A Statement on Donation of
Human Eggs for Research

Response to the Bioethics Advisory Committee's Consultation Paper entitled, Donation of Human Eggs for Research Presented by the National Council of Churches of Singapore The National Council of Churches of Singapore (NCCS) is grateful to the Bioethics Advisory Committee (BAC) for the opportunity to respond to the consultation entitled, Donation of Human Eggs For Research. It is encouraged by and welcomes the BAC's attempt to promote public discussion and consultation on this important issue. In this response, the NCCS wishes to address the two fundamental issues presented by the paper, namely, (1) should women be allowed to donate their eggs for research? and (2) should there be payment for donating eggs for research? DONATION OF HUMAN EGGS FOR RESEARCH Although the focus of this consultation paper is egg donation and the welfare of donors and not the ethical implications of the research itself, the NCCS must reiterate its position on embryonic stem cell research (ESCR). This is because the view taken by the NCCS regarding such research has direct bearing on its position regarding egg donation. The NCCS maintains that ESCR, which involves the destruction of human embryos, should be prohibited. This is because human life begins at conception, and the human embryo, regardless of its age, is worthy of the respect and dignity accorded to all human beings. The NCCS therefore rejects the distinction between embryo and pre-embryo as academic and arbitrary because it fails to take seriously the ontological status of the being in question. In similar vein, the NCCS rejects the distinction between therapeutic and reproductive cloning because the cloning process is the same in both 'types'. The only difference is the intended use of the manufactured embryo. For the same reasons, the NCCS maintains that the creation of human embryos through parthenogenesis should be prohibited. Although some ethicists have argued that this method of manufacturing embryos poses less ethical problems because the parthenote is not considered a human person, the NCCS finds this line of argument untenable. The primary reason as to why procuring eggs from women for the manufacturing of embryos for research should be prohibited is that such research results in the destruction of human beings. There are other reasons why women should not donate their eggs for research. The procedure that is currently employed to obtain eggs from donors involves considerable risks. Some of these risks are discussed on page 9 of the consultation paper. One of the main health risks associated with egg donation is that donors may develop a condition called ovarian hyper stimulation syndrome (OHSS). While according to the paper, 'the risk of egg retrieval is relatively low', it does continue to be a serious problem for specialists working in the field of infertility. As Annick Delvigne and Serge Rosenberg have pointed out, 'as this is an iatrogenic complication of a non-vital treatment with a potentially fatal outcome, the syndrome remains a serious problem for specialist dealing with infertility'. The former Chief Medical Officer at the Food and Drug Administration (FDA), Dr Suzanne Parisan, describes other risks associated with OHSS: OHSS carried an increased risk of clotting disorders, kidney damage, and ovarian twisting. Ovarian stimulation in general has been associated with serious life threatening pulmonary conditions in FDA trials including thromboembolic events, pulmonary embolism, pulmonary infarction, cerebral vascular accident (stroke) and arterial occlusion with loss of limb or death. The common drug used on egg donors is LupronTM (leuprolide acetate). A range of side effects associated with this drug has been reported to the FDA. This is not mentioned in the consultation paper, but such information is important for a closer assessment of the risks of egg donation. Such information is also vital for healthy women who are considering donating their eggs for research. The hormones used to stimulate ovaries to produce eggs such as gonadotropins, human chorionic gonadotropin therapy and gonadotrophin-releasing hormone (GnRH) agonists are known to produce adverse side effects ranging from headaches to organ damage. Alongside these risks human embryonic stem cells have enjoyed little success in clinical trials. Even in animal models of disease they not only have a lacklustre success but have also in fact carried significant risks including immune rejection and tumour formation. Thus in its December 2006 response to the British Human Fertilisation and Embryology Authority's (HFEA) consultation paper on 'Donating Eggs for Research: Safeguarding Donors', the Scottish Council of Human Bioethics states that '[T]he potential value of research on embryo is over-stated. Although the reasons given to justify embryo research are usually that it will lead to cures of various serious disorders, any benefits are, at best, likely to be in the distant future and there are grave doubts that "cures" will ever be realised using these techniques'. Principle 16 of the Declaration of Helsinki states that 'Every medical research project involving human subjects should be preceded by careful assessment of predictable risks and burdens in comparison with foreseeable benefits to the subject or to others'. Although it is not always easy to compute the risk-benefit ratio, it may be argued that in this case the ratio is not favourable. The NCCS therefore maintains that a woman should not be subjected to such a risky procedure that has no benefit to her and very doubtful benefit to others. Additionally and importantly, it must be pointed out that while the potential outcomes of research on human embryonic stem cells have been overstated, those of adult stem cells have been grossly understated. It is important to note that adult stem cells, which include stem cells taken from umbilical cords, have already been used successfully in human therapies for years, including the treatment of spinal cord injury, leukaemia, and Krabble's Leukodystrophy. To date, however, no therapies in humans