PETA Attack on The Rabies Challenge Fund, Fund Responses

Thank you for your email regarding the Rabies Challenge Fund (RCF).  Please be aware that we attempted to correspond with W. Jean Dodds (co-trustee and veterinarian responsible for the RCF) for a number of weeks in April and May of this year.  During that time, we tried to clarify a number of issues surrounding the RCF experiments, yet we received nothing of substance in response to our questions. We have repeatedly asked the study organizers: 1.      To supply a copy of the protocol so that we (and other experts who collaborate with PETA) might help redesign the study so that dogs are not killed at the end of the study, and so that the study might be done in the most humane way possible). Did that in an attachment to my first response to PETA. 2.       The number of dogs to be used as part of the two concurrent studies, how far along the study had progressed (have the dogs been purchased from a laboratory animal supplier, have they been vaccinated, are they already housed in the RCF facilities, etc.).  Answered that too.   The study began last fall, as described. 3.      What efforts RCF had made to avoid killing all of the dogs they are using in their study. Dr. Ron Schultz has undertaken informal dialog with USDA senior officials , in his capacity as advisor to the vaccine industry and regulatory body. He has decades of experience in the field and attends meetings with these folks regularly. At this point, we have not made progress in changing their views, BUT, he and I together are planning to present a more formal proposal to them. We have 4 + years to accomplish what we view as an important need to change the regulations as currently written for endpoint challenge testing -- before anything involving challenge of these healthy dogs [vaccinates and controls] with rabies virus has to take place according to the current regulatory protocol.  In  Dodd’s last response, (the third letter without substantive information), she told us she did not have the information we were seeking and referred our questions to another scientist responsible for the study – Ronald Schultz.  Please read my direct correspondence here. We never received any response from Schultz.  Dr. Schultz is a very busy Department Chairman, teacher, and world respected vaccinology scientist. I do not know if he directly answered any remaining questions PETA raised -- certainly we have nothing to hide here.   It is interesting that the Rabies Challenge Fund folks are now saying they will attempt to make changes to the protocol after the experiments have begun on the dogs (even though it is highly unlikely the USDA will agree to that since the experiments have already begun).  Nonsence.  This has nothing whatsoever to do with the fact that the study has begun, because no procedures related to challenge with rabies virus will take place for 4 + years. We have the interim years to dialog with the federal authorities, based upon Dr. Schultz's expertise, and hope to amend the CFR regulatory requirements for the end phase of their protocol.  So it is still likely that many dogs will die and many will die excruciating deaths. Absolutely untrue; all the vaccinates should be healthy and survive challenge. Even if we're forced by the USDA to follow the current challenge protocol at the end of the 5 and 7 year studies, there will be no excruciating deaths among the control dogs, because at the very first evidence of malaise and illness they will be sacrificed. The existing data on rabies challenge trials that were completed for  each currently licensed rabies vaccine tells us what to expect as far as the number of days before any sign of illness in the challenged control dogs shows up. Remember, this is a fatal mammalian disease, so animal caretakers in these facilities will be ever vigillant to spot the first signs of malaise and illness. As far as we can tell, RCF has made no attempts to date to get a serological protocol approved [i.e, titer testing commonly offered at many vet offices to accurately detect the concentration of rabies antibodies at any interval post-vaccination]. That is not true; most rabies titers done in the county today are to satisfy export requirements for animals moving to rabies-free countries. Relatively few clinical vets check rabies titers for purposes of getting exemption waivers as justified only on a case-by-case basis, and requiring approvalby local public health regultory authorities. In fact most vets don't even realize that such tests can be done.   The experiments being conducted by RCF are purely elective. Also not true.   Why not design a tenable serological protocol that can be approved by USDA?  They have always deigned such methodology and every year the US State and Territorial Public Health Officials unequivocally state that rabies titer serolgy is unacceptable and unreliable -- this year's reiteration was published in a May 2008 issue of the JAVMA.  A serological method would allow data to be collected from volunteers rather than dogs stuck in a laboratory.  No , it will not suffice . I don't know whether the PETA people are completely naiive here, or knowingly suggesting something to mislead their supporters into thinking that we've not thought of or tried to get such testing allowed.   Why were none of these efforts made before PETA began to shine a spotlight on the myriad of problems with RCF’s plans?  This presumption without evidence to support their contention is perhaps arrogant. These alternative suggestions have been made for years by myself, Dr. Schultz and others; they have been the subject of seminars, publications, and teaching handouts to both the profession and the public.  With regards to RCF's statement that PETA should be working on this issue, we are indeed working on non-animal protocols for vaccine testing at both the USDA and the FDA. PETA has spent more than three quarters of a million dollars in recent years to develop non-animal testing methods.  We're very happy to put our money where our mouth is!  IF that's true; we applaud the effort !  Despite repeated requests, the RCF folks have refused to provide details including: •       the actual number of dogs involved in each study.  The USDA gives only the minimum number of dogs that they must have data for at the culmination of the study, so logically RCF must use more dogs than the USDA’s minimum of 70.  No we only need a few extra animals [should a few become ill during the length of the study for some unforseen natural diseae] , and we will not use more from both humane and cost issues.  However, RCF has not answered even this simple question. • the conditions and socialization for the dogs.  Dodds referred PETA to USDA’s protocol for this information.  USDA’s protocol does not specify that dogs should be socialized, group housed, or that they should receive toys or even a bed. The existing USDA CFR protocol is outdated in that regard, and the law has not been updfated, BUT, as we and PETA all realize, all current research protocols are governed by the USDA Animal Welfare Act and the NIH Guide for the Care and Use of Laboratory Animals for all institutions that receive federal research monies. These regulations require socialization and exercise and specify the animal housing conditions. So, this point is moot and they're certainly are well aware of the current federal and state rules that apply.    •       how and when the dogs would be killed.  RCF referred PETA to the USDA protocol for this information.  USDA’s protocol stipulates that even vaccinated dogs are to be killed and their brains examined.  At the end of the 5 and 7 year studies, the current regualtions do so state, but see above for our plans to get some amendments accepted in the interim years. This is in direct contradiction RCF’s current claim that it will adopt out the dogs who don't die. No one in an official capacity for the RCF or any one else purporting to represent us, to my knowledge, has ever said that.  It  would create a huge liability issue.   RCF makes it appear that dogs will be killed at the first signs of rabies.  Rabies is painful and its symptoms can begin quietly.  See above. Dogs will likely die of painful complications related to paralysis and inability to breathe.  Not true; the end point will be recognized long before this end stage of paralysis.  No one is disputing how the immune system works and that dogs are most likely being over-vaccinated in many ways.  However, much more good could have come from an effort to change the way rabies vaccine efficacy is tested rather than to use more than $1 million to kill beagles.  This is just inflammatory rhetoric.   To paraphrase PETA's president, "A dog is a dog is a dog is a dog."   It is unfortunate the RCF chose to use crude and cruel methods in its attempts to help other dogs."  It is also unfortunate that PETA chooses to paint our good will for the benefit of millions in this light. It seems there are critical differences here, and I stand with PETA and again demand [ hey -- how about a request rather than demand here ? ]  the issues raised by PETA be addressed AND FOLLOWED. Sincerely,