25 February 2020

The Honourable Lu Shaye The Honourable Laurent Bili

Ambassador Ambassador
Embassy of the People’s Republic of China Embassy of the Republic of France
20 Rue Monsieur, Faguo Zhuhua Dashiguan 60 Tianze Lu
75007 Paris 100600 Beijing
France People’s Republic of China
chinaemb_fr@mfa.gov.cn presse@ambafrance-cn.org

The Honourable Cui Tiankai The Honourable Terry Branstad

Ambassador Ambassador
Embassy of the People’s Republic of China Embassy of the United States
3505 International Place, N.W. No. 55 An Jia Lou Lu
Washington, D.C. 20008 100600 Beijing
United States of America People’s Republic of China
chinaembpress_us@mfa.gov.cn Agbeijing@fas.usda.gov
office.beijing@trade.gov

Dear Ambassadors,

Re: Ban on Wildlife Imports in China; potential vector Orcinus orca

I am writing on behalf of the undersigned scientists and veterinarians and organisations. We have
been carefully following the outbreak of the novel coronavirus (2019-nCoV, now designated as
SARS-CoV-2), which appears to have originated in Wuhan City, Hubei Province, China. We are aware
of the wildlife import ban currently being implemented in China 1, in an attempt to prevent further
outbreaks of similar pathogens and we welcome this decision.
This letter focuses on orca (Orcinus orca, also known as killer whales); however, we also wish to
draw your attention to the fact that so far two species of cetaceans (whales, dolphins and porpoises)
have been identified as carrying coronaviruses. One was identified in a 13-year-old captive-born
beluga whale (Delphinapterus leucas) (believed to be born at SeaWorld, USA) and the coronavirus
was implicated in the cause of death (COD). This beluga exhibited “generalized pulmonary disease
and terminal acute liver failure. … The virus (SW1) was a novel, highly divergent coronavirus most
similar overall to group 3 coronaviruses” 2. The authors concluded “… the identification of a
previously unrecognized virus in a captive animal underscores the vast diversity of viruses that
remains unexplored in animals. These viruses have the potential to be transmitted to humans or
other animals, with significant implications for human and animal health.”
Another coronavirus, ‘Cetacean coronavirus’ (also known as CoV (BdCoV) HKU22), was isolated from
the faecal samples of three captive Indo-Pacific bottlenose dolphins (Tursiops aduncus) (held at

1
https://web.archive.org/web/20200207191149/https://www.washingtonpost.com/world/asia_pacific/china-
temporarily-bans-wildlife-trade-in-wake-of-outbreak/2020/01/26/90c01e4c-409f-11ea-99c7-
1dfd4241a2fe_story.html
2
Mihindukulasuriya, K. A., Wu, G., St. Leger, J., Nordhausen, R. W. and Wang, D. 2008. “Identification of a novel
coronavirus from a beluga whale by using a panviral microarray.” Journal of Virology 82: 5084–5088,
http://dx.doi.org/10.1128 /JVI.02722-07.

Page 1 of 18
Ocean Park, Hong Kong) and the findings of that study indicated that this conroavirus was associated
with acute infections and that “viral clearance was associated with a specific adaptive antibody
response when the bottlenose dolphins recovered from the infections … none of the three bottlenose
dolphins positive for BdCoV HKU22 developed any notable symptoms” 3. The latter is of concern in
that dolphins who may appear ‘healthy’ can still be infected with coronavirus.
We are reaching out to you as there have been recent reports regarding the import of five captive
orca into China 4 (from France and from the USA), as well as recent attempts to bring wild-caught
orca into China from Russia 5.
Orca harbour a range of pathogens. For example, one captive orca held in the USA has been
described as having a ‘normal loading’ of pathogens, yet she had more than 40 potentially
pathogenic organisms isolated from her tissues, exhalations and excrement. At least four were
reported as ‘drug resistant’ and some are also found in humans 6.
Generally, pathogens found in captive orca have not been reported in any detail other than vague
descriptions such as ‘bacteria’ or ‘respiratory related’ diseases. For example, an adult male orca
captured off the coast of Iceland and subsequently held for decades at SeaWorld (Florida, USA), died
in Jan 2019 after years of treatment. He was reported to have had a drug-resistant bacterial
respiratory infection 7.
For the past 25 years, facilities holding orca have refused to release necropsy (animal autopsy)
reports 8 or simply released vague descriptions of the COD, despite the fact that, among other
benefits, necropsy details could provide vital information for identifying zoonotic diseases (i.e.,
diseases that are transmissible from animals to humans). Scientists and veterinarians believe
captive wildlife necropsy information is of great importance 9. Several professionals seeking orca
necropsy information have filed a court case in the USA 10 in an attempt to access necropsy reports
for several recently deceased animals.

