Feminist International Network of Resistance to
Reproductive and Genetic Engineering
The Honourable Peter Heerey QC
National Health and Medical Research Council
GPO Box 1421
Canberra ACT 2601
Dear Judge Heerey,
The Feminist International Network of Resistance to Reproductive and Genetic
welcomes the opportunity to make a Submission
to the Review of the Operation of the
Prohibition of Human Cloning for Reproduction
Research Involving Human Embryos Act 2002.
On 30 September 2006, we
sent a detailed Submission
Prohibition of Human Cloning for Reproduction and the
Regulation of Human Embryo Research Amendment Bill 2006.
For this reason, we
will not repeat all our arguments
, but instead provide you
with a Summary of our main
Please do not hesitate to contact us if you
require more information
Dr Renate Klein
c/o PO Box 920
North Melbourne Vic 3051
0438 00 29 79
FINRRAGE (Australia) is part of international FINNRAGE which has been in existence
since 1985 with critical feminist assessments of
context (see www.finrrage.org).
: SUMMARY of Concerns regarding
Prohibition of Human Cloning
for Reproduction Act 2002
Research Involving Human Embryos Act 2002
Human Stem Cell Research
e not been kind to stem cell re
, both in Australia and overseas
all their promised cures for debilitating diseases through
and especially thro
ugh somatic cell nuclear transfer (S
the 2005/6 revision of the Act
none have eventuated.
In 2002, the Australian Government endorsed Monash University’s Australian Stem Cell Centre
(ASCC) as its Biotechnology Centre of Exc
ellence. The government granted the A
stately sum of $ 115 Million
Taxpayers might have expected
the ASCC to provide
some of the promised ‘miracles
they have been disappointed.
Instead, modest successes from research on adult stem cells and, since 20 November 2007,
induced pluripotent stem cells (iPS cells), appear to have made embryonic
stem cell research
especially SCNT research
undant. We are tempted to use a certai
to declare it ‘dead, buried and cremated’.
Even Alan Trounson, former ASCC director
and now Director of the Californian Institute of Regenerative Medicine (CIRM)
California, declared in a radio interview
on a visit to Australia in 2009 that induced pluripotent
stem cells (iPS cells) will make the need for human embryonic stem cells (hES) unnecessary
(quoted in Skene 2009).
we wait to see the long
term success of both adult stem cell and iPS
have one big advantage:
there is no need for women to provide eggs
SCNT cloning had already
lost much of its shine in 2005 with the revelations
Dr Hwang Woo
suk in South Korea
SCNT stem cell lines and ha
a large number
is own junior female researchers
‘agreeing’ to ’donate’
their eggs. Hwang used a staggering 2061 eggs fr
om 129 women (in
Sexton 2006, p.
almost 16 eggs per woman.
We will now turn to
FINRRAGE’s main concern with
hES and especially
it poses to young women who
to ‘donate’ the required ‘good quality’ egg cells.
2. The dangers of egg provision for (young
Since the 1980s
FINRRAGE has asked, again and again, for studies about the drugs used in IVF
ted technologies on women’s health.
one have been forthcoming despite
the NHMRC 1995 recommendations in its report:
term effects on women from assisted
, to undertake a study of the health of women who went through IVF
Thus women who are asked to ‘donate’ eggs do this in the absence of any
However, women’s health activists from around the globe
have witnessed and written about
term dangers to women’s health
from these technologies
, especially drugs
The word ‘donate’ is a misnomer. Egg provision is a lengthy and dangerous process that
involves both drugs and surgical extraction. It is very different from the donation of sperm.
Hence our use of
An excellent overview of adverse effects from IVF and associated technologies can be
found in Diane Beeson and Abby Lippman (2006) ‘Egg harvesting for stem cell research:
Ovarian Hyperstimulation Syndrome (OHSS) is the most da
term health risk.
lead to strokes and even death.
