Letter to the HFEA on first embryo cloning application

Dear Suzi Leather,

We are writing to express our concern about Professor Alison Murdoch’s proposed research involving the cloning of human embryos, which is currently before an HFEA licensing committee. While we understand the good intentions behind the proposal, we believe it to be unnecessary and highly unlikely to offer significant benefits: moreover it is ethically problematic and risks facilitating reproductive cloning. We therefore urge the HFEA not to license this proposal.

Cloning embryos is the height of scientific irresponsibility

As you know, in order to perform this research, Prof Murdoch and her colleagues would have to dramatically improve and refine existing techniques to create cloned human blastocysts. However, to do so, and to publish such results would be highly irresponsible. Once such techniques were perfected and published, it would be very much easier for would-be reproductive cloners to use them in countries where there is no legislation on cloning. It is not adequate or responsible to consider only the implications of the work in the UK, where reproductive cloning is illegal. It is therefore essential that creating embryos through cloning is not permitted, at the very least, until there is a global ban on reproductive cloning. Unless there is such a moratorium, statements of opposition to reproductive cloning by scientists are no more than lip service.

We believe that the scientific community should take the initiative to restrain itself in this area. There are currently discussions about restraining publication of research on biological warfare, and in some countries governments are considering enforcing this, in the public interest. We believe that reproductive cloning, whilst it might not have such immediately damaging consequences as biological warfare, poses issues for society that are equally grave. Worldwide, opinion polls show that the public in many countries is so concerned about the possibility of reproductive cloning that it wishes to see an immediate ban. If the scientific community is unable to police itself, it is the duty of regulators to ensure that irresponsible scientists do not make reproductive cloning easier.

Ethical problems with this research

The first ethical problem with this research is that it involves the creation of embryos purely for research. The individuals and organisations that are signing this letter are not ‘pro-life’. We do not believe that embryos are persons with a right to life. However UK law is based on the concept that embryos are morally significant entities and must be treated with respect. We believe that the creation of embryos purely as a means to an end (as a tool for research), and not for the purpose of reproduction fails to respect their moral status. In our view, this is part of a broader process of instrumentalisation of human life that is sadly being promoted by reproductive biomedicine.

The UK is one of only five countries worldwide which permits the creation of embryos purely for research, and we understand that even here, it is done very rarely. This would be the first major project in the UK to do this, and would set a dangerous precedent. This should not be done without a much broader public debate.

Secondly, this project will require the donation of very large numbers of eggs for research (in the Korean research 242 eggs were needed to create a single embryonic stem cell line). We understand that Professor Murdoch will use eggs that cannot be fertilised in IVF, yet this makes the likelihood of even producing blastocysts, let alone stem cell lines very unlikely. Eggs which cannot be fertilised are unlikely to survive the extra damage incurred in nuclear transfer and go on to produce blastocysts. This research is therefore much less likely to succeed than the Korean laboratory, which at least used good quality eggs. It is, in our view unethical to raise hopes and expend valuable medical research resources by embarking on research which has little chance of success.

This research is unnecessary and unlikely to produce useful new knowledge

We understand that Professor Murdoch aims to create a single embryonic stem (ES) cell line in order to investigate the causes of juvenile diabetes. However, such a research strategy is unlikely to be fruitful for a number of reasons. Firstly, any events detected in that cell line will not be statistically significant, and there will not be adequate controls in the experiment. Secondly, the nuclear transfer process itself is the source of many potential artefacts: cloning creates major health problems in animals, because the cloning process leads to incorrect programming of many genes. As Dr Ian Wilmut has recently noted (1), it may be expected that the same problems will occur in ES cells derived from cloned embryos. There are many alternative approaches to such research which are currently being pursued. It is difficult to believe that this research is ‘necessary’, within the meaning of the HFE Act.

The second aim of the research, 'therapeutic cloning' is, in our view, a medical dead end. It is extremely unlikely that cloning will ever be widely applicable, as Dr Ian Wilmut recently acknowledged (2). There are several reasons for this:

1) 'Therapeutic cloning' would require an enormous supply of eggs which simply does not exist. Even small-scale attempts to apply this technology could only be based on submitting women to the risks of hormonal treatment, and would likely lead to a market dynamic, similar to that which already exists for organs and surrogacy in the US, in which poor people are exploited.

2) Even if the eggs were available, the scenario would be absurdly expensive, and would only be available to the rich. It would also be highly impracticable, requiring the acquiring of expertise in embryo manipulation and tissue culture in each hospital. There would be further major problems with quality control for individualised batches of tissue.

3) For these reasons, biomedical companies attempting to apply embryonic stem cell technology are not pursuing 'therapeutic cloning', but instead are researching a variety of alternative methods of making tissues immunologically compatible (3, 4,5).

In summary, therefore, this research is highly unlikely to succeed, and overall seems very difficult to justify given the ethical problems and social risks it poses. It should not be licensed by the HFEA. We hope the HFEA will adopt a transparent approach to dealing with this proposal, and given the profound issues it raises, will consult the public widely on whether to license it. We will be releasing this letter to the media in order to stimulate public debate. We look forward to hearing your detailed response to the points made in this letter.

Yours sincerely,

Dr. David King, Director, Human Genetics Alert

Dr Michael Antoniou, King’s College, London University

Dr Bill Albert, British Council of Disabled People, Member of the Human Genetics Commission

Dr Richard Nicholson, Editor, the Bulletin of Medical Ethics

Dr Fleur Fisher, Healthcare Ethics Consultancy, former head of Ethics at British Medical Association

Professor Hilary Rose, Professor Emerita of Social Policy, University of Bradford

Sarah Sexton, The Cornerhouse

Dr Sigrid Graumann, Institut Mensch Ethik und Wissenschaft , Berlin

Jennifer Swift, writer and researcher

(Where an organisation name is in bold, the individuals are signing on behalf of that organisation.)

References

1. Rhind, S.M. et al 2003 Human cloning: can it be made safe? Nat Rev Genet. Nov;4 (11):855-64.

2. Wilmut, I The Moral Imperative for Human Cloning New Scientist 21 February 2004, p16.

3. Pollack A. 2001 Use of Cloning to Tailor Treatments has Big Hurdles, Including Cost New York Times December 18 th

4. Aldhous, P. 2001 Can They Rebuild Us? Nature 410 April 5 th.

5. Gellene, D. 2002 Clone Profit? Unlikely: the Technology’s Commercial Viability Faces Many Hurdles Los Angeles Times May 10th