3
Woo, P. C. Y., Lau, S. K. P., Lam, C. S. F., Tsang, A. K. L., Hui, S. W., Fan, R. Y.Y., Martelli, P. and Yuen, K. Y. (2014).
"Discovery of a novel bottlenose dolphin coronavirus reveals a distinct species of marine mammal coronavirus in
Gammacoronavirus." Journal of Virology 88 (2): 1318-1331.
4
https://one-voice.fr/en/blog/save-our-orcas-a-sanctuary-not-china.html
5
https://www.nationalgeographic.com/animals/2019/06/russia-moves-orcas-and-belugas-from-whale-jail/
6
See the Court-released report from Dr Ingrid N. Visser, regarding a captive orca held at Miami Seaquarium, which
refers to a number of drug-resistant pathogens (the ‘super bugs’ Staphylococcus aureus (MRSA) (Methicillin-resistant
S. aureus), Staphylococcus sp. (CoNS Coagulase-negative) Escherichia coli Sp#2 (Resistant). Case 1:15-cv-22692-UU,
Florida Southern District Docket, 2016. Additionally, a number of recent orca deaths at SeaWorld have been linked to
drug-resistant pathogens; e.g. see the female orca Unna https://slate.com/news-and-politics/2015/12/unna-killer-
whale-died-at-seaworld-san-antonio-this-week.html
7
https://www.thedodo.com/seaworld-tilikum-cause-of-death-2243563561.html
8
See news article regarding SeaWorld not releasing the necropsy report of the orca who featured in the documentary
‘Blackfish’ https://web.archive.org/web/20180130145534/http://www.wdwinfo.com/news-stories/seaworld-will-not-
be-releasing-tilikum-necropsy-details/
9
Rally, H. D., Baur, D. C. and McFeeley, M. (2018). “Looking behind the Curtain: Achieving Disclosure of Medical and
Scientific Information for Cetaceans in Captivity through Voluntary Compliance and Federal Enforcement.” Animal
Law. Lewis & Clark Law School. 24: 303.
10
https://web.archive.org/web/20190309192428/https://timesofsandiego.com/business/2018/01/11/seaworld-
hiding-orca-necropsies-including-san-diegos-kasatka-federal-suit-claims/
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In light of the 2003 outbreak of severe acute respiratory system syndrome (SARS) and the 2012
outbreak of Middle East respiratory syndrome (MERS-CoV) and now the SARS-CoV-2 outbreak –
each of which are respiratory diseases in humans believed to be zoonotic – health officials and the
authorities should be alert to the potential risks associated with displaying/contact with, not only
small wildlife species found at trade markets, but also larger species such as orca used in public
entertainment.
To illustrate our concerns, at least 40 captive orca have died from respiratory related diseases and
the three most recent orca deaths have been reported as:

• Kasatka (died August 2017, after years of unsuccessful treatment); COD respiratory
infection 11 (see attached photographs of this individual);
• Tilikum (died Jan 2019, after years of unsuccessful treatment); COD bacterial respiratory
infection;
• Kyara (died July 2017, after living only 3 months); COD lung disease.

