October 15, 2013
Christian Medical Association
PO Box 7500
Bristol, TN 37621
Food and Drug Administration
Center for Biologics Evaluation and Research
1401 Rockville Pike, HFM-71
Rockville, MD 20852
Transmitted via email to Gail.Dapolito@fda.hhs.gov
RE: Public comment submission to the Cellular, Tissue and Gene Therapies Advisory Committee, regarding its consideration of oocyte modification in assisted reproduction for the prevention of transmission of mitochondrial disease or treatment of infertility
The 16,000-member Christian Medical Association (CMA, www.cmda.org) opposes germ line genetic engineering on prudential, ethical and humanitarian grounds:
1. Mitochondrial transfer poses an unacceptable prudential risk, since our nascent knowledge of genetics remains grossly inadequate to predict unintended genetic consequences passed down to future generations.
2. Germ line genetic engineering also transgresses the ethical principle of autonomy; no successive generation can provide informed consent for the consequences of the precursor generation's genetic experimentation.
3. Techniques such as "pronuclear transfer"--a method of cloning from an IVF embryo--involve destroying living, genetically complete human embryos, further violating moral and ethical boundaries.
4. Procedures involving germ line genetic engineering are not essential, since ethical options remain for women with an identified high risk. Providing a loving home for a child through adoption, for example, far surpasses any perceived value of retaining a measure of genetic relation attained at the risk of tragic genetic consequences.
5. Opening the door to germ line genetic engineering also opens the door to the dehumanizing, utilitarian quest for perfect children--"designer babies." Rather than treating children as a commodity fulfilling parents' dreams, our humanitarian values and our Constitution require us to treat every human being as inherently valuable and worthy of love, respect and protection.
We urge the Committee to reject oocyte modification in assisted reproduction as unacceptably risky, unethical and inhumane.
Thank you for your consideration of these views.