Mon, May. 06, 2002
By Lisa M. Krieger
While research on embryos is under attack by politicians here in the United States, it is moving forward elsewhere in the world.
How research proceeds -- that is, what rules apply -- varies from nation to nation, reflecting each country's unique mix of historical, religious, cultural and political influences.
On one end of the spectrum is China, where scientists have cloned dozens of human embryos with few ethical qualms. On the other end is Ireland, where deeply held religious convictions make all such research repugnant.
The vast majority of nations are between the two extremes. Almost none advocate the cloning of an embryo to create a person. But after much soul-searching, most nations are deciding that embryo research aimed at enhancing human health should proceed, with restrictions.
In making those tough decisions, they are balancing ethical and cultural concerns against the promise of a powerful technology that could cure disease.
Embryos contain stem cells, coveted by researchers. These cells are human physiology's most basic starting point, from which grow the body's various tissues and organs. Stem cells have kindled hopes for new treatments for Parkinson's disease, Alzheimer's and other killers. But extraction of the stem cell destroys the embryo.
Embryos created by cloning genetic material from a patient's own cells have a special advantage: They could furnish stem cells that, when grown into a useful tissue or organ, would not be rejected by the recipient's body.
While any treatment based on embryo research would undoubtedly be welcomed, even by citizens of countries that now ban or restrict such research, nations that choose not to participate in research could find themselves left behind -- losing not only economic benefits, but also some of their brightest scientists, who might choose to move where there are fewer restrictions.
"Most of the international community is moving toward research and therapeutic uses of embryo-derived cells with serious scientific intent," said Laurie Zoloth, a bioethicist at San Francisco State University. "The healing imperative drives much of the research in countries other than the U.S."
Some countries allow research only on surplus embryos that are left over from fertility treatments. Others allow the creation of embryos specifically for research, either by cloning or by the more conventional method of joining an egg and a sperm in a petri dish.
In the United States, the fight over cloning has grown into one of the most emotional issues facing Congress this year. The House passed a broad ban on cloning in July; the Senate, which is expected to take up the issue later this month, is sharply divided.
It is a measure of how offensive this research is to some Americans that a Senate bill proposed by Sen. Sam Brownback, R-Kan., would criminalize the use of cloning-derived therapies, imposing a $1 million fine and up to 10 years in jail on any person who imports a product made through cloning. Anti-abortion activists have made passage of the Brownback bill their top legislative issue. Last month, President Bush called for a total ban on cloning, saying: "The use of embryos to clone is wrong. We should not, as a society, grow life to destroy it."
While U.S. work on stem cells moves forward in private laboratories, publicly funded research has been restricted by limited money and a presidential prohibition on the derivation of any new cells from embryos. Any expansion of U.S. research during this administration seems unlikely.
Treatments that might have been created in the United States, with strict regulatory oversight, will simply be done elsewhere -- perhaps under less rigorous standards, bioethicists caution.
"The debate is not whether it will happen, but where," said Arthur Caplan, director of the Bioethics Center at the University of Pennsylvania in Philadelphia. "If someone finds a cure, it will come here."
Reason for differences
History helps explain why some nations take a go-slowly approach to embryo research, while others want to accelerate, said Caplan, who in March moderated a weeklong meeting of the new United Nations Committee on an International Convention against the Reproductive Cloning of Human Beings.
Few countries have struggled with the ethical implications as much as Germany, which is haunted by the Nazis' grisly legacy of experimentation in eugenics between 1940 and 1945. Under the Nazi program to rid the society of people considered lebensunwertes Leben -- life unworthy of life -- hundreds of disabled children were used for medical experiments, then killed with large doses of barbiturates.
"The eugenics movement during the time of national socialism and also the abuses committed by scientists and physicians during that same time are a shadow over the country until the present day," said LeRoy B. Walters, professor at the Kennedy Institute of Bioethics at Georgetown University in Washington, D.C.
"There is very strong resolve not to let the misuse of human subjects occur again," he said.
So it is little surprise that modern-day Germany has banned its scientists from extracting cells from embryos or creating cloned embryos for research. It does permit them to do stem cell research -- as long as the cells are imported, derived from another nation's embryos. Austria also favors research restrictions.
But other nations see things differently.
Countries whose populations are ravaged by infectious diseases such as malaria, tuberculosis or AIDS may be more willing to accept biotech-based solutions, even if based in embryo research, Zoloth said.
Influence of religion
Religion also plays a huge role.
In countries where anti-abortion religious beliefs have a strong influence -- Ireland, Italy, Germany, Norway, Argentina and the United States -- the moral status of embryos is at the center of debate. Because the Roman Catholic Church supports the protection of human life from the moment of conception, nations with large Catholic populations generally oppose such research.
When scientists at Ireland's Adelaide Hospital called on the government to allow research on embryos up to 14 days old, opponents charged that "the purpose is to bring a Protestant medical ethos to the issue." The ban on such research still stands.
For many religions, however, an embryo in a test tube is not the moral equivalent of a baby, according to Zoloth.
