University Faculty for Life: Submission of Concern to the Canadian CIHR Re the 'Human Stem Cell Research Recommendations 2001'

Dianne N. Irving
Copyright June 3, 2001
Reproduced with Permission

University Faculty For Life

A multidisciplinary association of scholars speaking out for human life

120 New North Building, Georgetown University, Washington, D.C. 20057

UFL Board of Directors:

Dr. Alan Bernstein, President
Canadian Institutes of Health Research
Working Group on Stem Cell Research
CIHR Ethics Office
410 Laurier Ave. West, 9th floor
Ottawa, Ontario K1A OW9
June 3, 2001

Dear Dr. Bernstein and the CIHR Working Group:

As a member of the Board of Directors of an organization, i.e., the University Faculty For Life, I am contacting you on their behalf concerning your current request for responses to your "Human Stem Cell Research: Opportunities for Health and Ethical Perspectives" [hereafter referred to as "Recommendations"].

The University Faculty for Life was founded in 1989 to promote research, dialogue and publication among faculty members who respect the value of human life from its inception at fertilization or cloning to natural death. Abortion, infanticide and euthanasia, as well as human embryo and human fetal research, human embryonic stem cell research, and human cloning, are highly controversial topics, but we believe they should not be resolved by the shouting, newsbites and slogans that have dominated popular presentations. Because we believe the evidence is on our side, we would like to assure a hearing for our views in the academic community, as well as in the social and political communities -- hence our comments expressed to you here regarding certain concerns we have with the CIHR Recommendations.

The basic issues and concerns of the University Faculty For Life have many dimensions -- political, social, legal, medical, biological, psychological, ethical and religious. We do not have a detailed statement of orthodoxy; rather we have provided an interdisciplinary forum in which scholars can discuss these issues. Since 1990 the UFL has published a newsletter, Pro Vita; since 1991 it has held an annual conference at various university campuses; and since 1992 the Conference Proceedings have been published in book form and distributed to members and hundreds of university libraries. We have sent letters to public figures who misstate biological facts and submitted three amicus curiae briefs on the life issues to the U.S. Supreme Court (two of which I authored on "fetal personhood").

The University Faculty For Life includes as its goals the following:

The University Faculty For Life is also communicating our concerns about similar legislation on these related important issues to groups and organizations both in the United States and abroad. The University Faculty For Life strongly supports good research, but also agrees that immediate legislative action must be taken to prevent harmful and unethical research using human beings in these areas.

As you well realize, the issues raised in your Recommendations are likewise relevant to other proposed legislation dealing with the integrally related issues of abortion, as well as all of the various forms of human embryo research -- including human embryonic stem cell research, human cloning, human chimera research, etc. It goes without saying that your Recommendations, if passed by the Canadian Parliament, will have an immediate impact on similar and related laws, guidelines and regulations passed in other countries around the world. Any legislation passed by Canadian Parliament on these several critically important issues will in effect act as a "role model" for similar legislation internationally. Such legislation impacts greatly on the health and well-being of the individual members of all of our societies. It is difficult to imagine many issues that would effect our societies' health and well-being more than the abuse of living human subjects in research, and the actual manipulation and permanent designing of the future members of the human species.

We have included in this submission a summary of our concerns, followed by a more detailed and extensively referenced scientific response. We hope that these comments may be helpful to your Working Group in reviewing your Recommendations, and we thank you very much in advance for allowing us to submit our concerns to you for your thoughtful consideration.

Respectfully submitted,

Prof. Dr. Dianne N. Irving, M.A., Ph.D.
Member of the Board of Directors
University Faculty For Life
5108 Randall Lane
Bethesda, MD 20816-1917
301-229-4176 FAX 301-229-8748

(©Dianne N. Irving, M.A., Ph.D., May 31, 2001)


Relevant to your Recommendations #1, #2, #3, and #5, the University Faculty For Life would respectfully submit the following scientific and ethical concerns:

A. Scientifically, of concern to us is that:

The starting point for considering and determining public policy making in these scientific and medical issues should be the current accurate science.

Many "views" are based simply on subjective personal opinions, religious beliefs, and even passe "scientific" myths. The position of the University Faculty For Life, and that of many other individuals and organizations, is based not on "opinion", or "beliefs", nor on discarded and long-rejected scientific "myths", but rather on the objective and accurate current facts of human embryology and human genetics -- i.e., that the immediate product of human fertilization or of human cloning is a new unique already existing human being, who's fundamental human rights -- among which is the inherent right to life -- should be equally afforded the full range of legal protections as all other living human beings. The scientific categorization of different human beings into increasing gradients of either "humanhood" or "personhood", and therefore different ethical, social and political rights and protections, has historically never had any scientific, social or political merit, and indeed, has led to disaster.

