Letter to Health Canada in Response to their call for public input on the question of Embryonic Stem

Wednesday, 25 January 2006
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Mr. William E. Maga
Assisted Human Reproduction Implementation Office
Health Canada
Ottawa, ON K1A 0K9

Re: Responses to questions presented in Health Canada's issues paper entitled "Issues Related to the Regulation of Pre-implantation Genetic Diagnosis under the Assisted Human Reproduction Act"

Dear Mr. Maga:

The Catholic Organization for Life and Family (COLF) would like to take this opportunity to respond to the questions presented in Health Canada's issues paper, entitled "Issues Related to the Regulation of Pre-implantation Genetic Diagnosis [PGD] under the Assisted Human Reproduction [AHR] Act." For the reasons listed below, COLF urges that PGD be entirely prohibited in Canada, as it is in Italy and Germany.

1. Are there any other issues that should be addressed in the discussion of PGD?

A number of important concerns were omitted from the Health Canada issues paper. These include:

a) The inherent and inalienable dignity and worth of the human embryo. Regulations concerning PGD must take into account the scientific fact that from the moment of fertilization, the embryo is a living and developing human being with unique and individual DNA and characteristics different and separate from the gamete donors.[1] Like all other human beings, the embryo has inherent worth and "inalienable dignity." [2] It has the same fundamental rights as all other human beings, and must never be treated as a mere object. PGD inherently disrespects the dignity and worth of human life, since it is performed in order to select the most genetically perfect embryos while discarding those that are deemed undesirable. Parents, doctors, and society become the evaluators of the future worth and quality of the lives of existing embryos, and the arbitrators of life or death for these embryonic human beings. Yet each embryo, as a human person, has the "primary and fundamental right to life."[3] Thus, "a diagnosis which shows the existence of a malformation or a hereditary illness must not be the equivalent of a death sentence" for the unborn child.[4] The Catholic view is that "no one can, in any circumstance, claim for himself the right to destroy directly an innocent human being."[5]

b) Risk to the health and life of the embryo. PGD is dependent on in vitro fertilization, which has been shown to endanger the lives of embryos far more than a natural pregnancy. Approximately 50% of in vitro embryos die through freezing and thawing, and over 80% of these embryos do not survive through to pregnancy.[6]

The in vitro process also endangers the health of the children eventually born. Documented physical problems include double the risk of birth defects, [7] a threefold increase in neurological disorders,[8] up to a sevenfold increase in the likelihood of urological/genital defects,[9] a much higher rate of premature births,[10] and a much higher risk of disability[11]. Documented psychological problems include "survivor's syndrome." [12]

In addition, scientists still do not know the long-term effects on children of having a cell removed from their organism as embryos.[13] Putting embryos at risk in this manner disrespects their dignity and worth as human beings, and also violates the AHR Act, whose guiding principles specify that "the health and well-being" of AHR children "must be given priority in all decisions respecting their use." [14]

2. In light of the issues presented above, do you feel that the Government of Canada should set boundaries for the conditions for which PGD may be used in Canada? Why?

The Canadian Government should entirely prohibit PGD, as has been done in Italy and Germany. While some argue that PGD is done only to give parents more information about their future children, the reality is that PGD is used to screen for healthy embryos. The very fact that there are multiple embryos, and that it is not possible to use all of them, creates pressure to select the most genetically perfect, while the rest will be discarded. PGD is a eugenic practice because it is directed towards improving the hereditary characteristics of human beings and eliminating those who are deemed "less fit".

Opening the door to PGD in Canada could radically alter the relationship between parents and children. Children would be viewed more as customized consumer products valuable for their traits than as gifts to be loved unconditionally. Parents could also feel compelled to have children that conform to societal standards of health, appearance and ability, and PGD could become perceived as part of responsible parenthood. Indeed, Dr. Robert Edwards, the IVF pioneer whose work led to the birth of the first IVF baby, has said that "Soon it will be a sin for parents to have a child which carries the heavy burden of genetic disease."[15]

Rather than promoting PGD and thereby deepening misperceptions about the quality of life of the disabled, the Canadian government should be educating society to be more accepting and accommodating towards those with impairments. Most disabled people themselves have come to appreciate that their lives are worth living. Catherine Frazee, a well known Canadian writer and educator who is severely disabled with spinal muscular atrophy, has said of the disabled: "[L]et us affirm that our lives--however much pain, however much struggle—our lives are worth living. Taking our lives to spare us OUR pain and OUR struggle is a crime."[16]

3. The Government invites your view on the use of PGD for cancer predisposition testing, late onset diseases and tissue typing (HLA typing).

