New Zealand Anti-Vivisection Society (Inc.)
   
Home About the NZAVS Mobilise Newsletter Archive Materials Available Links to other websites Contact the NZAVS

/ Home / Submissions / Royal Commission on Genetic Modification, 2000 Email page link | Print this page

Submission of the New Zealand Anti-Vivisection Society Incorporated to the Royal Commission of Inquiry on Genetic Modification

December 2000

Submission description

NZ Anti-Vivisection Society against the use of animals in genetic modification experiments.

Executive summary

  • NZAVS believes that the omission of the Society from having "interested person" status at the Commission is part of the on-going campaign to censor and silence the scientific anti-vivisection arguments. This tactic backfires as it leads to an increase in illegal direct actions being taken against vivisectors.
  • The use of non-human animals and non-human-animal-derived data should be prohibited, due to the dangers of extrapolating results between species, in determining the safety or otherwise for humans of products of genetic modification.
  • Animal experimentation must be abolished. The New Zealand public demands that it be abolished.
  • Xenotransplantation and xenotransplantation research must be prohibited, due to the dangers to human health.
  • Animal farming should be phased out in favour of organic/veganic cropping.

This Submission deals with the following terms of reference:

Section A(1), Section A(2), Section B(h), Section B(i), Section B(j)(i), Section B(j)(ii), Section B(m), Section B (n)

  1. The New Zealand Anti-Vivisection Society is astonished not to have been granted "interested person" status by the Commission. The Commission stated in their decision that the Commission was "satisfied the public interest which they [NZAVS] typify, will be adequately represented before us by others". NZAVS wrote to the Commission asking for a list of those that the Commission would represent scientific anti-vivisection. NZAVS has not received a reply to this letter. NZAVS believes that none of those granted "interested person" status have the experience, ability and desire to present the scientific anti-vivisection argument.

  2. This belief was borne out only a matter of days into the Hearings of Submissions of Interested Persons, when on 18 October 2000, The Press ran the headline "Experiments on animals 'justified'" (page 6). The article quoted AgResearch's Phil L'Hullier presenting evidence at a Hearing of the Commission justifying research on sheep supposedly aimed at preventing human heart failure.

  3. L' Hullier was challenged on grounds of "cruelty" by Green Party MP Sue Kedgley but was not met with any of the evidence that NZAVS would have presented showing the scientific arguments against using animals in heart research. For instance NZAVS would point to the work of Brandon Reines DVM who wrote:
    "Heart Research on Animals A Critique of Animal Models of Cardiovascular Disease", a comprehensive review of supposed advances in cardiovascular medicine. Reines concluded that "there is little, if any, scientific evidence that animal experimentation has achieved a single significant advance in the battle against CAD [Coronary Artery Disease], hypertension, stroke and congenital heart defects. It was not animal experimentation but clinical investigation that led to the 'Blue Baby Operation', open heart surgery, heart transplantation, and which prevented the deaths of several thousand human beings from CAD. It is not animal experimentation but clinical investigation that should be glorified by the medical community and the mass media."
    (Reines' work is available from NZAVS).

  4. NZAVS can provide many more examples of such evidence of the failure, due to its inherent unscientific basis, of animal experimentation in the field of heart research.

  5. NZAVS notes the irony in using sheep (who eat a vegetarian diet) to study heart attacks in humans (many of whom eat too many sheep, leading to heart attack).

  6. L'Hullier's evidence shows how animal ethics committees are used to protect the vivisectors rather than the animal or human victims of vivisection. Animal Ethics committees are comprised entirely of pro-vivisectionists. NZAVS recommends the abolition of animal ethics committees.

  7. Animal Ethics Committees are based on the principle of the 3Rs, Reduction, Refinement, Replacement. Hans Ruesch writes in 'CIVIS Bullet-in, Nr. 2 - The Infiltration in Animal Welfare': "The 3R's, devised by the British chemical interests and palmed off to the Parliamentarians of the Common Market in Strasbourg and Brussels as a progressive step in animal welfare, instead of a step backward. Its purpose is anesthetic - designed to fool the Parliamentarians and provide them with an alibi, and to allude the A/Vs [anti-vivisectionists] that 'something is being done'. Its unavowed purpose is of course to perpetuate vivisection."

  8. The 3Rs principle is neither valid in theory nor practice. For instance, despite attempts by MAF and the National Animal Ethics Advisory Committee to mislead the public through their press releases, the total number of animals being used in New Zealand experiments is not decreasing. The figure for the 1999 period is almost identical to the mean for the period 1994-99 of 250,000 per year. NZAVS recommends New Zealand abandon the promotion and use of the 3Rs principle.

