Background: The New Zealand Anti-Vivisection Society (Inc.) (referred to as "the Society" within this document) was formed in 1978 by Bette Overell. The Society opposes vivisection on the grounds that it is medical and scientific fraud. We have adopted the CIVIS Principles, written by our Patron, Hans Ruesch, as our policy on vivisection. These Principles are included in this Submission as Appendix I. Our campaigns have included a 1984 Petition to the New Zealand Parliament for the Abolition of the LD50 Test (recommended for "favourable consideration") and our 1989 Petition to the New Zealand Parliament calling for the abolition of vivisection (attaining over 100,000 signatures). We have made submissions to the New Zealand Government on the moratorium on xenotransplantation that currently exists in New Zealand (our Submission on Xenotransplantation to the New Zealand Finance and Expenditure Committee on Supplementary Order Paper No. 231 is included as part of this Submission in Appendix II). We have also made submissions to such agencies as the Xenotransplantation Working Party of the National Health and Medical Research Council (Australia).

This submission on the Review of the Regulation of Human Tissue and Tissue-based Therapies focuses solely on the issue of xenotransplantation.

Recommendations:

Question 59 of the Discussion Document of the Review of the Regulation of Human Tissue and Tissue-based Therapies.

The dangers from xenotransplantation:

Transplanting living animal organs into humans circumvents the natural barriers (such as skin and gastrointestinal tract) that prevent infection, thereby facilitating the transmission of infectious diseases from animals to humans.

Viruses that are harmless (or asymptomatic) to their animal hosts can be deadly when transmitted to humans. For example, Macaque herpes is harmless to macaque monkeys but lethal to humans. (Campaign for Responsible Transplantation (NY), cited in The Civil Abolitionist, Vol. 9, Issue 2, Summer 1998, CIVITAS USA).

There is no way to screen for viruses that are not yet known, or have not yet mutated. New viruses in primates and pigs are continuing to be discovered that were unknown before.

An animal virus may mutate inside its human host or recombine with human viral elements creating new viruses that could be highly lethal.

Proceeding with xenotransplantation could expose patients and non-patients to a host of new animal viruses, which could remain dormant for months or years before being detected. And if at the end of this period a dangerous virus was detected in humans there may be no way of tracing it back to its origin of the xenotransplantation.

The danger is not only from viruses, but also from (potentially antibiotic-resistant) bacteria. Yersinia enterocolutica is a bacterium that uses pigs as a reservoir and can infect humans. It is currently spread via pork. Symptoms in humans range from abdominal pain, mimicking appendicitis, to severe septicaemia. Yet pigs harbouring the disease appear healthy.

Prions, fungi and parasites are other potential dangers that may be transferred from animals to humans via xenotransplants. One theory is that prions are responsible for BSE (Mad Cow Disease) and CJD (Creutzfeld Jacob disease in humans).

It is impossible to guarantee a completely pathogen-free animal.

The Submission concentrated on the principal danger from xenotransplants. A danger that provides such an overwhelming a case for abolishing and banning the procedure, that details of the other problems associated with xenotransplants (failure rate, rejection, biological differences, animal welfare, environmental degradation, cost etc) were not addressed in the body of the submission but are summarised in Appendix II.

For a more detailed report on the dangers of xenotransplantation refer Appendix III, for the full text and references of "Of Pigs, Primates and Plagues" by the Medical Research Modernization Committee.

Thus for these reasons xenotransplantation should be prohibited.

Permanence of prohibited activity.

Xenotransplantation should be listed as an activity to be permanently banned. As mentioned above there is no way to screen for viruses (or other dangers) that are not yet known, or have not yet mutated.

The Xenotransplantation Working Party of the National Health and Medical Research Council of Australia proposed using the results of non-human animal to non-human animal transplants to assess safety or efficacy of xenotransplantation involving humans. This is completely unacceptable due to the species differences that render such results unreliable at best and likely misleading and dangerous. (Refer Appendix I). Also note that in the field of transplantation, animal experiments have not and do not have predictive value for humans for instance:

"Results from animal experiments in the 1960s suggested that there might be important advances in transplantation and there-by prompted a large amount of further research into heart and kidney transplants in rats. But tissue differences between humans and rats proved that animal experiments were once again misleading. The encouraging results had raised hopes that a major advance in clinical immunosuppression for transplantation was in the offing, but these hopes have now faded and nothing of the great mass of work has been translated into clinical practice."
(John Fabre of Oxford's Nuffield Department of Surgery, "Transplantation", Vol. 34, 1982, pages 223-234.)

In attempts to remove xenotransplantation from the list of prohibited activities it seems likely that the vivisection industry will attempt to use results of non-human animal to non-human animal transplants. The best way to prevent this from happening is to ensure that xenotransplantation is listed as a permanently prohibited activity.

Question 60 of the Discussion Document of the Review of the Regulation of Human Tissue and Tissue-based Therapies.

The Society gives the Ministry of Health permission to give the Bioethics Council the Society's contact address so that the Society may be sent materials on xenotransplantation.

Phil Clayton
Director
New Zealand Anti-Vivisection Society Incorporated
June 2004

Appendix I
CIVIS Principles
These principles, written by NZAVS Patron, Hans Ruesch, have been adopted as the policy of the New Zealand Anti-Vivisection Society Incorporated.

Appendix II
NZAVS Submission to the (New Zealand) Finance and Expenditure Committee on Supplementary Order Paper No. 231
This document discusses the risks of cross-species infection from xenotransplantation.

Appendix III
Of Pigs Primates and Plagues
Full text and references from this report on xenotransplantation published by the Medical Research Modernization Committee.