Canadians must not allow PGD testing for late-onset diseases or cancer predisposition. The predisposition for cancer does not justify taking a person's life and depriving him or her of perhaps 30, 40 or more years of life. In addition, we must not condemn embryos to death simply because they fail to match the tissue of a sibling. The Church affirms that "every human being is to be respected for himself, and cannot be reduced in worth to a pure and simple instrument for the advantage of others."[17]

COLF offers these comments to assist Health Canada in the development of regulations concerning PGD which respect sound ethical principles.


†Most Rev. Ronald P. Fabbro, C.S.B.
Chairman of the Board
Catholic Organization for Life and Family

[1] The father of modern genetics, Dr. Jérôme Lejeune, declared that "from the moment of fertilization, that is from the earliest moment of biologic existence, the developing human being is alive, and entirely distinct from the mother who provides nourishment and protection." (Lejeune Declaration, available here (October 11, 2005)).

[2] Pontifical Academy for Life, The Dignity of Human Procreation and Reproductive Technologies, Anthropological and Ethical Aspects (Final Communique), February 2004, available here (October 14, 2005); Donum Vitae, supra, Introduction: 1.

[3] Congregation for the Doctrine of the Faith, Instruction on Respect for Human Life in Its Origin and on the Dignity of Procreation Replies to Certain Questions of the Day (Donum Vitae), February 22, 1987, available here (August 23, 2005), Introduction: 1.

[4] Donum Vitae, supra, I: 2.

[5] Donum Vitae, supra, Introduction: 5.

[6] Baylis, Françoise, "Human Embryonic Stem Cell Lines: The Ethics of Derivation," Journal of Obstetrics and Gynecology Canada 2002; 24(2): 159-63, 162, available in pdf format here (October 12, 2005); "Study Findings Suggest over 6.7 Million Embryonic Children Have Died During IVF," LifeSiteNews.com, September 9, 2005, available here (September 9, 2005).

[7] Hansen, Michèle, M.P.H., et. al., "The Risk of Major Birth Defects after Intracytoplasmic Sperm Injection and in Vitro Fertilization," New England Journal of Medicine, March 7, 2002, Vol. 346:625-730,No. 10, available here (October 12, 2005).

[8] Connor, Steve, "Brain disorders more common in IVF children," The Independent, Feburary 8, 2002, available here (October 12, 2005).

[9] Johns Hopkins Medicine Press Release, "In Vitro Fertilization May Be Linked To Bladder Defects," Johns Hopkins Medicine, March 18, 2003, available here (October 12, 2005). See also: Hope, Jenny, "IVF Timebomb," The Daily Mail, November 23, 2004, available here (October 13, 2005).

[10] "In Vitro Fertilization: Risky for Mother and Child - Long Assailed by Church, Procedure Stirs Doctors' Concerns," Zenit, July 13, 2002, available here (October 12, 2005).

[11] "Study Finds Brain Problems in IVF Children," February 8, 2002, LifeSiteNews.com, available here (October 13, 2005).

[12] "In Vitro Children and the Risks They Face: Interview With Neonatologist Carlo Bellieni" Zenit, June 6, 2004.

[13] Testimony of Mr. Andrew Kimbrell, Executive Director, International Center for Technology Assessment, Center for Food Safety, United States Senate Hearing on Science, Technology and Space: Prenatal Genetic Testing Technology, November 17, 2004, available here (January 11, 2006).

[14] Section 2(a), Assisted Human Reproduction Act.

[15] Kimbrell testimony, supra.

[16] Frazee, Catherine, "Our Lives are Worth Living: Comments from a Vigil for Tracy Latimer," 1995, Disabled Women's Network Ontario, available here (January 10, 2006).

[17] Donum Vitae, supra, I: 5.