We are therefore concerned scientifically that these Recommendations: (a) fail to acknowledge the scientific fact that the immediate product of human fertilization and human cloning is a new unique living human being; (b) fail to acknowledge the scientific fact that individual cells and groups of cells from both totipotent and pluripotent "human embryonic stem cells" can "heal" themselves and exist as new individual human beings; (c) use such discarded "scientific" myths as the "biogenetic law", and (d) the "pre-embryo" theory, on which to ground public policy on stem cell research; (e) use a false scientific distinction between "therapeutic" and "reproductive" kinds of research using living human embryos; (f) ban only one scientific method of cloning, i.e., somatic cell nuclear transfer (SCNT), while allowing other direct and indirect methods of cloning human beings, e.g., (g) "embryo splitting", (h) human germ line cell cloning, (i) "sexual cloning", (j) non-chromosomal DNA cloning, and (k) the formation of human chimeras. Extensive current and accurate scientific references for our position may be found in more detail in Part II, below.

In sum: The University Faculty For Life would support only ethical medical research that is based on and that uses current and accurate science, and which does not involve the killing of innocent living human beings -- at any stage of development.

B. Ethically of concern to us is that:

(a) the first ethical requirement of scientific research is not met; (b) the means used to reach good goals are not considered; (c) all human beings are human subjects; (d) a specific defunct, normative, and eugenic "ethics" is ambiguously employed; (e) neither mothers or fathers could give legally or ethically valid informed consent to donate their living human children for medical research; (f) other ethically acceptable means of achieving good goals are available, e.g., the use of adult human stem cells, and other ethical research avenues.

In sum: The University Faculty for Life would support only ethical medical research using adult human stem cells, or other ethical medical research which does not involve the killing of innocent living human begins -- at any stage of development.


[Emphases used to aid those unfamiliar with the science]

(a) The immediate product of human sexual and asexual reproduction is a new, unique, living human being:

As we are certain you are aware, it is a long-established objective scientific fact that the immediate product of human fertilization -- in vivo or in vitro -- is a newly existing, genetically unique, individual living human being -- the single-cell human zygotic embryo.1 This is also the beginning of the embryonic period2 as well as the beginning of normal pregnancy in the fallopian tube of the woman.3 These scientific facts are not new; indeed it has been established scientifically since 1880-1885, with publication of the three-volume tomb, Anatomie menschlicher Embryonen, (Vogel, Leipzig) by Wilhelm His, the founder of human embryology.4 The immediate product of human cloning is likewise a newly existing, genetically unique, individual human being.

(b) Human embryonic "stem cells" can "heal" to form new human beings:

"Blastomere separation", "blastocyst splitting", or "fission", also referred to as "embryo multiplication", can result in these "totipotent" and "pluripotent" cells derived from whole human embryos to "heal" themselves, resulting in new human beings that are "copies" of the original embryo.5 Therefore, these techniques are forms of cloning as well as forms of human embryo research. Since IVF-produced human embryos are usually implanted or frozen at the 2 to 16-cell stage of human embryonic development6, they would be prime candidates for the multiplication of or for the cloning of new human beings. It is an objective scientific fact that as long as the cells of the early human embryo are still intact as parts of the whole embryo, these totipotent and "pluripotent" cells are correctly termed "stem cells". However, once these cells (or, "blastomeres") are separated from the whole embryo, each of these "totipotent or "pluripotent" cells are no longer "stem cells". Single "totipotent" cells, and even groups of "pluripotent" cells, are each capable of "healing" themselves (called "regulation"), and reverting back to being a whole human being. This is indeed what takes place naturally in human monozygotic twinning.7 "Embryo splitting", therefore, is also a form of human cloning by which "identical copies" of human beings are produced.

(c) An implied use of the "scientific" myth of the "biogenetics law" is apparent:

In phrasing the issue in terms of "'a graduated approach' ... in which permitted interventions correlate with the developmental stage of the embryo", the Recommendations obfuscate the critical importance of grounding public policy on universally acknowledged and scientifically accurate facts. Such a "graduated approach" is grounded in the antiquated, long-rejected and scientifically discarded "biogenetic law", i.e., "ontogeny recapitulates philogeny", in the sense that this theory implies that the individual developing human embryo/fetus is not yet a full human being, but is only "gradually" becoming one. Today scientists understand that empirically this is not the case. As human embryologist Ronan O'Rahilly, who sits on the international board of the Nomina Embryologica, has succinctly put it (quoting de Beer), this discarded scientific theory has had a "regrettable influence in the progress of embryology".8 The early human embryo and human fetus is an already existing whole human being immediately from fertilization or cloning on; it is not a frog or a fish "on its way to becoming" a human being. Scientifically, there is no scientific basis for any such "graduated approach" as used in the Recommendations. Ethically, it could be a form of "consensus ethics"; however, "consensus ethics" is a normative ethical theory, and therefore would be properly used to determine public policy in a democratic, pluralistic, multicultural society.