using embryonic stem cells have been successfully carried out. PAYMENT FOR HUMAN EGG DONATION The position of the NCCS regarding egg donation for research has, in a sense, made the question concerning payment for egg donation less relevant. However, because the question of financial incentives for donors is not only restricted to women who donate their eggs, the NCCS would like to state that it categorically opposes any inducement of or payment to tissue and organ donors. The NCCS therefore fully agrees with the statement of the 1998 HFEA consultation on the Implementation of Withdrawal of Payments to Donors which maintains: 'In order to ensure beyond doubt that donors were not motivated by financial gain, it would be necessary to abolish all payments and benefits (other than necessary expenses)'. At the outset it must be pointed out that the term 'commercial egg donation' is an oxymoron. As Thomas Murray has argued, 'Despite the repeated reference to "donors" of both ovum and sperm, paying individuals for their biological products makes them vendors, not donors'. While critics may be right to point out that gametes are not strictly speaking the 'product' of donors and receiving payment for them therefore do not make them vendors, there can be no side-stepping the issue that such a practice would result in the commodification and commercialisation of tissues and body parts. The buying and selling of human tissues would lead to the increased objectification of the human body, where the concept of the 'body-as-self' is replaced with the 'body-as-property'. This shift in perspective, which Murray tries to point out with his metaphor of the vendor, will no doubt encourage people to view individual humans as saleable commodities and this would surely compromise and degrade human dignity. How we perceive the body is profoundly important because it will influence the policies that we put in place in securing important and valued body tissues. In recent history, the human body is not simply a subject of observation and study, but an object of manipulation. Biomedical science and technology has in the past quarter century found many revolutionary lifesaving potentials of the body in medicine as new life is created through reproductive technologies, and lives are sustained through organ and tissue transplant. In addition, biomedical science also seeks to preserve life through research on tissues and cells. The image of the body as property has become more prominent now more than ever before. But there is a need to ask whether it is appropriate to see the human body through the conceptual lens of 'property', and examine what radical changes are introduced to our sense of self-identity when this paradigm is embraced uncritically. Yet, there is widespread if often inarticulate unease in society about the very idea of offering parts of the human body for sale at the right price. The sense of repugnance, which is firmly rooted in our collective psyche and moral sensibility, must not be taken lightly. This is because it reveals a resistance to the view that the human body is just a natural object that can be used at our disposal. We realise the need to increase the supply of organs for life-saving transplantations, and we know that doing so exacts a cost. By insisting that organs must be given freely and must not be bought and sold we are finding a way to live with this cost. We know that by allowing organs to be bought and sold we could possibly increase their supply and save many more lives. But we have resisted this approach because we know that by doing this we would make the body or parts of the body simply natural objects, at our disposal if the price is right. There is, of course, nothing degrading about buying and selling, and there is a sense in which commerce can enhance human life. But life itself must never be viewed as a commodity. Our sense of repugnance is therefore rooted in the belief that some things are simply not for sale. In our society, we recognise that public offices and criminal justice may never be bought or sold. To this list we must include the human body. The NCCS therefore supports the position expressed in para 48 of the consultation paper that the donation of tissues 'should be outright gifts and there should be no financial incentives, although reasonable reimbursement of expenses incurred should be allowed'. The NCCS is therefore in broad agreement with the principles delineated in para 48 of the consultation paper (and other documents such as Human Tissue Research and Section 13 of the Human Cloning and Other Prohibition Practises Act [Cap 131B, 2005 Rev Ed]). The NCCS therefore recommends that this policy be retained because it is founded on sound ethical principles. These principles are articulated in other major guidelines, particularly those issued by the European Union and the Council of Europe, for example the Additional Protocol to the European Convention on Human Rights and Biomedicine Concerning Transplantation or Organs and Tissues of Human Origin (ETS No. 186), alluded to in the consultation paper. Terms like 'compensation' and 'payment' commonly used in such documents are often ambiguous and fluid and must be therefore carefully defined. The compensations or payments that a donor might receive must be such that they can never be perceived as financial incentives to donate. These payments must only serve to compensate for loss of earnings or other justifiable expenses so that the donor will not suffer from any financial disadvantage due to the donation. Any form of payment that exceeds reasonable compensation must be deemed unethical. In similar vein, any benefits in kind such as reduction of fertility treatment costs for donors would be unethical. The NCCS therefore does not support 'egg sharing' in which a woman undergoing fertility treatment is induced either by reduced fees or a shorter waiting time to donate her excess eggs for research. Such a practice would tantamount to the commercialisation of human bodily parts by obtaining financial gains or comparable advantages.

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