Submissions to Ministry of Health
The Ministry of Health is called for submissions on development of Guidelines on Using Cells from Established Human Embryonic Stem Cell Lines for Research.

The Ministry issued a 59-page discussion document (which can be downloaded from their website).
Submissions closed 5pm, Friday 3 March 2006.

View the New Zealand Anti-Vivisection Society's Submission

Ministry of Health Media Release on Submission Progress 18 May 2006

The use of human embryonic stem cells is already legislated under a variety of Government Acts. However, Guidelines for their use are being developed to assist researchers and ethics committees dealing with such research.

Points to note
The discussion document notes (2.1) that "animal models" of human disease are being used to predict potential human therapies resulting from human embryonic stem cell research.. It is important to stress that results of experiments on animals should be discarded when assessing potential human benefits, because animals do not react the same way as humans.

The document cites (2.2.1) "testing the effects of human embryonic stem cells in animal models of disease", as a type of human embryonic stem cell research that "researchers" believe they could develop. This type of research should be prohibited.

The document (2.3.1) states that, "Much of the research suggesting that human embryonic stem cells could lead to new therapies was done using mouse cells." It also notes that there are many differences which "complicate" such inferences. Only research directly relating to humans should be used to assess the potential of new therapies. The document similarly cites experiments involving rats and chickens.

Section 2.3.3 reads: "…the fact that human embryonic stem cell lines have been grown on mouse fibroblasts as a nutrient source means that many established lines are unsuitable for transplantation into humans, as will be required to develop therapies from such cells. The feeder cells, and other factors introduced to the cell lines, may be contaminated with bacteria or viruses that are harmless to mice but may cause disease in humans. In addition, the presence of molecules produced by animals but not by humans will cause an immune reaction if transplanted into the human body... Researchers have only very recently discovered techniques of maintaining human embryonic stem cell lines in culture without relying heavily on products derived from mice to support their growth".

Section 2.3.5: "alternatives must also be found to using animal-derived products in the culture of human embryonic stem cell lines as their presence poses risks of cross-species infection. Recent advances in the design of growth media suggests that it may be possible to culture human embryonic stem cells in a medium that is free of animal products."

If human embryonic stem cells are to be used then the research priority should be their use in a way that is free of non-human animals and animal products.

Section 5.2.2 cites the current German law where "Embryonic stem cell research may only be carried out where:...
according to the state of the art in biomedical science, the questions studied by the research have been examined as far as possible using animals."

Reject this part of German law.

The Ministry's proposed guidelines include the following:
"10. The principal researcher must clearly explain and demonstrate to the ethics committee why this objective cannot be addressed through other types of research, including research on other stem cells (such as adult stem cells or animal embryonic stem cells)."

This should be amended to specifically exclude the use of animal cells or experiments.

The Guidelines should be amended to prohibit the use of human embryonic stem cells in research using animals.

Further information

Ministry of Health Discussion Document

New Zealand Anti-Vivisection Society's Submission

Ministry of Health Media Release on Submission Progress 18 May 2006

Ray Greek MD on "The Latest on Stem Cell Research" 15 October 2004, NAVS (USA)

"Wisconsin scientists grow two new stem cell lines in animal cell-free culture" Press Release, 1 January 2006

"Derivation of human embryonic stem cells in defined conditions" 1 January 2006 doi:10.1038/nbt1177 Nature Biotechnology