Animal-to-Human Transplants (xenotransplantation)
National Health and Medical Research Council of Australia (NHMRC) DRAFT GUIDELINES ON XENOTRANSPLANTATION  
        
Submission to the NHMRC
by Ratifiers for Democracy
(this paper prepared by Toshi Knell)
28 August 2002
(slightly modified for web posting)
The greatest public health issue of our time is both global, unpronounceable, and unknown: xenozoonosis from xenotransplantation.
The Guidelines pose the question:

Is Xenotransplantation Safe?

Xenotransplantation is unusual among medical procedures because it carries risks for the wider community as well as for the individual patient. The major concern for public health is that viruses from animal xenotransplantation products may infect human transplant recipients. Retroviruses or other unknown, probably latent, viruses are the chief concerns. Such viruses may initially show no obvious signs of disease and may spread beyond the recipient into the general population, giving rise to an epidemic that only becomes obvious when others have been infected.

That not even the medical profession considers this a hot topic, is partly a measure of how  the issues in biotechnology have been debated on theological and sensational grounds, and partly because even the most concerned scientists are worried about being labelled Luddites if they bring up the disease risk from crossing species. But we need to face fact that diseases passed from animals to man are on the rise, as they are between different animal species today, and that any technology that works by increasing the factors that increase the rate of that rise is a technology about which we must have at the least, grave second thoughts.

Nature editorialised this issue, August 17, 2000, writing "the public consequence could be catastrophic … Animal viruses can also change unpredictably when they jump the species barrier."

As Jonathan Allan, a virologist at the Southwest Foundation for Biomedical Research, states, zoonotic viruses "can lurk in the body for years before causing any symptoms. Once it splices itself into the host genome, it is virtually impossible to get it back out." [2]

The BSE Inquiry [3] levied much criticism for allowing disease to jump the species barrier, a topic that came up 222 times in the report. 

The science of xenotechnology is the very tearing away of the species barrier. In xenotransplantation, rejection problems, both immediate and delayed, the removal of the species barrier is not sufficient to stop organ rejection. Two further methodologies are then used to trick the human body into accepting the foreign material. Immunosuppression is one method, and inserting human DNA into pigs, the other. Both methodologies act to insert even more capability into the host to support zoonoses.

Peter Collignon, Canberra Clinical School, Sydney University, Director Infectious diseases Unit and Microbiology, the Canberra Hospital, wrote:

"What if we were trying to design the ideal experiment in which a new virus that would infect humans would be cross-transmitted from pigs to humans? We would be hard pressed to come up with a better experiment than what is planned to be done with xenografts (and on a massive scale). Currently there are plans for large numbers of genetically engineered pigs to be developed whose outer cell membranes will be altered so they more closely mimic the antigens found on human cells.  Any new animal viruses that multiplied would therefore likely be covered in human antigens rather than porcine antigens.  Organs (and the viruses they contain) from these pigs will then be transplanted directly into normally sterile sites bypassing important barriers in humans that protect us from animal viruses (eg intact skin and intestinal mucosal surfaces).  These patients will also be very heavily immunosuppressed.  This will mean that even if some of these animal viral antigens are recognised, the probability of the virus being destroyed will be significantly compromised." [4]

Thus far, xenografting does not work because of the massive fight that the human body puts up. The efforts to make the body accept  by heavily immunosuppressing only increase the vulnerability to disease of the human recipient, and the potential for xenozoonoses.

Therefore, as the Guidelines explain: "a major thrust of current research programs involves the genetic modification of donor animals with some key human genes so as to prevent their tissues from being recognised as 'foreign' by the immune system of the human transplant recipients."

 We know that we still know remarkably little about the mechanisms of disease, and continually surprise ourselves with new zoonotic capacity discoveries. [5]We don't know how to stop or prevent a plague other than by extreme means such as the way we dealt with the Mad Cow threat. Yet it isn't exactly human genome sequencing to look at the technology of xenotechnology, and add up the factors involved. Susan Wolsborn, an artist for Elsevier Science, put it this way. "The very method (genetically modified pig-people ... or peoplish pigs ... or something'r other) researchers are using to trick human immune systems to accept xenotransplants will increase the risk of (well, let's be honest, speed up the pace of) disease transmission."

