The Chief Executive Officer,                                      
National Registration Authority,

P.O.Box E240,        
ACT , Australia 2604
Fax (06) 272.4753 Int. +61 6 272.4753
28th November 1997

Dear Madam/Sir,

I am aware that the NRA may be in the process of considering the licensing
of RCD/RHD coated baits for use in Australia.The RCD/RHD baits are a unique
and novel product, very different from the RCD/RHD injectable virus which is
currently the only lawful product available for the deliberate spread of
RCD/RHD in Australia. I demand full disclosure of the nature and make-up of
the RCD/RHD baits and that full public consultation be allowed in the
consideration process of allowing or disallowing the approval for use in
Australia by the NRA of RCD/RHD coated baits.

4 out of 5 major calicivirus groups are already known to infect humans and
no guarantees can be given that RHD/RCD will never infect any other species.
Any proposal to deliberately increase the levels of RCD/RHD in the
environment must be scrutinized extremely carefully and independently. If
evidence exists that non-target species may be put at risk by the deliberate
use of such baits, the approval of the RCD baits should be disallowed by the

Further facts concerning the RCD/RHD virus are as follows:

1. The origins (mutation or non-rabbit host) of RHD in China in 1984 remain

2. The genetic determinants and mechanisms resulting in a rapid and bloody
RHD induced death are unknown. 

3. The modes of RHD transmission across ocean channels and between
continents are unknown. 

4. The mechanisms of RHD transmission, which is sometimes rapid and
sometimes leap-frog (hundreds of
kilometers), are unknown. 

5. The reason for failure of RHD to transmit even under contact conditions
in fenced enclosures (Wardang Island)
are unknown. 

6. The host range of RHD is virtually certain to extend well beyond rabbits
(Geelong experiment showing 2-17 fold
antibody increases in 11 test species using purported subimmunogenic virus
doses) but remains unknown. 

7. Diagnostic reagents for RHD lack the specificity and sensitivity to carry
out adequate epidemiologic assays,
particularly in non-rabbit species including humans. 

8. RHD vaccines for rabbits in Spain are reported over time to have become
less protective. 

9. RHD vaccines are not available to protect any non-rabbit species at risk,
including humans. 

10. RHD has not been shown (using proven and acceptable scientific methods)
to be caused by a calicivirus alone;
therefore, the infectious makeup of RHD is unknown. 

11. RHD cannot be propagated in cell culture. Yet, that was a stated
essential CSIRO requirement to be met
before infectivity studies were to be carried out (1994 BRS report). 

12. RHD may have already impacted human health (see Dr. Cherrys' Report
submission to the NZ Government MAF authority)and the extent of the
suspected threat to human health is unknown. 

13. In Australia, RHD is uncontrollable, unpredictable, and often unreliable
as a rabbit control agent.

I demand a full and open public consideration process to be allowed by the
NRA in considering the approval/disapproval of the licensing of RCD/RHD
baits as a veterinary chemical product in Australia.