Recommendations:

NZAVS supports a moratorium on xenotransplantation so that the relevant authorities can educate the public on dangers of the procedure, in preparation for an outright ban at the end of the moratorium. The education programme must be embarked on immediately and must be able to counter the expected backlash by those with a financial, or emotional and uninformed, interest in the procedure. As a lethal pandemic could occur after just one xenotransplant, and given the massive financial resources those involved in xenotransplantation have at their disposal, we find it dangerous and unacceptable that the Minister of Health be allowed to potentially approve a xenotransplant. Especially given the current state of our “health system”. Further a ban on xenotransplantation research not necessarily involving humans must also be put in place immediately.

1) The restriction on xenotransplantation in Part 3 is necessary due to the potential danger from this procedure. The principal danger is outlined as follows:

1.1) 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.

1.2) 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).

1.3) 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.

1.4) 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).

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

1.6) The potential for the unleashing of a lethal epidemic exists… it needs only one xenotransplant.

2) A moratorium as the precursor to an outright ban of xenotransplants will give the regulatory and other agencies time to put in place an education programme to inform the public of the danger (as outlined above) from xenotransplants. This programme will be necessary to counter the expected attempts at manipulation of public opinion by those with vested financial interest in the procedure.

If organs were to be genetically-engineered and marketed, it has been estimated that (prior to any surgery or hospital charges) they may cost between $US 100,000 to $US 500,000 each. (Greek & Greek, “Sacred Cows and Golden Geese”, Continuum, 2000)

The editor of Nature has stated:

“The momentum toward clinical trials of xenotransplantation is seemingly unstoppable, powered as it is by… multimillion dollar investment by biotechnology companies… politicians would do well to err on the side of caution, and agree on an international moratorium on clinical trials.”
- Nature Vol. 391, p.309

These vested interests will not hesitate to use the emotionally affected and uninformed to attempt to derive some sympathy and false glory from the public by way of public relations manipulations. The education programme must aim to counter such misinformed claims.

3) Section 96 proposes to grant the Minister of Health the power to authorise xenotransplants. Xenotransplants must be exempt from this power, given the above-outlined financial interests. Further one has to only look at the current perilous state of our so-called “health” system (more accurately described as a ”sickness system” to quickly lose faith in the Minister’s ability to adequately assess risks.

The current “health” system is based on animal-based research. Animal research cannot work because….

• 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.
• Human diseases cannot be recreated in animals – or in human beings for that matter – simply because, once a disease is “recreated”, it is artificial and is no longer the original, natural disease that the body itself produced. For example, if you don’t have epilepsy, no one can give it to you, and much less to a non-human animal. The exception to this is the case of infectious diseases. However, animals do not get human infectious diseases. Among other reasons, there are huge differences between the immune system of humans and that of other animals (rats live in sewers, dogs drink water from puddles, and cats lick dirt off their bodies without getting sick!).
• Increasing numbers of doctors and scientists agree that the only way to deal with our mounting health problems is to engage in prevention and clinical research (the observation and treatment of human beings suffering from human diseases).
• Consequently,our economic survival is also at stake. New Zealand spends over six billion dollars each year on what is euphemistically called “health care”. The fact is that, after more than 100 years of massive animal-based research at a cost of countless billions of dollars, crippling and deadly diseases of all kinds are affecting an ever-increasing number of New Zealanders. Far from curing anything, we are losing ground in the fight against cancer, cardiovascular diseases, diabetes, AIDS, muscular dystrophy, multiple sclerosis, Alzheimer’s disease, and birth defects, just to mention a few. Soaring “sickness care” costs are bankrupting our economy.

Given the current state of our ‘health’ system, it would surely totally collapse in attempting to deal with the effects of a xenogeneic virus in the human population.

4) This Submission has 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) have not been addressed in the body of the submission but are summarised in an appendix.

5) As the dangers of xenotransplantation are not restricted to xenotransplants involving humans, there must be an immediate ban on xenotransplant research.

Phil Clayton
National Secretary
New Zealand Anti-Vivisection Society Incorporated
January 2002

Attached (to original submission) Appendix: Medical Research Modernization Committee (USA), “Of Pigs, Primates and Plagues – A layperson’s guide to the problems with animal-to-human organ transplants”, Guardian Newsletter, Vol. 3, No. 11, Summer 1997, pages 16-18. This article is a summary of a more comprehensive report. Copies of the report are available from NZAVS.

The summary is on-line here:
http://www.mrmcmed.org/pigs.html

The full report is on-line here:
http://www.crt-online.org/mrmc.html