As for recipients transmitting xenozoonoses, the longer a recipient lives, the more danger of xenozoonosis developing and being transmitted. The recipient therefore becomes a carrier of an unknown collection of pathogens, and a vector for an unknown number of diseases passed from another species, to our own. The humanised pig is also a zoonosis problem, and the known problem of animal handlers contracting zoonoses increases when there is a level of both secrecy and commerciality that means that infected animals and their handlers could be a problem hidden from the public for some time, even if authorities do manage to find out about it and do something. [6]

 The Centers for Disease Control (CDC), Atlanta, raises even more points, in its answer to the question,

"Do xenogeneic infections constitute a threat to the health of the greater community?"

     Once introduced into humans, zoonotic viruses that are not particularly pathogenic in their host species           have resulted in noteworthy outbreaks…..Thus, the world experience with zoonotic viruses provides substantial evidence for the potential of epidemic human infection due to xenogeneic infections. It is this potential that makes them a public health concern….   

     Experience with zoonotic diseases suggests that mechanisms of evolutionary adaptation exist in both microbes and their natural hosts. The disease-producing potential of an infection is a function of the relationship between the host and the infecting agent and not of the microbe alone. As a result, the pathogenic potential of an infection can change in an unpredictable fashion when the infecting microbe is transmitted from its natural host into a new species….

     The short life expectancy of the average swine minimizes the opportunity to observe clinical manifestations that might result from infections with agents characterized by long periods of clinical latency such as retroviruses or prions. The potential for endogenous retroviruses in transplanted porcine tissue to infect immunosuppressed human recipients, rescue replication-defective viruses or recombine with latent human viruses to create a pathogenic hybrid is unknown. We were only framing these questions, the science hasn't been done to give answers to them.

….our experience with zoonotic diseases, in particular our developing understanding of the origins of the human AIDS pandemic, have lead to the framing of new questions regarding the potential for the use of animal tissues in humans to introduce new infections of public health importance into the human community. Little scientific data exists to assist in addressing these questions." [7]

 The CDC brought up an important point here that has not been addressed by the NHMRC at all. The pig's lifespan is so short that that is another reason we do not know what the pathogenic capacity is, since they die too early for many diseases that need a longer incubation period to manifest themselves. And if the pig's life span is a problem, imagine the problem with rodents, yet they are commonly used now, in the also undiscussed rampant amount of barely regulated and fall-through-the-cracks-of-regulation xenotechnology occurring today in Australia and around the world.

The concerns of the Centers for Disease Control are not, however, how xenotransplants are being addressed. "Interview with a Humanoid" in the New York Times in July, is how the technology is portrayed. The writer, an influential essayist, wrote about no biological risks because he didn't know of any.

      In a secret, locked barn near DeForest, five black-and-white calves look up from their hay with huge, friendly eyes. No. 313 approaches, as if to grant an interview, for these are not the ordinary bovines they seem — all five are part human….

     Biotechnology is transforming the world around us, far more quickly than we can build a regulatory structure to accommodate it. Human cloning gets the attention, but for the next 15 years the greater impact will arise from the genetic manipulation of animals.

     Biotechnology faces crippling obstacles, including a drought of venture capital that will kill off plenty of companies. But eventually, genetically modified pigs (perhaps slightly human in their genetics) will be able to produce livers, kidneys, hearts and pancreases for ailing patients." These technologies could help the 80,000 Americans now on waiting lists for organ transplants…." [8]

 

Xenotechnology exposes the species to an historically unprecedented level of species mixing and epidemiology outcome unknowns, at a time when we still do not have the social structures and science to cope with the rising disease burden that we have, and while we concurrently face both antibiotic resistance, ageing populations (that increasingly clump together) in the rich countries where the xenotransplants are being promoted, and unprecedented globalisation. In no country considering xenotechnology could there be considered to be a health care system that citizens think works well enough, and in a trustworthy manner, though if we compare Australia to both the UK and the United States, it would come out splendidly. If what researchers hope won't occur, does occur on any scale, let alone a "catastrophic" scenario, how would a xenozoonotic outbreak compare to the BSE experience, which, in pandemic terms, has been very mild?