In the very few cases where the pathogen that is associated with the respiratory infection is
identified publicly, the microorganism was also known to infect humans:

• Unnamed female orca (died October 2003, captured in Russian waters and survived only 13
days); COD bacterium Pseudomonas aeruginosa 12;
• Haida (died 1982, after 1.5 decades in captivity); COD lung infection from bacteria
Staphylococcal sp.13 ;
• Unnamed female orca (died August 1971, after 20 months in captivity); COD salmonellosis 14.
Furthermore, at least two CODs in captive orca have been identified as mosquito-transmitted
diseases that have also been recorded in humans 15. Two orca trainers, who have since left the
captivity industry, describe the situation eloquently when they write in their peer-reviewed
scientific article:

https://web.archive.org/save/https://www.npr.org/2017/08/17/544193748/seaworld-euthanizes-its-oldest-killer-
11

whale-after-respiratory-issues
Rozanova, E. I., Alekseev, A. Y., Abramov, A. V., Rassadkin, Y. N. and Shestopalov, A. M. (2007). "Death of the killer
12

whale Orsinus [sic] orca from bacterial pneumonia in 2003." Russian Journal of Marine Biology 33(5): 321-323.
13
Kielty, J. (2011). Marine Mammal Inventory Report (Deficiencies). St Pete Beach, Florida, USA, The Orca Project Corp
(unpublished report, available from https://theorcaproject.wordpress.com/2011/03/18/noaa-nmfs-marine-mammal-
inventory-report-deficiencies/), 25 pp.
14
Ridgway, S. H. (1979). "Reported causes of death of captive killer whales (Orcinus orca)." Journal of Wildlife Diseases
15(1): 99-104.
15
Buck, C., Paulino, G. P., Medina, D. J., Hsiung, G. D., Campbell, T. W. and Walsh, M. T. (1993). "Isolation of St. Louis
encephalitis virus from a killer whale." Clinical and Diagnostic Virology 1: 109-112.
Jett, J., Ventre, J., Vail, C. and Dodson, L. (2012). “Evidence of lethal mosquito transmitted viral disease in
captive Orcinus orca.” Marine Mammal Health Conference IV. Mote Marine Laboratory and Aquarium, Sarasota,
Florida. 5.
Jett, J. and Ventre, J. M. (2012). "Orca (Orcinus orca) captivity and vulnerability to mosquito-transmitted
viruses." Journal of Marine Animals and Their Ecology 5(2): 9-16.
St. Leger, J., Wu, G., Anderson, M., Dalton, L., Nilson, E. and Wang, D. (2011). "West Nile Virus infection in
killer whale, Texas, USA, 2007." Emerging Infectious Diseases 17(8): 1531-1533.

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 “Although unreported in wild orca populations, mosquito-transmitted diseases have killed
at least two captive orcas (Orcinus orca) in U.S. theme parks. St. Louis Encephalitis Virus
(SLEV) was implicated in the 1990 death of the male orca Kanduke, held at SeaWorld of
Florida. In the second case, West Nile Virus (WNV) killed male orca Taku at SeaWorld of
Texas in 2007. Captive environments increase vulnerability to mosquito transmitted
diseases in a variety of ways. Unlike their wild counterparts who are rarely stationary,
captive orcas typically spend hours each day (mostly at night) floating motionless (logging)
during which time biting mosquitoes access their exposed dorsal surfaces. Mosquitoes are
attracted to exhaled carbon dioxide, heat and dark surfaces, all of which are present during
logging behavior. Further, captive orcas are often housed in geographic locations receiving
high ultraviolet radiation, which acts as an immunosuppressant. Unfortunately, many of
these facilities offer the animals little shade protection. Additionally, many captive orcas
have broken, ground and bored teeth through which bacteria may enter the bloodstream,
thus further compromising their ability to fight various pathogens. Given the often
compromised health of captive orcas, and given that mosquito-transmitted viral outbreaks
are likely to occur in the future, mosquito-transmitted diseases such as SLEV and WNV
remain persistent health risks for captive orcas held in the U.S.”
Both SLEV and WNV are diseases to which humans are susceptible and there are no vaccines to
prevent, or medications to treat, either virus in people (or animals).
Diseases of concern are not only respiratory in nature, as these two examples show:

