Donating Eggs for Research: Safeguarding Donors - Submission to the HFEA Consultation on Behalf of Affinity

[The HFEA's Consultation document is available at http://www.hfea.gov.uk/consultations/index.jsp#Donating]

PERSONAL INFORMATION

Title/Name:  Dr John R. Ling

Organisation:  Affinity

Email:  admin@affinity.org.uk

Address:  Affinity, PO Box 2119, Reading RG1 7WS

Position in Organisation (if applicable):  Bioethical issues adviser

Please indicate the nature of your interest in the egg donation for research review.  Affinity is a network of evangelical Christian denominations, church groupings and independent causes representing approximately 1,200 congregations.  We have a strong interest in bioethical issues and public engagement.

In line with the Cabinet Office Code of Practice on written consultation, responses to this consultation may be made public unless specifically requested.  Do you agree to the HFEA making your response publicly available?   Yes x  No

SECTION A - GENERAL VIEWS ON EGG DONATION FOR RESEARCH

1. Do you think that women should be able to donate their eggs to research?

a) as non-patient donors  Yes  No x  

REASON  If this Consultation were concerned with the donation of eggs alone and their subsequent use solely in gamete research, we would have only limited reservations.  However, the truth is that these donated eggs are to be used mostly to create human embryos, and these are destined to be destroyed in the process of stem cell production.  Because we hold that all human life is special and inviolable, and because it commences at fertilisation, we are implacably opposed to the deliberate creation and destruction of human embryos, and thus to the central proposals of this Consultation.

We admire acts of true altruism.  However, ova donation, either by egg-sharing arrangements or by non-patient donors, is a prime example where arguments and actions governed by consequences have been allowed to take precedence over those determined by ethical principles.  Utilitarianism has been mistaken for altruism.  Moreover, we have all witnessed the over-enthusiasms of researchers, and their more recent recantations, surrounding the likelihood of imminent cures for serious diseases by the use of embryonic stem cells.  The distinct possibility of such promotional hype, if not subtle coercion, from all personnel involved in either treatment or research, will simply compound these dilemmas for the women involved.

Furthermore, we reject the so-called autonomy argument.  Women, like all of us, must accept certain boundaries to their individual freedom.  Gamete donations (and their subsequent uses) are not like other donations, such as that of blood, or even kidneys.  Gametes determine who we are.  They are more than mere biological materials.  Their donation should be exceptionally considered and exercised only within the covenant of marriage.  The selling, buying and trading of gametes is unacceptably vulgar.

b) through egg-sharing arrangements  Yes  No x  

REASON  See above.

2. Do you consider the medical risks of egg donation too great to allow non-patients to choose to donate eggs to research?  Yes x    No

REASON  We are not unaware of the common problems and serious risks for women involved in donating eggs.  The known and unknown effects of the obligatory drugs on both the induced eggs in the short-term, and on the women in the long-term are adequate reasons to halt such procedures.  Donations of blood and kidneys are typically for lifesaving purposes.  Egg donations are for non-essential medicine and women’s lives should not be so endangered unnecessarily.

3. Do you consider the ethical concerns so significant that people should not be able to choose to donate eggs for research?

a) for non-patient donors  Yes x    No

REASON  We are not anti-science.  We agree with the Chairman’s opening remark that, ‘New research is essential for the progression of science.’  Indeed, we too are excited by the prospects of stem cell technology, and we support and encourage the progress of such research, but only with non-embryonic stem cells.  Science, like all human activities, should be practised within the boundaries of an ethical framework.  As a result, some areas of research must be ‘no-go’ areas.  Hence, we reject the argument that destroying human embryos is essential for stem cell production in order for progress to be made, for example, in discovering new treatments for serious diseases.  It is both unethical and unnecessary. Instead, stem cells derived from umbilical cord blood, bone marrow and numerous other sources can, and should, be used.

We have consistently held and argued these propositions since before the days of the Warnock Report and the 1990 Human Fertilisation and Embryology Act.  We shall continue to press our case, which is not only rooted in orthodox, biblical Christianity, but which also represents the views of the majority of the ‘morally sensitive’ population.

The proposals contained in this Consultation document represent yet a further step in the trivialisation of human life.  We deeply regret this.  We urge the HFEA not to promote a policy of donation with the impractical hope of protecting donors, but rather to reject altogether the practice of egg donation for research purposes and thus curb the destruction of human embryos.

b) for egg-sharing donors  Yes x    No

REASON  See above.

4. Do you consider egg donation for research to be significantly different to donation for treatment?   Yes   No x  

REASON  If fertility treatments involve the deliberate destruction of human embryos then we are opposed to them as much as we are to embryo destruction during or after research.

5. Do you consider the issues associated with non-patient donation for research to be different to those associated with egg sharing for research?   Yes   No x  

REASON  See above.

SECTION B – IF EGG DONATION FOR RESEARCH WERE ALLOWED

Because of our steadfast opposition to egg donation for research subsequent questions have not been answered.

We wish to thank the HFEA for inviting and receiving our views on this issue.