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The United States Department of Agriculture (USDA) is attempting to withdraw their previous approval of vaccines and medications for wolves and wolfdogs. As the following information will show, these animals are already approved for the currently licensed vaccines.

A BRIEF HISTORY OF THE QUEST FOR RABIES VACCINE APPROVAL:

There have been at least three attempts over the last 10 - 15 years to work with the USDA to get official approval for a rabies vaccine for wolves and wolfdogs. These three attempts approached the issue using different strategies.

The first attempt in the late 1980's at the insistence of the USDA, was that actual challenge testing on wolves and wolfdogs was considered. The procedures set forth by the USDA required, among other things, a great deal of money and the death of many animals. Following the USDA’s directions, an organization called Wildlife Education and Research Foundation (WERF) attempted twice to initiate challenge testing. However, for many reasons, they were unsuccessful.

The second attempt began in the early 1990s by an organization called The Rabies-vaccine Approval Finding Team (RAFT). Their approach was based in taxonomy and the USDA’s own rules. Although limited success was realized, the USDA and other opponents made further progress extremely difficult..

The third attempt proved successful. In November 1998, the Wolf Dog Coalition formed a vehicle through which various organizations could work together and focused specifically on political means to resolve the vaccine approval issue. At the instruction of the USDA, the requested numbers of vaccination records were sent to them. In January of 1999, notice was given by the USDA that data submitted was sufficient and significant enough to allow them to make a decision about vaccine approval for wolves and wolfdogs.

In September 1999, the USDA determined that all vaccines currently approved for dogs should also be approved for wolves and wolfdogs. Their approval would be stated by an amendment to the Code of Federal Regulations, Title 9 (CFR9) declaring all vaccines approved for any member of the species Canis lupus. This can be seen at (Docket No. 99-040-1) Published APHIS Rules & Notices: http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=1999_register&docid=fr28se99-17 or USDA's press release: http://www.aphis.usda.gov/lpa/press/1999/09/dogwolf.txt

The National Wolfdog Alliance thanks the owners and organizations that provided their own animal's vaccine documentation, through the Wolf Dog Coalition, to USDA. Special thanks should be given to Gene Sydnor and Diana Bendit for their tireless dedication and work in this endeavor.

USDA ATTEMPTS WITHDRAWL OF APPROVAL:

On April 18, 2001 the USDA published an attempt to withdraw their proposed changes. You can find more information on that withdrawal at: http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=2001_register&docid=fr18ap01-18

USDA'S OWN REQUIREMENTS PROVE VACCINE EFFICACY:

1) Wolves and dogs are taxonomically (scientifically) classified as the same species, i.e. lupus. Mammal Species of the World, A Taxonomic and Geographic Reference, 1993, pages 280-281. For example: [Genus - species - subspecies - (common name)] A dog would be Canis lupus familiaris (Beagle) and a wolf would be Canis lupus arctos (Arctic wolf).

2) Certain "dogs" (canines) have been tested, and procedures approved by USDA for all licensed rabies vaccines, and all other canine medications.

3) Testing of members of a species approves the entire species, according to the USDA CFR9 requirements. The USDA’s contention, therefore, that there is a need for further testing is invalid.

4) USDA set requirements for the Wolfdog Coalition: - The Wolfdog Coalition met and exceeded those requirements - USDA then accepted the data and approved the vaccines and medications for use on wolfdogs and wolves. USDA's spurious attempt to withdraw a scientifically proven and accepted position, which was conducted at their direction, flies in the face of true science and violates the USDA's own policies and public trust.

5) Therefore, dogs, wolves and crossbreeds thereof, all members of the lupus species, are already included under the currently licensed dog vaccines and medications.

POSITIONS OF THE USDA, AS PUBLISHED IN THEIR CODE OF FEDERAL REGULATIONS, CFR 9:

Uninformed authorities and individuals often refer to a privately owned wolfdog or wolf as an “Exotic Animal” or “Wild Animal”. According to the USDA, the animals are neither. This federal agency states that exotic animals are animals that are imported into the United States, and wild animals live in their natural wild state within the boundaries of the United States. Wolfdogs do NOT exist naturally in a wild state. If wolfdogs are not “exotic” or “wild” animals, what then are they? Again, according to the USDA’s own Code of Federal Regulations, the animals are to be considered “Domestic animals,” “Pet animals,” and a “dog.”

This Code of Federal Regulations is the official publication all citizens must adhere to. It logically follows that the federal agency making these rules must adhere to them as well.

USDA Contributes to a Possible Rabies Epidemic:

According to the Humane Society of the United States (HSUS) there are between 1.5 and 2.5 million wolfdogs in this country and 250,000 born every year. These dogs already exist through out the United States. For USDA to ignore this fact does not change it. For them to attempt to withhold rabies vaccination for a certain group of dogs is a violation of their trust to protect public health. This willful attempt would create a massive reservoir of vaccine-approved canines that are susceptible to rabies and which are in daily contact with humans. This is NOT in the best interest of public health.

If the USDA continues to refuse the verified scientific evidence it now has which proves the efficacy of the vaccines and medications in wolves, wolfdogs and all other canines and yet denies this information, it may well leave itself open to legal action in the future.

In addition, the USDA may not wish the public to own this type of dog. However, such a decision is the right of individuals, municipalities and states. It is not within the authority or the trust given to the USDA to attempt to dictate through such unconstitutional means.

Position of the National Wolfdog Alliance (NWA):

After review of documentation supporting the information contained herein, the National Wolfdog Alliance rejects the latest USDA attempted withdrawal. It is illogical, has no foundation in science, may be extremely detrimental to public health, and is blatantly inconsistent with it’s own rules, regulations and definitions. We conclude that these canines are already included under the currently licensed rabies vaccines, and other dog vaccines and medications. We expect the USDA to properly fulfill their obligation to the public and and to immediately and publicly acknowledge this indisputable fact. No unequal secondary approval, no more political duplicity, no other non-scientific or non sequitur determination from the USDA is acceptable.

The Alliance will notify the appropriate authorities of our position and will continue to update this website as needed.

In addition, the Alliance suggests that you make copies of this position statement and history along with the form below and distribute them to all veterinarians and other interested parties you can contact.