 A joint WHO/FAO/OIE conference on BSE stated:

"It can be affirmed that never before in history has a health event of animal origin given rise to so many debates (as BSE), controversies, and economic and social upheavals within and outside the agricultural world. However, the impact of BSE on herds is insignificant in relation to other epizootics (less than 200,000 cattle affected over 15 years out of a global livestock population of nearly one-and-a-half billion). Furthermore, at the current stage of observations from the epidemiological surveillance of human populations, the impact is far from the level of ravages on humans caused by major zoonoses, such as rabies, echinococcosis, tuberculosis or brucellosis….

The delay created by the long incubation of the disease and the delay in acquisition of scientific knowledge creates a void. Faced with this void, international organisations and national decision-makers find it difficult to propose timely and appropriate decisions relating to risk management."  [9]

Because disease has different periods of dormancy, different levels of physical manifestations (for example, in the current West Nile fever outbreak in the US, health authorities have issued statements saying you can be a carrier with no physical signs),[10] and different methods of transmission, including respiration, the numbers of people infected would be totally unknown. Therefore, how can we consider that carers and immediate contacts are the only ones of possible concern (as blood banks are contemplating), and use terms like "stakeholders" as the NHMRC does, with xenotransplantation? If, for instance, respiration is a method of transmission, an airplane would be an ideal vehicle for the modern Typhoid Mary. With delayed outcomes, the impact could be much greater than Mary's.

 "Perhaps the most acute worry of proponents and opponents alike is that an endogenous animal retrovirus might move into the human population  just as HIV did. As endogenous retroviruses lurk in an animal's genome, they are not easily screened for and could remain dormant for decades, according to David Cooper, president of the International Xenotransplantation Association and a surgeon at the Massachusetts General Hospital." [11]

 As far as retroviruses are concerned,

"It is now recognised that pigs carry an edogenous retrovirus--porcine endogenous retrovirus, or PERV. Reports that PERV can infect human primary cells and cell lines in vitro are of concern….. Important features of retroviruses include clinical latency (where the first presentation may occur many years after the initial, often asymptomatic,infection); a range of disease manifestations, including direct immunosuppression (eg HIV); and an association with opportunistic infections, malignancy and central nervous system disease…. Retroviruses are transmitted in various ways, including horizontal transmission from animal to animal in a population via sexual contact of blood, and vertical transmission from mother to offspring. A feature is their ability to move across species and emerge in the new species with a different patten of disease and mode of transmission." NHMRC draft guidelines

This is how the NHMRC  assessed the public health risks associated with PERV:

6.4 Assessing the public health risks associated with PERV

A chain of events would be required for PERV to pose a public health risk:

(i) infectious PERVs must exist that are able to infect human cells (this condition has been met);

(ii) such viruses must be present in the germ line of pigs bred for xenotransplantation (this condition is met for most, but not all, such pig herds);

(iii) the viruses must be expressed in transplanted cells, tissues or organs (this has been demonstrated in vivo in immune deficient mouse models only);

(iv) expressed PERV must infect the xenotransplant recipient (risk unknown to date);

(v) replication and spread through the recipient must take place (risk unknown and not demonstrated in any human or animal model); and

(vi) transmission to others must occur (risk unknown and not demonstrated in any human or animal model) (Stoye 1998).
 

However, one doesn't have to seek much and one will find that there is much more known than the NHMRC discussed in the Guidelines and its public statements. This is an excerpt from a description from the Council of Europe. Note especially the aspect of PERVs transmitted genetically to progeny, a very important detail not covered in the Guidelines, nor in public statements made by the NHMRC in the "thumbs-up"[12] campaign (?) to go ahead.