• K'yosha (died Jan 1992, after living only 5 months); COD brain infection;
• Haida II (died Aug 2001, after 19 years in captivity); COD brain abscess, fungal infection.
It is already established that orca in captivity are chronically stressed and many, if not all, are
immuno-compromised 16. It has been noted that “perfect conditions for new viruses to emerge”
develop at the ‘wet’ markets in China where animals are traded and where they are also “massively
stressed and immune-compromised” 17.
Seventy percent of zoonotic diseases identified so far come from wildlife 18 and as such these CODs
serve as warnings for all forms of wildlife contact and zoonotic diseases. Therefore, our concerns
extend to include the orca already in China, not only any potentially imported orca, because these
animals are, or will be, on public display in front of large stadium audiences.
We emphasise that the typical show format (including the existing one in China) includes the orca
using their tails to splash the audience with very large volumes of water from the tank (see attached
photos from various days and years to illustrate this is a regular occurrence). It should be noted
that this is the same water where the orca defecate and urinate and it is the same water that
circulates with the ‘off show’ tanks – where in China we have documented dead fish decomposing
in the water on the tank floors (see photos attached). Microbes identified in orca faeces have been

16
Marino, L., Rose, N. A., Visser, I. N., Rally, H. D., Ferdowsian, H. R. and Slootsky, V. (2019). "The harmful effects of
captivity and chronic stress on the well-being of orcas (Orcinus orca)." Journal of Veterinary Behavior
https://doi.org/10.1016/j.jveb.2019.05.005.
17
https://web.archive.org/web/20200214015805/https://www.wcs.org/get-involved/updates/a-primer-on-the-
coronavirus
18
https://ghss.georgetown.edu/ihr2005resources/p4/

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shown to be resistant to drugs (erythromycin, ampicillin, tetracycline, and chloramphenicol proved
to be ineffective against the cultured bacteria)19. Recently Chinese scientists have found traces of
SARS-CoV-2 in the faeces of some human infected patients, possibly indicating an additional mode
of transmission 20.
Additionally, orca, particularly after high-energy exercises such as breaching (where the orca ‘jump’
completely out of the water– a trick commonly seen in display shows at theme parks), exhale with
force and their breath is known to contain a wide range of pathogens (see the appended Table,
where 15 potential and known pathogens were identified from free-ranging orca exhalations) 21.
The health hazards for such encounters are already obvious but in addition to these, the orca who
are to be imported from France and the USA have severe dental damage 22 (also see appended
images), resulting in infections and purulent discharge. Body fluids from these conditions will also
enter the water. To further illustrate our concerns, we provide several images (again appended to
this letter) from two orca who are held in the USA (one in California and one in Florida), showing
some of the issues that manifest themselves in orca, despite “world class veterinary care”.
Given the SARS-CoV-2 outbreak, we believe that the alert levels and quarantine status should be
raised for this type of show. We note that Shangdong Province has appropriately implemented a
ban on all imports of aquatic animals (including ‘controlling’ breeding). There is a ban on visiting
aquariums and these facilities are closed and all exhibitions and activities related to aquatic wildlife
have been stopped 23.
China (as of 2019) holds more captive cetaceans than any other country (23% of the world’s captive
cetaceans), followed by Japan (16%)24. Within China there are an estimated 1,000 individual
cetaceans from at least 13 species25. Although we recognise that there has been no recorded
zoonotic transmission of coronavirus from cetaceans to humans, there have been examples of
transmission from small mammals (e.g., masked palm civets and bats in the case of SARS) 26 and
larger mammals (e.g., camels in the case of MERS) 27 to humans. It is well recognised that many

