Rabies: Why Is There Still A Problem?
Or do we need to keep counting until we get the right number?
Rabies is the most significant problem facing wolfdog owners and those furry friends we share our lives with. Wherever two wolfdog owners meet, it isn't long until the rabies subject comes up. We have been fighting this problem for many years, and just when it looked like we would finally see a resolution in 1999, we went "on hold" again. And then, in 2001, we returned to Square One.
Many knowledgeable veterinarians agree that any canine living in close proximity to humans should be vaccinated against rabies as a precaution. There is also agreement among many that the vaccine is effective on wolfdogs and does not harm them. Why then have we not seen US Department of Agriculture approval of this vaccine for wolves and wolfdogs? Is there scientific reason not to approve the vaccine or are we feeling the pressure of politics? Following are extracts of documents which have been written regarding this approval. They are provided as a timeline of what it has taken to get "almost there." It has been a hard battle and we cannot quit now.
R. L. Rissler, Assistant Director, Animal Health Programs, USDA, wrote a widely distributed letter to veterinarians to provide a clarification of Hybrid Animal Crosses. “All hybrid crosses between wild and domestic animals, such as wolf x dog, cat x Jungle cat, buffalo x domestic cattle, etc., are considered to be domestic animals. Thus, a wolf x dog cross is considered to be a dog and must be maintained under the dog standards…”
Dale F. Schwindaman, Plant Health Inspection Service, US Department of Agriculture: "Rabies vaccines are approved for all domestic dogs of the scientific name Canis lupus familiaris."
Robert B. Miller, Chief Staff Veterinarian, Robert B. Miller, Chief Staff Veterinarian, Plant Health Inspection Service, US Department of Agriculture: “The U.S. Department of Agriculture has what appears to be conflicting regulations concerning the status of wolf-dog hybrids. Title 9 … implementing the Virus-Serum-Toxin Act does not address the distinction between domesticated and wild animals. The regulations governing the licensing of rabies vaccines require that the product be shown to be effective in each species for which it is recommended. Without knowledge of the behavior of rabies vaccines in wolves, we cannot allow a manufacturer to recommend the product in that species."
Wolf Dog Coalition to USDA:
“The Code of Federal Regulations has defined a wolfdog as domestic … wolves, wolf dogs and dogs are now classified as Canis Lupus, dogs and wolf dogs are classified as Canis lupus familiaris…. The taxonomic issue is clear, the wolf and wolfdog should be included under the dog label, without the need for testing."
NASPHV issued a Compendium of Animal Rabies Control, which states in part: "The American Veterinary Medical Association (AVMA), the NASPHV, and the Council of State and Territorial Epidemiologists (CSTE) strongly recommend the enactment of state laws prohibiting the importation, distribution, relocation, or keeping of wild animals and wild animals that are crossbred to domestic dogs and cats as pets... Wild mammals (as well as the offspring of wild species crossbred with domestic dogs and cats) that bite or otherwise expose people, pets, or livestock should be considered for euthanasia and rabies examination."
Terry L. Medley, USDA Administrator to Congressman Frank R. Wolf:
"While we are certainly aware of the risks associated with the lack of a rabies vaccine specifically approved for use in wolves and wolf-hybrids, the US Department of Agriculture does not directly prohibit veterinarians or individuals from vaccinating these animals. Our authority in this matter is in determining whether or not to approve a vaccine for use in certain species...It is true that the scientists present at our public meeting agreed that the rabies vaccines currently licensed for use in domestic dogs should also be effective in wolves and wolf-hybrids. However,… when asked whether they would recommend such vaccines for use in wolves and wolf-hybrids without testing to demonstrate their safety and effectiveness, most scientists at the meeting indicated that they would not."
Terry L. Medley, Administrator, USDA to Congressman Wolf: “ We need to ensure that this vaccine meets the final criteria of the Virus-Serum-Toxin Act, that the vaccines are safe for use in wolves and wolf-hybrids…. Because the similarities between dogs and wolves create a unique situation for our Agency in terms of vaccine approval, we do not have an established standard for the number of animals that should be tested…. We have statistically determined that we would need vaccination records from 1,500 animals. In establishing this number we are attempting to strike a balance between an acceptable level of risk and a testing parameter that is attainable.”
Terry Medley, USDA Administrator provided an update:
"Because there appear to be fewer than 500 wolves in the United States under the care of a veterinarian, it may not be possible to obtain a sample of this size. Because we would like to continue working toward a resolution of this issue...we will review data on as many wolves as are available."
Craig A. Reed, Acting Administrator, USDA to Congressman Wolf: “If the studies demonstrate to our satisfaction that wolves and dogs respond to vaccines as members of the same species should, we will take the appropriate action to notify biologics manufacturers of our findings and allow wolves and wolf-hybrids to be added to the list of animals for which applicable canine biologics are approved.”
On September 28, 1999, the Notice of Proposed Change was, in fact, published in the Federal Register (Volume 64, Number 187), pages 52247-52248. This change to 9 CFR Part 101 (Viruses, Serums, Toxins, and Analogous Products; Definitions) was listed as Docket No. 99-040-1. The Summary section states: "SUMMARY: We are proposing to amend the Virus-Serum-Toxin Act regulations by adding a definition of the term dog to include all members of the species Canis familiaris, Canis lupus, or any dog-wolf cross. APHIS believes that dogs, wolves, and any dog-wolf cross can be safely and effectively vaccinated with canine vaccines. This action would allow canine vaccines that are recommended for use in dogs to be recommended for use in wolves and any dog-wolf cross.”