In her award
winning 2011 documentary ‘Eggsploitation’
filmmaker and President of
he Center of Bioethics and Culture Network,
summarises these risks in an interview with Melinda Tankad Reist
term risks of ovarian hyperstimulation syndrome (OHSS) which can be mild,
moderate or severe cannot be underestimated and pose a real danger to the health of the
egg donor. There is a risk of infection and bleeding related to har
vesting the eggs. One
woman in the film suffered a major brain stroke, another had a torsioned ovary requiring
its removal. Another woman had internal bleeding because of a bleeding artery near the
ovary, which went undiagnosed for many hours. She ended up
in intensive care. Longer
term risks are associated with cancers (reproductive and non
We strongly recommend the Review Committee view Jennifer Lahl’s Documentary which not
only shows the exploitation of women in ‘eggsploitation’, but pu
the defence by
supporters of SCNT research and egg ‘donation’ that the women are adults who can make their
‘informed choice’. We suggest that when there is an absence of peer reviewed studies on health
effects from IVF technologies, no woman, ho
wever intelligent, can make an ‘informed choice’
because, quite simply
this procedure to her does
the research to back up his or her claim that egg ‘donation’ is safe.
We also strongly concur with L
that egg ‘donation’
commodifies women as they are
only seen as ‘raw material’ for research.
3. Payment for Eggs?
In the light of the above
he failure of human
2. The dangers
of egg provision for (young) women,
we are more than puzzled
to hear that there is a move amongst some peo
ple to have the Act changed
so that payment for egg
‘donors’ will be able to occur. Indeed, we are
quite taken a
back that Professor Loane Skene
o has publicly raised this
ee Skene, 2009) is a Member of
this Review Committee. It
is our strong hope that Profe
ssor Skene will absent herself
from any discussions on this topic
during the Review Process so as not to
influence other Committee M
Apart from our arguments made
we will further
that there is no
for egg cells by Australian researchers, as the few issued
Embryo Research L
show (see 4. below)
. Apart from this, we kno
w from countries where
for egg cells is
legal that it is overwhelmingly poor women who ‘volunteer’ for egg provision
as it supplements
their often meagre income. This has be
en particularly well documented
where UK fertility c
linics access local poor women and buy their eggs
European Parliament, 2005
). There are poor women in Australia too
and due to rise because of
poor immigrants and
financial woes associated with the 2011 floods and cyclone
surely no self
vernment could agree to further exploitation of
medical risks and ethical problems’.
Reproductive BioMedicine Online
also George (2008) and Klein (2008).
These cancers include ovarian, uterine, endometrial and breast cancer. Women who ‘donate’ eggs can also
lose their own fertility.
4. Cloning Licenses
After the 2006 Amendments to the Act that allowed for SCNT research, one would
have expected to see an explosion of applications for SCNT research as its promoters
the Australian public that they were desperate to engage in such
research for which ‘fresh’ egg cells
healthy and fertile women
needed (with only one set of chromosomes which is different from
two sets in
over fertilised IVF embryos).
2009, only 3 out of 10
The NHMRC’s 2008
9 Embryo Research Licensing Report
all from Sydney IVF.
allowed to be created
for the whole life of the
to the end of
March 2009, 7 ‘other’ embryos
created but without producing any
embryonic stem cell lines (the longest development was an 8
The latest NHMRC Report that covers the period from
shows 9 current licenses
(8 from Sydney IVF, 1 from Melbourne IVF)
projects, all from Sydney IVF.
Out of the permitted
1640 excess ART embryos
527 had been used during the life of the project
(46 in the 2010 reporting period).
urning to the 3
SCNT projects, w
e are astonished by t
he high number of
permitted to use
in each project (7200 total)
and wonder who decided on
this high number and for what reason.
The 2010 NHMRC Report states that a total of 389 eggs h
ave already been used for
these 3 SCNT projects (p. 10) (64 in the reporting period) and
that they were all
clinically unsuitable eggs
(p. 7 and 8; used in License Number 309712 and 309714,
both from Sydney IVF).