"Not only is the view of the early embryo different in countries without a large Roman Catholic influence, the primacy of the duty to heal outweighs many other considerations," she said.
"In many countries, such as Israel, healing the sick, saving lives and doing research to save lives is not only a national priority, it is a deeply embedded commandment of the Jewish faith. Scientific and medical advance can be understood differently, as a progressive and critical tool," she said.
Israel has become a leader in stem cell research; its national bioethics committee also supports research in cloning that could lead to therapies.
Similarly, Singapore's Bioethics Advisory Committee recently decided that the nation is justified in using early embryos for research that may benefit others. Such embryos cannot feel pain because their nervous systems have not started to grow, it said.
"In cultures where Buddhism or Hinduism or Confucianism is strong, there is less focus on the moral obligation to the very early embryo than there is among conservative Catholics and Protestants," said Walters of Georgetown University.
In China, Singapore, India and Japan, "the argument about the moral status of embryos doesn't count. It's not in their religious tradition," Walters said.
Muslim bioethics are based on principles, duties and obligations rather than individual rights. Most Muslim scholars suggest that embryos are endowed with souls at 4 months plus 10 days of age. For these reasons, embryonic stem cell research is supported in the Islamic community.
Hindus believe that embryonic stem cell research may be acceptable if it saves lives. While Buddhists generally do not support research on surplus embryos from fertility clinics, they accept research conducted on already-aborted embryos with the intention of finding cures for disease.
"If you talk about the embryo as a person, that's not the majority view. President Bush may believe it, tens of millions of Americans may believe it, but the majority of the world doesn't believe it," said University of Pennsylvania's Caplan. "The rest of the world thinks of us as the leader in technology. So when we sound so fearful about biotechnology, people get puzzled."
In Sweden, a strongly secular nation, "the right to use contraception and the right to have an abortion are not political issues but are considered fundamental rights," says Kathinka Evers of the International Council for Science Standing Committee on Responsibility and Ethics in Science in Oslo, Norway, in the current issue of the New England Journal of Medicine. "As long as a fetus can be legally aborted, it has no rights."
Sweden has emerged as a front-runner in stem cell research, and has permitted research on existing embryos for years. The largest number of stem cell lines -- 24 -- come from Sweden.
But the country does restrict where these cells come from. Officials there reason that creating embryos through cloning is acceptable, because it provides a unique source of matching tissue for patients. But they don't support creating embryos through more conventional techniques, such as fertilizing an egg in a petri dish. Since there are plenty of surplus embryos at fertility clinics, why create more?
Cuba is another secular nation that supports stem cell research and human therapeutic cloning. "Religious views do not shape anything they do," Caplan said.
Pragmatism also plays a role in Cuba's attitude, he added. "Cuba thinks they can make a contribution because it is so new that no one else has a big lead."
Singapore smells opportunity, as well. Already committed to computer technology, the country's officials see biotechnology as a field in which it can excel. Said Caplan: "Singapore sees itself as a city-state with no natural resources. It has no land to farm. But it has brains. So the government is pushing hard for biotechnology."
China's policymakers see cloning as a potential tool for extending the human lifespan, cutting medical costs and delivering better medical care. So Beijing has invested heavily in the biotech industry, setting up a national fund to finance researchers and lure top Chinese scientists familiar with the latest technology back home from abroad.
Even Germany, which bans cloning and embryo research, shares the fear of being left behind. Officials there fashioned a compromise: Stem cell lines can't be created, but may be imported from other countries for research.
"It is the most conservative compromise you could make and still have the research go forward. They understand that if you don't make a consensus, scientists will go ahead and do research elsewhere," Walters said. "Its leaders and scientists know very well this research will go forward in the United Kingdom and Israel and China, and in the private sector in the U.S."
Science vs. politics
The United States struggles with political polarization seen in few other nations.
"There are two sharp differences between the U.S. and Britain," said Thomas H. Murray, president of The Hastings Center in Garrison, N.Y., a bioethical think tank. "First, although there is a right-to-life movement in Britain, it is nowhere near as politically powerful as its U.S. counterpart. In addition, the party in power in Britain is not beholden to the right-to-life movement the way the Republican Party is here."
Unlike the United States, the United Kingdom has designated a national authority to oversee embryo research. Debate on the embryo was carried out years ago, resulting in a decision to allow research on embryos up to 14 days old. In a more recent vote, British politicians agreed to allow creation of cloned embryos; the first licenses were issued to researchers last month.
Canadian developmental biologist Janet Rossant, who chaired a panel that guided the Canadian Institutes of Health research, writes that in her country, "opposition groups aren't as organized politically, lobbying is less important and the government has a strong majority in Parliament."
Bioethicists agree that the most troublesome scenario of all may be a deadlock in the Senate on the cloning issue. If Democratic and Republican proposals cannot be reconciled, no regulations will be put in place to govern any type of cloning research. In an unregulated environment, a nation that often sounds like Ireland may end up looking like China.
"One awful but entirely possible outcome of the current legislative debate," said Murray, "is that we may end up with nothing at all."