19
Potter, S. L. (2013). “Antimicrobial resistance in Orcinus orca scat: Using marine sentinels as indicators of
pharmaceutical pollution in the Salish Sea.” Master’s Thesis, p. 125, Evergreen State College.
20
https://www.scmp.com/news/china/politics/article/3048611/coronavirus-scientists-identify-possible-new-mode-
transmission
21
Raverty, S. A., Rhodes, L. D., Zabek, E., Eshghi, A., Cameron, C. E., Hanson, M. B. and Schroeder, J. P. (2017).
"Respiratory microbiome of endangered Southern Resident killer whales and microbiota of surrounding sea surface
microlayer in the Eastern North Pacific." Scientific Reports 394: 1-12.
22
Visser, I. N., Jett, J., and Ventre, J. (2019). INOUK – Captive 20-year-old male orca, with chronic and extensive tooth
damage. Report prepared for OneVoice (www.one-voice.fr), March 2019, 25 pp.
23
https://web.archive.org/web/20200214021240/http://www.sd.xinhuanet.com/news/2020-
02/06/c_1125536780.htm?fbclid=IwAR2v0k2QwTvO0pzBtpELlOuE0x-OzmgWX5g9fzi-SLnYwsODLbAPmWnUGvQ
24
https://www.worldanimalprotection.org/sites/default/files/media/int_files/behind_the_smile_-
_dolphins_in_entertainment_report_final_011019.pdf
25
http://chinacetaceanalliance.org/wp-content/uploads/2019/06/19-CCA-Report-English-FINAL.pdf
26
https://www.ncbi.nlm.nih.gov/pubmed/17848070
https://web.archive.org/web/20200217232015/https://www.forbes.com/sites/allenelizabeth/2020/02/12/beluga-
27

whales-can-get-sick-with-coronavirus-too/
Page 5 of 18
species of animals function as ‘reservoirs’ of infectious diseases like coronaviruses and that
outbreaks of such diseases are expected to continue in both marine mammals and humans.
Using a precautionary framework, we strongly urge you to pass this information along to the
appropriate authorities in China and to request that orca (and other cetaceans) be added to the
permanent ban on wildlife imports in China. We also ask that the Shangdong Province
implementation of banning shows and closing aquariums is considered as a nation-wide option, with
due regard for the provision of adequate welfare of the animals currently held in captivity.
Respectfully,

Ingrid N. Visser, PhD

Cetacean Scientist
Orca Research Trust
New Zealand
ingrid@orca.org.nz
www.orcaresearch.org

On behalf of (listed alphabetically):

Page 6 of 18
Gitte Andersen, DVM Erich Hoyt
Veterinarian & Owner Research Fellow
Park Animal Hospital Whale and Dolphin Conservation
Mississauga, United Kingdom
Canada
Samuel Hung, PhD
Monica K. H. Bando, BS MS BVSc PhD Dolphin Biologist
Wildlife Veterinarian Hong Kong Dolphin Conservation Society
Board, Global Animal Welfare Hong Kong

Maddalena Bearzi, PhD Mark Jones BVSc MSc (Stir) MSc (UL) MRCVS,
President Veterinarian & Head of Policy
Ocean Conservation Society Born Free Foundation
USA United Kingdom

Jean-Michel Cousteau Rob Laidlaw, CBiol and MRSB

Environmentalist/Educator/Film Producer Founder & CEO
Founder Zoocheck
Ocean Futures Society Canada
USA
Heather Rally, DVM
Chris Draper, PhD Wildlife Veterinarian
Head of Animal Welfare & Captivity Captive Animal Law Enforcement
Born Free Foundation PETA Foundation,
United Kingdom USA

Silvia Frey, PhD Naomi A. Rose, PhD

Marine Conservation Biologist Marine Mammal Scientist
KYMA Sea Conservation & Research Animal Welfare Institute
Switzerland USA

Toni Frohoff, PhD Christelle Roy-Corbin, DVM, MSc

Wildlife Behavioral Biologist Exotic Animal and Wildlife Veterinarian
TerraMar Research Avian & Exotic Animal Hospital, Montreal
USA Canada

Deborah Giles, PhD Jan Schmidt-Burbach, DVM, PhD

Science and Research Director Head of Wildlife Research and Animal Welfare
Wild Orca World Animal Protection
USA Germany / Thailand

Julie Herbert, DVM, ABVP Thomas I. White, PhD

Veterinarian (Head of Exotic Animals) Ethicist
Laval Emergency Animal Hospital, Laval Oxford Centre for Animal Ethics
Canada United Kingdom

Sophie Hebert-Saulnier, DVM Lindy Weilgart, PhD

Exotic Animal and Wildlife Veterinarian Cetacean Biologist
Avian & Exotic Animal Hospital, Montreal Dalhousie University
Canada Canada

Page 7 of 18
An orca on its side, using its tail to create large splashes which reach the audience, Shanghai
Haichang Ocean Park, Shanghai, China (photos taken 20181217, © Ingrid N. Visser).

