similar effectiveness9.

USDA/APHIS argue that if the rabies vaccine is approved for use in wolves, then other vaccines against Parvovirus and Distemper, for example, will have to be approved also. This is illogical and may again endanger public health. Humans are not susceptible to these diseases, although humans are definitely susceptible to rabies. Their logic is elusive. Recently, a paper appeared in JAVMA10 stating that 41% of states and territories of the U.S. do not allow vaccination of wolf-dog crosses. Other states allowing vaccination may follow suit once the USDA/APHIS recommendations are widely read, once again endangering public health, possibly to an even higher level.

USDA stated that their preferred study would be challenge testing according to Title 9, CFR part 113.209, however testing has been accomplished under these regulations since rabies vaccines are tested according to species. Disregarding current taxonomy11, and evolutionary12 and genetic13, 14 relationships, and applying a misguided use of the Biological Species Concept in relation to this issue, USDA/APHIS have disregarded the scientific panel's unanimous recommendation that rabies vaccines currently licenced for use in dogs should also be used in wolves and wolf-dog crosses. The logic that USDA/APHIS has used that wolves and coyotes can reproduce and produce fertile offspring and still are not considered the same species is generally misguided. Using their logic, Great Danes and Chihuahuas should be designated as separate species based on a mechanically reproductive isolating mechanism. The use of skull morphometrics alone would undoubtedly classify the two breeds as separate genera. A total disregard of systematics has taken place in relation to this issue. The skull of an animal does not respond to a vaccine and is not the factor deciding if a vaccine will prime the immune system or not.

In closing, we recommend that USDA/APHIS reevaluate this decision and that wolves and wolf-dog crosses be vaccinated in the best interests of public and animal health.

N.E. Federoff (Wildlife Biologist)

REFERENCES

1. Johnson, M.R. 1992. The potential role of rabies in relation to possible Yellowstone wolf populations. In Wolves for Yellowstone? Vol. 4, J.D. Varley and W.G. Brewster (eds.) National Park Service, Yellowstone National Park, Montana, pp. 546-567.

2. Rausch, R.L. 1958. Some observations on rabies in Alaska, with special reference to wild Canidae. Journal of Wildlife Management 22:246-260.

3. Chapman, R.C. 1978. Rabies: Decimation of a wolf pack in arctic Alaska. Science 201:365-367.

4. Ritter, D.G. 1991. Rabies in Alaskan furbearers: A review. Sixth Northern Furbearer Conference. Alaska Department of Fish and Game, Fairbanks, Alaska, pp. 26-34.

5. Weiler, G.J., G.W. Garner, and D.G. Ritter. 1995. Occurrence of rabies in a wolf population in Northeastern Alaska. Journal of Wildlife Diseases 31(1):79-82.

6. Jay, M.T., K.F. Reilly, E.E. DeBess, E.H. Haynes, D.R. Bader, and L.R. Barrett. 1994. Rabies in a vaccinated wolf-dog hybrid. JAVMA 205(12):1729-1732.

7. Fekadu, M. 1991. Canine rabies. In The natural history of rabies, 2nd ed. G.M. Baer (ed.), CRC Press, Boca Raton, Florida. pp. 367-387.

8. Tierkel, E.S. 1975. Canine rabies. In The natural history of rabies, Vol. 2, G.M. Baer (ed.). Academic Press, New York 2:123-137.

9. Mech, L.D. Letter of 3/2/95 to Dr. S. Jenkins (NASPHV/Rabies Compendium/Virginia Department of Public Health).

10. Johnston, W.B. and M.B. Walden. 1996. Results of a national survey of rabies control procedures. JAVMA 208(10):1667-1672.

11. Wozencraft, W.C. 1993. Classification of recent Carnivora: Canidae. In Mammal species of the world: a taxonomic and geographic reference. D.E. Wilson and D.M. Reeder (eds.). Smithsonian Institution Press, Washington, D.C., pp. 280-281.

12. Wayne, R.K. and S.J. O'Brien. 1987. Allozyme divergence within the Canidae. Systematic Zoology 36:339-355.

13. Chiarelli, A.B. 1975. The chromosomes of the Canidae. Pages 40-53 In The wild canids: Their systematics, behavioral ecology, and evolution (M.W. Fox, ed.). Van Nostrand Reinhold, New York.

14. Wurster-Hill, D.H. and W.R. Centerwall. 1982. The interrelationships of chromosome banding patterns in canids, mustelids, hyena, and felids. Cytogenetics and Cell Genetics 34:178-192.