  9. Further to paragraph 2 , on 24 November 2000, The Press ran the headline "Animals' suffering 'justifiable'" where the NZ Veterinary Association 'justified' vivisection to the Commission "if the research would benefit humans". A situation which NZAVS can and has shown on many occasions has not and can not occur. For instance refer the book written by Bette Overell and published by NZAVS, Animal Research Takes Lives - Humans and Animals Both Suffer (Hard cover available from NZAVS).

  10. As Hearings are continuing past the closing date for written submissions, the Commission has in effect decided that there will be no scientific anti-vivisection input for the rest of the Commission process.

  11. Over the past twenty years, anti-vivisectionists have been urged to go through the 'proper' or 'legitimate' channels. But whenever NZAVS has attempted to do so these channels have been blocked... this Commission being such a case.

  12. The New Zealand public demands abolition of vivisection. In 1989 a Petition of 100,640 signatures seeking the abolition of vivisection was presented to Parliament. This Petition was never given a fair hearing with Primary Production Select Committee Chair Ross Meurant walking out during the presentation of evidence by NZAVS witnesses saying that he did not have time and had matters more pressing. It was later revealed in the media that matters more pressing may have been his involvement in second hand arms dealing and recruiting soldiers of fortune.

  13. Unless they witnessed them directly, members of the Commission probably do not recall the spectacular marches that our Society organised through the streets of Wellington, that while filmed by TV crews were censored from the TV news. They will probably also be unaware of our effective and spectacular rally outside a General Motors dealer in Wellington in 1992, protesting the use of animals in car-crash testing. No media coverage resulted, but by a strange coincidence the General Motors dealer ran extraordinary full-page advertisements in the next days' newspapers (possibly on the pages where reports of our protest may have appeared otherwise?). Subsequently, due to public protest and the fact that it is dangerous to use animal studies as models for humans General Motors ceased its use of animals in car crash tests. As we have demonstrated the extent of public support for the abolition of vivisection has not been highlighted or paid attention to by the media or Parliament.

  14. The scientific anti-vivisection arguments are left unheard. meanwhile human and animal victims of vivisection suffer. This of course leads to anti-vivisectionists who have witnessed such blockages of legitimate channels acting outside of NZAVS, often in illegal activities. These actions may take the form of direct action such as those carried out by the Animal Liberation Front, resulting in liberation of animals or economic damage to the vivisectors or their backers. NZAVS predicts that as a result of this Commission there will be an increase in the number of illegal direct actions targeting the use of animals in genetic modification. NZAVS has no direct contact with groups such as the Animal Liberation Front and does not undertake these types of illegal activities.

  15. Given the refusal of the Commission to have the genetic modification vivisectors face scientific anti-vivisection scrutiny, NZAVS is limiting its submission to a brief outline, for the record, of the anti-vivisection perspective on genetic modification plus an example of genetic modification vivisection in the field of xenotransplantation, with a call for New Zealand to implement a ban on xenotransplantation (including - but not limited to - xenotransplants involving genetically modified animals.)

    16. Anti-vivisection and genetic modification

  16. "In 1983 hundreds of people in Spain died after consuming adulterated rapeseed oil. This adulterated rapeseed oil was not toxic to rats."
    - Professor Dennis Parke of University of Surrey School of Biological Sciences, a former chief advisor on food safety to Unilever Corporation and British advisor to the U.S. FDA on safety aspects of biotechnology.)

  17. Professor Parke warns that the current testing procedures for genetically altered foods including rodent tests are not proving safety for humans.

  18. "Some 'safe-food' campaigners vociferously advocate more animal tests to determine the safety or otherwise for humans of genetically modified foods. But animal experiments cannot work, as each 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. 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."
    - Prof. Pietro Croce M.D., "Vivisection or Science?", Zed Books, 1999

  19. Consequently thousands of drugs, chemicals and other substances are withdrawn from sale - despite being found "safe" based on animal tests - because of the serious health problems they cause in human beings.

  20. "I can find no evidence that the Draize test, LD50 test, or any other tests using animals to support the 'safety' of chemicals and cosmetics, have any relevance to the human species..."
    - Donald C. Doll, M.D., "Declaration of Concern and Support", Physicians Committee for Responsible Medicine, USA, 1988, cited in Hans Ruesch "One Thousand Doctors (and many more) Against Vivisection", CIVIS, 1989.

  21. New Zealand's regulations for safety of food and other substances are currently based on the results of animal tests multiplied by a supposed safety factor (eg 1/100). But it is the inherent metabolic and other differences between species - not merely a level of dosage or difference in the animals' size or weight that renders this method invalid.

