The U.S. Conference of Catholic Bishops (USCCB) sent a detailed letter to the National Institutes of Health (NIH) outlining the reasons why they oppose the Institute’s plan to rescind a moratorium forbidding federal funding of human/animal chimera embryo research. This research will involve injecting human embryonic stem cells into animal embryos to create beings who will allegedly help scientists to grow human tissue and organs in animals which will aid in studying human development, disease pathology and eventually organ transplantation. 

However, as the bishops correctly point out, using embryonic stem cells hasn’t worked very well thus far, and this new plan only causes more problems.

“The government has already crossed a significant moral line by treating the destruction of human beings, at a very early stage of development, as the raw material for allegedly useful human embryonic stem cell (ESC) research. Such research has failed to produce treatments for human ailments over the last 17 years, and morally noncontroversial avenues such as adult stem cell and induced pluripotent stem cell research have surpassed ESCs in scientific and clinical benefits,” states the letter, which was written by Anthony Picarello, USCCB associate general secretary and general counsel, and Michael Moses, associate general counsel.

“The government now proposes running roughshod over another basic moral principle, however, by injecting human embryonic stem cells into the embryos of various animal species to create beings who do not fully belong to either the human race or the host animal species.”

This presents a serious moral issue. "For if one cannot tell to what extent, if any, the resulting organism may have human status or characteristics, it will be impossible to determine what one's moral obligations may be regarding that organism."

Among the experiments eligible for federal funding under this proposal are:

1. Introducing human pluripotent stem cells into non-human primate embryos after the blastocyst stage;

2. Introducing such human cells into any animal species “where the introduction of human cells may contribute to the germ line,” as long as the resulting being is not allowed to engage in “breeding”;

3. Introducing these human cells into non-human mammalian embryos “such that there could be either a substantial contribution or a substantial functional modification to the animal brain by the human cells.”

Catholic morality allows for "the respectful use of animals in research that can benefit humanity. But because of the unique dignity of the human person, there are limits to what can morally be done…” the lawyers state.

They go on to list the ways in which chimera research violates ethical principles: "It relies on the destruction of human embryos; it contemplates producing entities with partly or wholly human brains (without any additional level of scrutiny in the case of rodents); and it allows for producing living entities who have human gametes (though researchers will be told to take precautions so these entities do not engage in 'breeding')."

But, as Picarello and Moses clearly state, these practices aren’t just a matter of violating Catholic moral principles – they’re also against the law.

"[T]he dignity and inviolability of human life at every stage of development is a foundational principle of any truly civilized society," they write. "The core ethical norms protecting human research subjects, affirmed in the Nuremberg Code and many subsequent documents, reflect this principle. The right not to be subjected to harmful experimentation without one's express and informed consent is an innate human right…."

However, in proposing to do away with the moratorium on this kind of experimentation, the federal government is also ignoring the fact that federally funded research of this kind is prohibited by Federal statute. They cite the Dickey Amendment, which forbids the use of federal funds for research on embryos or “any organism, not protected as a human subject . . . that is derived by fertilization, parthenogenesis, cloning, or any other means from one or more human gametes or human diploid cells.”

Not only is this research grossly unethical and illegal, the current NIH proposal would not prevent the most egregious abuses, such as the production of non-human animals with substantially human brains or gametes, Picarello and Moses state, but explicitly contemplates funding some of these abuses.

In addition, “The NIH does not indicate that sufficient research has been conducted using solely animal sources, such as stem cells from nonhuman primates, before funding research that could definitively blur the boundary between human beings and non-human animals. As such, even by longstanding NIH policy, and aside from the moral objections we raise herein, the current proposal is seriously flawed. For all these reasons, the proposal should be set aside.”

The public comment period on this issue closed on September 6 and a decision on the lifting of the moratorium is expected shortly.

The full text of the comment letter is available here. ---