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An orca on its side, using its tail to create large splashes which reach the audience, Shanghai
Haichang Ocean Park, Shanghai, China (photo taken 20181223, © Ingrid N. Visser).

One of the large splashes reaching the audience, Shanghai Haichang Ocean Park, Shanghai, China
(screen grab from video taken 20181223, © Ingrid N. Visser).

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Another large splash reaching the audience, Shanghai Haichang Ocean Park, Shanghai, China (screen
grab from video taken 20181223, © Ingrid N. Visser).

Note the umbrellas used to partially deflect the large splash from the orca, Shanghai Haichang
Ocean Park, Shanghai, China (photo taken 20190404, © Ingrid N. Visser).

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Three children (in white raincoats) in the splash zone created by the orca (also note the umbrellas),
Shanghai Haichang Ocean Park, Shanghai, China (photo taken 20190404, © Ingrid N. Visser).

Decomposing fish and fish parts on the floor of one of the orca tanks, Shanghai Haichang Ocean
Park, Shanghai, China (photo taken 20181217 © Ingrid N. Visser).
Page 11 of 18
Decomposing fish and fish parts on the floor of one of the orca tanks, Shanghai Haichang Ocean
Park, Shanghai, China (Top; screen grab from video 20181217, Lower photo 20181218. All © Ingrid
N. Visser).

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A wild-born female orca known as Kasatka (right) with an undisclosed pathogen creating extensive
lesions across her whole body. Of note is that she is held with other orca during this outbreak.
Photo circa 20170806 by hunter.d.photography, SeaWorld San Diego, California, USA.

Kasatka, with the pathogen, perhaps at

an earlier stage (as date and author
unknown), SeaWorld San Diego,
California, USA.

Page 13 of 18
Kasatka (including close-up) with an undisclosed pathogen creating extensive lesions. Photo circa
20170616 by a whistle-blower, SeaWorld San Diego, California, USA.

Page 14 of 18
Kasatka image posted online 20170808 by ‘seaworldtruthteam’ (note the date the photo was taken
is unclear). This posting was 1 week before she was euthanized by SeaWorld who stated that she
had an untreatable, drug-resistant pathogen (this pathogen remains undisclosed).

Left; Close-up of Kasatka’s right tail

fluke, showing needle ‘track-lines’ as a
result of treatment for an undisclosed
pathogen. Note the open lesions
along the vein lines in the center of the
fluke and near the tip. Photo circa
20170616 by a whistle-blower,
SeaWorld San Diego, California, USA.

Page 15 of 18
A female orca (captive born), known as Malia, with an undisclosed pathogen creating extensive skin
discolouration and apparently some open lesions. Posted online 20171230 by ‘makaiolover_lisag’,
SeaWorld Orlando, Florida, USA.

Photographed a week later, this image of Malia shows that the skin discolouration extends onto the
chin area and close examination of this image also shows that it is also on her right side. Posted
online 20180107 by ‘sworlandophotography’, SeaWorld Orlando, Florida, USA.

Page 16 of 18
Inouk, an adult male orca held in France. This is one of the animals reportedly to be shipped to
China. Note that all his teeth are worn down to the gums and they have all been drilled to expose
the pulp. Internal documents show that he often has infections. (see footnote 20).

Page 17 of 18
Source: Raverty, S. A., Rhodes, L. D., Zabek, E., Eshghi, A., Cameron, C. E., Hanson, M. B. and Schroeder, J. P. (2017).
"Respiratory microbiome of endangered Southern Resident killer whales and microbiota of surrounding sea surface
microlayer in the Eastern North Pacific." Scientific Reports. 394: 1-12.

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