AVMA Opposes Rule: The American Veterinary Medical Association (AVMA) position has not changed. In July, 2000, they approved a recommendation by their Council on Biologic and Therapeutic Agents opposing the broadening of the definition of “dog”. When the proposal first appeared in the Federal Register, the AVMA’s Council on Biologic and Therapeutic Agents and the Council on Public Health and Regulatory Veterinary Medicine sent conflicting recommendations to the AVMA Executive Board. While the former opposed the change, the latter suggested that reasonable evidence exists supporting the safe and efficacious use of canine vaccines in wolves and wolf-dog hybrids. The Executive Board ultimately voted in favor of the recommendation from the Council on Biologic and Therapeutic Agents and they notified USDA of the AVMA opposition to the proposed rule. Their chief objection was the lack of scientific evidence supporting USDA’s suggestion that vaccines used to treat domestic dogs would work safely in wolves and wolf-dog crosses. There was also concern over the implications of the federal government ruling that the two species are essentially the same; the AVMA thought it was in the public interest not to blur the meaning of “dog.”
USDA Withdraws Proposed Change: In the April 18, 2001 edition of the Federal register, USDA withdrew their proposed change. USDA cited comments for and against. Commenters opposed the proposed rule in three areas. First, insufficient safety and efficacy data established by controlled studies. Second, that even with a lack of adverse reactions in 600 vaccinated wolves and wolf-dog crosses, they did not view a valid scientific inference that the products can be safely and effectively used in such animals. Third, including wolves and wolf-dog crosses in the definition of dog sends the wrong message to the public. Commenters stated that this change in definition could have an implied meaning of domestication and behavioral traits normally associated with dogs. According to commenters, such an implication would pose serious safety problems to the public. They state that wolves and wolf-dog crosses can be highly unpredictable, have wild behaviors, and should not be promoted as pets. Consequently, the USDA withdrew the proposed change.
AVMA Advises Members of USDA Withdrawal:
In the June 1, 2001 edition of the Journal of the American Veterinary Medical Association, the AVMA advised that wolf and wolf-dog crosses are not eligible to be added to dog vaccine labels. Following a short discussion of the USDA action Dr. Bonnie V. Beaver, a member of the AVMA Executive Board is quoted as saying, “While veterinarians recognize that having an approved rabies vaccine for wolves and wolf hybrids is desirable, this proposal could have had a significant, negative effect on public health by eliminating the USDA’s own requirement of proving rabies vaccine efficacy through direct virus challenge…. The proposal would have set a serious legal precedent by allowing wolves and wolf-hybrids to be called dogs. Taxonomy classifies dogs and wolf-hybrids as subspecies of wolves, not the other way around.”
NASPHV issued the 2001 Compendium of Animal Rabies Control:
Part I.D. states that the efficacy of parenteral rabies vaccination for hybrids (the offspring of wild animals crossbred to domestic dogs and cats) has not been established. No such vaccine is licensed for these animals. Part III. B. 1) C) states that no parenteral rabies vaccine is licensed for use in wild animals. Wild animals or hybrids should not be kept as pets. Part III. C. states that the public should be warned not to handle wildlife. Wild mammals and hybrids that bite persons, pets or livestock should be considered for euthanasia and rabies examination.
Florida Public Health Guidelines indicate that Wolves and wolf-dog hybrids, and wild cats and wild cat/housecat hybrids are not recommended as pets. However, if owned, the animals must be properly permitted through the FWCC. Because of the possible protective effect of vaccination, veterinarians are encouraged to vaccinate these animals against rabies providing: (1) the owner signs a statement recognizing the current “off-label” use of the vaccine; and (2) the owner understands that the animal will be euthanized and tested for rabies should it bite or expose a person or be exposed to a rabid animal. It further states that vaccination status will not alter the decision-making process when wolf-dog, zoo animals and pet wildlife are involved in rabies exposure incidents.
Where do we go from here?
First, Florida Lupine Association strongly advocates that all animals living in close proximately to humans be vaccinated for rabies. Wolfdog owners should discuss this procedure with their veterinarians.
Second, all wolfdog owners must adhere to acceptable levels of containment to ensure the protection of their animals and the protection of the public. Whenever an animal gets loose, there is a strong possibility that the animal will die. When this happens, it is due to the actions or lack of actions of the owner.
Third, Florida Lupine Association will continue to work with local and state officials to assist wherever possible when decisions are being made regarding individual dogs or decisions that will affect all wolfdogs. Education and accurate information are the critical tools that must be used. Presenting fair and balanced information provides the public official the ability to make the best possible decision.
Fourth, the wolfdog community must begin working together with local veterinarians to get the AVMA position overturned. The AVMA had conflicting positions within their organization; it appears to us (Florida Lupine Association) that the AVMA endorsed the wrong position regarding this issue. It seems unlikely that USDA will renew their proposed “dog” definition change without support from the AVMA. Consequently, action is needed to work with veterinarians who actually have experience treating these animals (outside of a laboratory environment) to obtain an AVMA reversal.
Alan L. Mitchell, June 30, 2001