Mr. Doug Shank
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Dear Mr. Shank:
Please excuse our delay in responding to your July 22, 1994, letter
concerning
the status of rabies vaccine for wolves and wolf-dog hybrids. Your
questions
are difficult to answer. The U.S. Department of Agriculture has what
appears
to be conflicting regulations concerning the status of wolf-dog hybrids.
Under the regulations established by animal welfare legislation, the
progeny
of wild and domestic animal crosses are considered domestic for the
purposes
of humane care, handling, transportation, or exhibition. The regulations
in
Title 9, Code of Federal Regulations, Parts 101 through 118, which
implement
the Virus-Serum-Toxin Act do 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.
Until recently, there was unanimous acceptance that wolves and dogs
were
separate species. Licensed vaccines were not allowed to be recommended
for
hybrids because their taxonomic status was in doubt.
In 1993, a book, Mammal Species of the World, was published that purportedly
placed dogs into a subspecies of wolves. This has not been universally
accepted. We have been trying to contact experts in the field
of animal
taxonomy to verify the intent of the publication and to determine if
the
immune response of wolves and dogs to an antigen could be expected
to be the
same.
We feel that it is imperative that any decision in this regard be based
on
science and not politics. We recognize the similarity of wolves with
some
breeds of dogs, and the dissimilarity between breeds of dogs. However,
without knowledge of the behavior of rabies vaccines in wolves, we
cannot
allow a manufacturer to recommend the product in that species.
Sincerely,
/s/ Robert Miller
Robert B. Miller
Chief Staff Veterinarian
Veterinary Biologics
Biotechnology, Biologics,
and Environmental Protection
APHIS
Protecting American Agriculture An Equal Opportunity Employer