March 2006

Background and Introduction

The New Zealand Anti-Vivisection Society (Inc.) (referred to as "the Society" or "NZAVS" 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 an Appendix.

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).

The Society's membership comes from a variety of backgrounds, cultures, political, religious and ethical beliefs. Thus, the Society restricts its comments to the influence of animal experiments (and animal products) on the Ministry's proposed Guidelines. It is for individual members to make known separately, to the Ministry, their own views on the ethics of using human embryonic stem cells for research and the implications of those ethics on the proposed Guidelines.

Recommendations:

• That, when assessing potential human benefits that may result from human embryonic cell research, results of experiments on animals should be discarded because animal experiments are unable to reliably predict effects in humans.
• That testing the effects of human embryonic stem cells in animal models of disease be prohibited.
• That, if human embryonic stem cells are to be used, then their use should involve methods that do not use non-human animals and non-human animal products.
• That the Ministry of Health reject and condemn 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."
• That the Ministry of Health's proposed guideline number 10 be amended to read:

  "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 human stem cells (such as human adult stem cells)."

Comments on the Discussion Document (http://www.moh.govt.nz/moh.nsf/by+unid/DF32587ABFCA33C5CC2570C800708A24?Open)

Section 2.3.1 of the Discussion Document notes the many differences between mouse cells and human cells which, as much of the research has been done using mouse cells, call into question the potential new therapies that may come from research using human embryonic stem cells.

Species differences not merely at cellular level…

Every species of animal is a different biomechanical and biochemical entity. Non-human animals are different, not only from humans, but also from each other, anatomically, physiologically, immunologically, genetically, and histologically (down to the basic cellular structure). The dog is different from the cat and the cat is different from the rat. The rat is also different from the mouse. And they are all different from human beings.

Animals react differently to different drugs, vaccines, and chemical substances, not only from humans, but also from each other. Aspirin kills cats and penicillin kills guinea-pigs. Yet guinea-pigs can safely eat strychnine - one of the deadliest poisons for humans, but not for monkeys. The list is endless. Consequently every year thousands of pharmaceutical drugs - drugs that had been found "safe" based on animal tests and approved for human consumption - are pulled off the shelves because of the serious health problems they cause in human beings.

Different animals suffer from different illnesses. Humans suffer from around 30,000 illnesses, but only a "paltry number" (Page, Dr T., 'Vivisection Unveiled', 1997, p. 6) are shared with other species. Even when a species of animals suffer from a disease that may also coincidentally occur in humans the cause or symptoms may differ.

"The rabbit is more susceptible to bovine Mycobacterium tuberculosis than to human Mycobacterium TB. The guinea-pig reacts in the opposite fashion. But in neither guinea-pig nor rabbit does tuberculosis have any characteristics in common with the disease in humans."
(Croce, Prof. Pietro, MD, 'Vivisection or Science? - a choice to make', Zed Books, 1999, p. 24).

Small differences between species can result in large differences in outcomes. This is illustrated by Neal D. Barnard, MD ("Growing Skepticism over Animal Tests", 'Good Medicine', Vol. VIII, No. 4, Autumn 1999, p.15) using the example of drugs or chemicals entering the body:

"…it [a drug or chemical] is subjected to a range of actions that can dramatically differ from one species to the next. First, it must be absorbed. Then it disperses into various tissues. Third, enzymes in the liver or other organs may break it apart or change it into any number of other compounds. Finally, the chemical - or whatever other chemical compounds it has become - is excreted from the body… toxicology experts have found that enzyme systems animals use for eliminating chemical toxins differ dramatically between species".

Similarly the effects of the immune system of differing species to the presence of micro-organisms are subject to chaotic effects, where even 'small' differences between species can result in large outcomes due to the complexity of living systems.

"Since one never knows all the variables between animals and humans in advance when testing a new chemical or procedure, one never knows how or when the animal is going to 'trip one up' in one's foolhardy attempts at extrapolation"
(Page, Dr. T., 'Vivisection Unveiled', 1997, p.18-19).

Testing the effects of human embryonic stem cells in animal models of disease (Discussion Document 2.2.1) is flawed as animal models of disease are not predictive of disease in humans.

The use of animal experiments should therefore be prohibited and results from animal experiments be disregarded when assessing the potential use of human embryonic stem cells and research using such cells.

The Discussion Document (Section 5.2.2) notes current German law where embryonic stem cell research may only be carried out where the questions have been examined using animals. This section of law is dangerous and retards medical progress, and should be rejected and condemned by the Ministry of Health.

The Ministry of Health's Proposed Guideline Number 10 should be amended to exclude reference to non-human animal stem cells. The Guideline should be amended deleting the words "or animal embryonic stem cells" and adding the word "human" between "other" and "stem", and also adding the word "human" between the words "such as" and "adult". The amended guideline should read:

"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 human stem cells (such as human adult stem cells)."

Sections 2.3.3 and 2.3.5 of the Discussion Document notes the use of mouse fibroblasts and other animal products used in the growth and culture of human embryonic stem cell lines. The Discussion Document notes the problems associated with immune reactions and cross-species infections associated with such use of animal products.

Articles published on-line since the beginning of 2006 in the journal 'Nature Biotechnology' (http://www.nature.com/nbt/index.html) have described how researchers at the University of Wisconsin-Madison have succeeded in growing human embryonic stem cells without using animal components. (Greek, Dr R. (MD), "Human Embryonic Stem Cells Grown Without Using Animal Components" (http://www.navs.org/site/News2?page=NewsArticle&id=6783&news_iv_ctrl=-1), 9 January 2006)

With the dangers of using animal products in growth or culture of human embryonic stem cell lines acknowledged and superior methods now a reality, if human embryo stem cell research is to be performed it must be in a way such that neither non-human animal nor non-human animal products are used.

Appendix
CIVIS Principles (http://www.nzavs.org.nz/ourPolicy.html)
These principles, written by NZAVS Patron, Hans Ruesch, have been adopted as the policy of the New Zealand Anti-Vivisection Society Incorporated.