And the allowed creation of
in the 3
SCNT projects we
Again we ask: who decided on this number and why? In
‘other embryos’ have been created (11 during the
As in 2009,
the longest development was an 8
cell stage b
embryonic stem cell lines
It is unclear
whether the 389
clinically unsuitable eggs
resulted in the
32 so far
listed on the same page of the report (p. 10)
. As there is no mention of
women ‘donors’ in th
e Report, should we assume
that so far
no specifically ‘donated’
eggs from women who were not undergoing IVF have been used
from women providers rather than
‘unsuitable eggs’ (presumably from IVF)
ould be noted in the NHMRC’s Licensing Committee reports? Surely,
Interestingly, the ASCC never had an embryo research license: so much for the Key
preeminent position in Australia’s human stem cell scie
nce (and taxpayers’
there would be comments on their state of health during and after said egg provision
So, we wonder what exactly is the raw material for the
32 ‘other embryos’?
In sum, with
current embryo research licenses, 8 granted to Sydney IVF and
human embryonic stem cells from the 3 SCNT research
e suggest that at the least any
present and future
SCNT research projects be
• As we have shown above,
SCNT research projects in Australia have not
embryonic stem cell lines
alone ‘miracle cures’. This research
should be abandoned and
declared ‘dead, buried and cremated’.
• Failing to stop SCNT research projects, we suggest
the number of ‘other
authorised to be created’ and restricting them to be
from women already undergoing IVF
are already (or will be in future)
‘harvested ‘ from
the NHMRC Research Licensing Committee
has an obligation to
demand a detailed
rocedure, and any complications
reover, the woman’s
health must be monitored following
and if there are long
term effects, then life
free health care (paid for by the r
searchers) should be mandatory.
All of this needs to be
• The Reports from the NHMRC Research Licensing Committee have to become more
transparent and clearly specify the source of the egg cells used for ‘other embryos’.
• Payment for egg ‘donation’
We urge the NHMR
C to finally deliver on its 1995 promise and begin retrospective studies of
the health of women who underwent IVF since its beginnings in the late 1970s.
Other potential sources of human eggs are ovaries that
ble when a
woman undergoes a total hysterectomy. Researchers have also suggested that unripe eggs
from the ovaries of aborted foetuses could be matured in the laboratory and then used for
research. We presume, however, that
in good faith
the NHMRC report w
ould have listed
We also remain opposed to the creation of animal /human embryos which we consider
Given the health risks involved in IVF we certainly do not endorse its practise. However,
since women w
ill continue to submit to IVF and there will be many eggs extracted that are
‘unsuitable’ for fertilisation, their use in (futile) SCNT projects is preferable to the
exploitation of non
IVF patient providers.
Beeson, Diane and Abby Lippman
. ‘Egg harvesting for stem cell research:
risks and ethical problems’.
Reproductive BioMedicine Online
, 13, pp. 573
European Parliament. 2005.
Resolution on the trade in human cells
Planned egg cell trade OJC320#, p. 251.
George, Katrina. 2008. ‘Women as collateral damage: A critique of egg harvesting for
Women’s Studies International Forum
, 31(4), pp. 285
. ‘From test
tube women to bodies without women’
, 31(3), pp.157
Melinda Tankard Reist.
‘Eggsploitation: a devastating case against the
commodification of women and eggs’,
Interview with Jennifer Lahl
National Health and Me
dical Research Council
on women from assisted conception
Commonwealth of Australia: Canberra.
National Health and Medical Researc
h Council (NHMRC). 2009. ‘NHMRC Embryo
Research Licensing Committee. Report to the Parliament of Australia.’
2008 to 31 March 2009,
, Commonwealth of Australia:
National Health and Medical Research Council (NHMRC). 2010.
Research Licensing Committee. Report to the Parliament of Australia.
1 March 2010
to 31 August 2010
, Commonwealth of Australia: Canberra.
Sexton, Sarah. 20
05/updated 2006. ‘Transforming “Waste” into “Resource”: From
Women’s Eggs to Economics for Women’. The Corner House, UK.
‘Why not pay women to donate their eggs for
(accessed 15 March