  22. Meanwhile if animal tests happen to supposedly 'show' or 'suggest' that a substance may be harmful to humans, the tests are dismissed by the chemical companies and their public relations people as being irrelevant because everyone knows that you can't extrapolate results across species! For instance Dow defended their continued production of pesticide 2,4,5-T (after it was found to have harmful effects in rabbits) as follows:
    "There is no known means of extrapolating between rabbits and humans"
    - Mr J. Plunkett, Agricultural Products Manager for Dow Chemicals (Australia), Dominion, 4 September 1987.)

  23. Similarities can be seen in the case of Dr Pusztai who claimed rats fed potatoes modified with an insecticide gene from snowdrops suffered damage to their organs and their immune systems. The British Royal Society (by no means an anti-vivisection organisation!) reported on his experiments thus:

  24. "The work concerned one particular species of animal, when fed with one particular product modified by the insertion of one particular gene by one particular method. However skillfully the experiments were done, it would be unjustifiable to draw from them general conclusions about whether genetically modified foods are harmful to human beings or not."
    - Royal Society U.K., "Review of data on possible toxicity of GM potatoes, May 1999

  25. Testing the effects of drugs or foodstuffs or other substances on genetically-identical animals can tell us nothing regarding the effect on genetically-diverse humans.

  26. NZAVS recommends:
    • That the Commission disregards results, due to their unscientific and meaningless conclusions, from animal experiments regarding the safety or otherwise of genetically modified products for humans.
    • That no animal experiments take place to determine the safety or otherwise for humans of genetically modified products.
    • That results from animal experiments be declared to have zero weighting in any decisions made by regulatory authorities on the safety or otherwise for humans of genetically modified products.

  27. Genetic manipulation is put forth as the answer to problems of rejection of animal to human organ transplants. But there are still serious problems with human-to-human transplants, which require lifelong use of anti-rejection drugs. All transplantation is an admission of failure of prevention, diagnosis and early treatment.

  28. 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.

  29. "Viruses that are harmless 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.

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

  31. Breeding animals for xenotransplantation would add to the environmental problems already experienced with conventional farming.

  32. The 'Diaries of Despair' report [copy of the report attached to original submission as an appendix] compiled by Uncaged Campaigns, U.K., shows the horrors and bad science that takes place in xenotransplantation research.

  33. The report predominantly deals with the transplantation of hearts and kidneys from genetically-engineered pigs into baboons and cynomolgus monkeys carried out by Imutran, a subsidiary of Novartis. The report highlights, using leaked documents from the vivisectors, the extent of animal suffering in the experiments, the lack of progress in achieving viable xenotransplantation, the public health risk from viruses carried by the baboons, the errors and omissions in the conduct of the studies.

  34. "Since the publication of the report Imutran have announced that it is moving its operations from U.K. to USA"
    - Daily Express U.K., "Animal lab shuts down", 28 September 2000)

  35. New Zealand must take steps to ensure that such research does not occur in this country. It must be noted that this research was carried out with U.K. Home Office approval under the Animal (Scientific Procedures) Act 1986. In a letter to NZAVS, dated 23 November 2000, the Home Office claim that the Act is "the most rigorous piece of legislation of its type in the world". If 'research' such as that described in the Diaries of Despair report can occur under those circumstances then New Zealand must take extraordinary steps to prohibit Novartis or Imutran or subsidiaries of either company carrying out such work here.

  36. NZAVS Recommends
    • That xenotransplantation be prohibited due to its dangers to human health.
    • That xenotransplantation research be prohibited.

  37. Recent years have seen the emergence of diseases supposedly caused by agents such as the Ebola virus. There is no way of predicting what might happen when genetic material or organisms that have reached their present form over long periods of time are rearranged. If human genes were to be incorporated into, for example, pigs, it may cause pig diseases to make adjustments that could invade humans with new organisms to which our species has had no chance to adapt.

  38. Human proteins produced in animals may be contaminated with animal viruses harmful to human patients. No animal whether transgenic or otherwise remains completely free of endogenous viruses and it is impossible to screen for unknown agents. There is no proof that animal-derived proteins have any clinical benefit.

  39. NZAVS Recommends:
    • That the production of human proteins in animals be prohibited.

  40. NZAVS has presented to Parliament comprehensive arguments for the phasing out of animal farming in New Zealand in favour of organic/veganic cropping. Phasing out animal farming renders the need for agricultural genetic modification experiments unnecessary. NZAVS refers those interested to NZAVS Submission in Support of NZAVS Petition to Abolish Vivisection 1989. (available from NZAVS).

  41. NZAVS Recommends
    • The phasing out of animal farming.
    • The promotion of organic or veganic cropping.

  42. For further information:

< Back ^ Top

Home | About | Mobilise! | Materials | Links | Contact