Furthermore, employing such a scientifically erroneous "anthropology" as the starting point, or major premise, of your considerations in these Recommendations unfortunately leads necessarily to the use of additional scientifically erroneous claims and concepts throughout your Recommendations. Such a "graduated approach" also leads to the ethically invalid claim that the early human embryo possesses simply a "reduced moral status" -- i.e., that there is some sort of a parallel "gradually acquired moral status" -- and therefore, supposedly, it would be "scientifically and morally justified" to use him/her in experimental and therapeutic research. However, this would not be a scientifically valid, and therefore not an ethically valid, claim.

(d) An implied use of the "scientific" myth of the "pre-embryo" is used:

Similar "scientific" efforts have been made to imply a "reduced moral status" for the early human embryo because it is simply a "pre-embryo", or by simply using the same scientifically erroneous "science" on which the "pre-embryo" myth was grounded without using the term itself. Scientifically there is no such thing as a "pre-embryo",9 yet the term, or the same or similar false human embryology, has literally flooded the bioethics literature, and national and international documents10, for several years now. [See also Part III (c), below]. However, if scientifically there is no such thing as a "pre-embryo", and if the "science" on which the term is grounded is scientifically erroneous, then any ethical conclusions based on this erroneous "science" are thereby automatically likewise invalid. Therefore neither the false term "pre-embryo", nor the false "science" on which it is grounded, can be used to "scientifically justify" any "reduced moral status" for these early human beings.

(e) A scientifically false distinction between "therapeutic" and "reproductive" research with regard to using human embryos, and human embryonic and human fetal cells, is used:

Scientifically there is no real distinction between using human embryos, i.e., living human beings -- for "therapeutic" purposes or for "reproductive" purposes. Scientifically, once an innocent human being comes into full existence at fertilization, or at cloning, he/she remains an existing human being -- regardless of the scientific, social or political uses that other human beings might have for him/her. This false distinction is true for human stem cell research, as well as for human cloning.

(f) Only one form of cloning, i.e., somatic cell nuclear transfer (SCNT), is banned:

Although these Recommendations courageously do reject the cloning of human beings by means of somatic cell nuclear transfer (SCNT), they fail to properly and accurately address the scientific fact that SCNT is only one method of cloning human beings, and that other methods of cloning human beings would be possible if these Recommendations are "silent" about them. This includes the cloning of human beings by means of the method of parthenogenesis, as well as other methods of human cloning (discussed further below).

If "human cloning" is defined generally as "the direct or indirect production of 'identical copies' of human beings or human DNA materials", then there are several other types of direct and of indirect human cloning that would not be banned by these Recommendations.

(g) Direct cloning of human beings by "embryo splitting" is not banned:

These Recommendations fail to acknowledge scientifically that "embryo splitting", a procedure used by researchers, including for IVF research and for IVF "therapy", is both a form of human cloning as well as a form of human embryo research. [See Part II, (b), pp. 5-8 above].

(h) Direct cloning of human beings by the use of "human fetal stem cells", and their use in DNA-recombinant human gene germ line transfer, is not banned:

Although these Recommendations do accurately recognize that "human fetal stem cells" are actually "human embryonic germ line cells", they fail to specifically acknowledge that these human embryonic germ line cells are diploid11 and therefore can also be cloned, or be used in human DNA-recombinant gene germ line transfer, thus permanently altering future generations of human beings.12 In addition, it should be understood that these human germ line cells can also be retrieved from both living and dead cadavers, not just from embryos and fetuses post abortion.

(i) Indirect cloning of human beings by "sexual" cloning is not banned:

By addressing only an "asexual" form of cloning (i.e., SCNT), these Regulations would not cover "sexual" human cloning, i.e., the duplication or "copying" of human DNA by means of DNA-recombinant human germ-line gene transfer to human gametes or human embryos in vitro, which genetic changes are then "copied" or cloned by means of normal sexual reproduction through the generations. DNA-recombinant human gene germ-line "therapy" is a form of "positive eugenics", as so defined by researchers themselves,13 and essentially accomplishes the same thing eventually as normal a-sexual eugenic cloning, or as does the pre-selection of human embryos after sexual reproduction using IVF. It also involves the human germ-line cells, now referred to simply, and erroneously, in the stem cell debates as "fetal stem cells."

(j) Indirect cloning of human beings by the use of extra-chromosomal and extra-nuclear human DNA is not banned:

By restricting the ban to the cloning of chromosomal nuclear DNA only (i.e., by means of SCNT), the bill would not ban cloning or copying of extra-chromosomal and extra-nuclear human DNA, e.g., as found in several organelles inside and outside the cell nucleus (e.g., the cloning of mitochondrial DNA).14

Next Page: (k) Indirect cloning......
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