Letter to the National Institutes of Health

Fr. Joseph C. Howard, Jr., M.Div., has sent the following letter to the National Institutes of Health:

The American Bioethics Advisory Commission is responding to the "Draft National Institutes of Health Guidelines for Research Involving Human Pluripotent Stem Cells" (December 1999). As research, experimentation, and therapeutic procedures move forward with significant advances in molecular biology, it is critical that appropriate ethical considerations are taken into account and that the moral rights of all human beings are unconditionally respected from the moment of fertilization until natural death. This is especially relevant regarding the current NIH Guidelines as applied to human embryonic stem cell research.

To accurately understand the ethical realities surrounding human embryonic stem cell research, it is absolutely essential to have a correct understanding of the scientific embryology of the beginning of human life. Due to advances in scientific biotechnology, we know with no doubt whatsoever that a human life begins at the moment of fertilization. "The human zygote is a living entity, a human being, a human individual, and a person, all one and inseparable. From the moment of fertilization, under conditions we have come to understand and describe as normal, all subsequent development to birth of a living newborn is a fait accompli. There is no subsequent moment or stage which is held in arbitration or abeyance by the mother, or the embryo, or the fetus. Nor is a second contribution, a signal or trigger, needed from the male in order to continue and complete full development to birth. Human development is a continuum in which so-called stages overlap and blend one into another. Thus, the beginning of a new life is exacted by the beginning of fertilization, the reproductive event which is the essence of life. " (Kischer, C.W. 1997. The Beginning of Life and the Establishment of the Continuum, pp. 10-11, in The Human Development Hoax, Kischer and Irving, American Life League, Inc., Stafford, VA). Though many today use the term "pre-embryo," there is no valid scientific or embryological basis for such a term since, prior to the formation of an embryo, all that exist are gametes. Scientific research which is truly ethical must be directed toward the good and service of all human beings without exception from the moment of fertilization until natural death. Failure to observe this ethical principle assaults the dignity of human beings resulting in automatic injustice. Human beings come to be perceived as "objects" or "commodities" which can be exploited for the so-called benefit of others. It must be continually emphasized that all human beings are "ends" in and of themselves and can never be exploited as a "means" to an "end" without their dignity being violated. These fundamental ethical principles must govern all experimentation, research, and therapeutic procedures as applied to human beings unconditionally and without exception from the moment of fertilization until natural death.

The NIH Guidelines call for obtaining pluripotent stem cells for experimentation and manipulation with the hope that these cells could be used for transplantation in persons suffering from various diseases. Pluripotent stem cells are obtained using "human embryos created in excess of clinical need by IVF where informed consent was obtained." It must be recognized that even though some individuals perceive these human embryos as useless since "they are in excess of clinical need," this in no manner diminishes nor destroys the objective nature of these and all other human embryos: All human embryos—whether generated in vivo or in vitro—are human beings and subjects with rights whose dignity and right to life must be unconditionally respected from the first moment of their existence. Such "informed consent" which is granted is morally illicit. While it is true that pluripotent stem cells are not human embryos themselves as totipotent stem cells are, it is also true that the isolation of pluripotent stem cells by removal of the Inner Cell Mass of a human embryo at the blastocyst stage of development results in the death of a human embryo each and every time and amounts to nothing less than human embryonic vivisection (HEV). Investigators must be ready and on standby to collect the pluripotent stem cells after a human embryo(s) has been destroyed or those cells will die within minutes. This places those investigators in direct complicity in actions which are gravely unethical and can never be morally justified. It is never morally justifiable to deliberately and intentionally directly destroy one human life in order that another human life be saved.

The second source of pluripotent stem cells according to current NIH Guidelines is that of fetal tissue obtained from women who have undergone induced abortion and "granted informed consent." Again it must be recognized that such "informed consent" is morally illicit, as no parent has a moral right to grant "consent" for the destruction of their child nor for the use of the remains of their child after the act of killing has occurred. Investigators in this situation also must be ready and on standby to collect these cells or they, too, will die within minutes. This places such investigators in direct complicity with actions being performed which are gravely unethical. Individuals such as researchers or investigators not involved in the act of killing who nonetheless have knowledge that the killing will occur and remain on standby ready to collect cells, tissues or organs de facto, such persons are directly and formally cooperating in actions which are gravely unethical and should certainly never be funded by the United States Federal Government.

The American Bioethics Advisory Commission recognizes that it is possible to ethically isolate stem cells for experimental research and manipulation in hopes of finding therapeutic cures. It is known that various organs and tissues in the human body contain a reservoir of stem cells. These stem cells, in principle, could be ethically isolated and used for therapeutic purposes as has been demonstrated with both skin and bone. One such study evaluated the use of hematopoietic stem and progenitor cells from umbilical-cord blood in 562 transplantations performed from August 24, 1992, through January 30, 1998. This study included data on most placental-blood transplantations from unrelated donors performed in the world thus far. The 562 patients in this study were diagnosed with one of the following disorders: Acute Lymphoblastic Leukemia, Acute Myelogenous Leukemia, Chronic Myelogenous Leukemia, Juvenile Chronic Myelogenous Leukemia, Chronic Lymphocytic Leukemia, Lymphoma, Fanconi's Anemia, Severe Combined Immunodeficiency Disorder, Osteopetrosis, Hurler's Syndrome, Wiskott-Aldrich Syndrome, Adrenoleukodystrophy, Blackfan-Diamond Syndrome, Myelodysplastic Disease, and Severe Aplastic Anemia. The results of this study found that for patients for whom no histocompatible donor is available, allogeneic hematopoietic stem cells from placental blood offers substantial advantages: the relative ease of procurement; the absence of risk to the donor; the small likelihood of transmitting clinically important viral infections such as CMV or EBV; the low risk of severe graft-versus-host disease; and the rapid availability of placental blood to transplantation centers. The effectiveness demonstrated in this study could be enhanced by wider accessibility and by improvements that would speed engraftment and lessen early morbidity. (See N Eng J Med 1998, 339:1565-77) It is very likely that these stem cells can differentiate into muscle, bone, and connective tissue as well. Recent experimental studies conducted in mice demonstrated that neural stem cells from the brains of mice when transplanted into the bone marrow of irradiated mice were reprogrammable, becoming a variety of cell types, including myeloid and lymphoid cells as well as early hematopoietic cells. Using experimental protocol with reverse design, mice were injected with genetically tagged bone marrow cells and their brains were subsequently examined. The tagged bone marrow cells were found to have the capacity to differentiate into microglia, fibrous astrocytes of the subcortical white matter, and protoplasmic astrocytes of the neocortex.

In conclusion, the American Bioethics Advisory Commission shares the concerns of alleviating human disease and suffering; nonetheless, we must seek solutions which are truly ethical and respect the intrinsic dignity of all human beings without exception. This means showing unconditional respect for all human life from the moment of fertilization until natural death. Failure to do so destroys the first and most fundamental of all rights as established by the Laws of Nature: the unconditional right to life of all human beings from the moment of fertilization. We must work together to conduct experimental research and find therapeutic cures for pathologies which place science and medicine at the service of all humanity exemplified by showing absolute respect for all human life.

Sincerely yours,

Fr. Joseph C. Howard, Jr., M.Div.
Executive Director
American Bioethics Advisory Commission

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