The special interest in retroviruses is based on their ability to integrate into the genome of infected cells. Retroviruses are RNA-viruses, which use a viral enzyme, the reverse transcriptase (RT) to transcribe the single-strand RNA into double-strand DNA, which then will be integrated as provirus. So called exogenous retroviruses such as HIV-1 infect specific target cells and integrate into the genome of these cells. Proviruses will therefore not be found in other cells of the organism. If, however, a retrovirus infects an oocyte or a sperm cell, which gives rise to a new organism, every cell of the body will contain the integrated provirus. Such retroviruses are termed endogenous. Endogenous retroviruses may, on one hand, be expressed as infectious virus particles, and on the other they will be transmitted like normal genes to the progeny."[13]

During the public meeting in Sydney on August 21st, (a member of the NHMRC panel)  minimised PERV risk by saying that they could (and this is my recollection, but without the transcript being made available publicly, I could be not exact in every word) "PERVs could probably be screened out."

 There was an implication that then the already deemed low possible risks would be made even lower, and that the process would therefore be safe. The complexity of keeping another species from transmitting zoonosis when cellular intermixing is the object is far greater than was presented by the NHMRC, as the Council of Europe explains, and note that they say that PERVs cannot be eliminated:

 In order to obtain pathogen free animals for xenotransplantation, known bacteria, fungi, parasites and viruses including exogenous retroviruses may be eliminated by (i) selection of uninfected animals, (ii) by treatment with antibiotics and antiparasitical reagents or (iii) by vaccination of the animals. To achieve this, animals have to be tested for the presence of all microorganisms listed in Tab. 3, 6, 7, 11 and 12. At present an additional risk comes from unknown microorganisms which may not be detected, and from endogenous retroviruses, which cannot be eliminated. [14]

 Further, on the possibility of obtaining biologically "clean" animals, the Council continues,

The decision has to be made by scientists and the public, taking into consideration ethical aspects, the expensive investments into SPF containment, basic research and the need to develop assays to test animals.

Even for the most commonly used laboratory animals, mice and rats, the task is difficult, and zoonosis is a problem which comes up repeatedly in the lab manual, Infectious Diseases of Mice and Rats. [15]

We now know that blood banks and hospitals have become vectors for disease. The US Red Cross is examining its own response to xenograft recipients, and they are looking at the narrowest definition of risk in terms of blood donors. [16] Thus, infection could bealso be spread by the health agencies' response to risk.

If we look at a prospective xenograft recipient, even in Australia's part socialist medical system, the public is footing the bill for what is seen to be a private-only procedure, as the costs are exorbitantly high. Thus, only the wealthy will have this as a choice, though the whole community is subjected to the disease impact and costs, and for the "surveillance" (NHMRC term) part of this process, it is both unstated as to who will pay and what the surveillance will be, but certainly the burden of public health monitoring for public health purposes, and notification for same, will fall on the taxpayer, though the benefactors are private in two ways: the small percentage of our species that could have access to this procedure, and the companies who are selling it.  In terms of capitalist theory, this is the inverse of user pays. It turns dry, rightist economics on its head. And as for a socialist system, it fails utterly, as it puts the individual and private corporation above society as a whole, both in the society paying for the bulk of the "research", and society  paying in both the research stage and the commercial stage, in disease risk and burden.

The problems that the BSE Inquiry showed, we also experienced in Australia during zoonotic outbreaks. Turf wars, lack of coordination and information sharing, industry protection, cults of secrecy.  Because disease is an international problem, it must be faced with maximum efficiency, and that is just for the rising number of zoonoses that we are facing now. Xenotechnology puts a new burden on the world to identify, coordinate, treat, prevent (when we cannot even do these things with the status quo).

 The 2002 workshop organised to examine the problem of emerging zoonotic diseases stated:

"Collaboration can be improved at the international level as well. Although many international activities have succeeded, often via the WHO, difficult circumstances have required the involvement of institutions outside the usual public health agency loop, such as agricultural agencies. This was true when the West Nile virus emerged in the United States in 1999, when the H5N1 influenza virus emerged in Hong Kong in 1997, and when the Hendra virus emerged in Australia in 1994. In each case, turf issues arose, and in some instances efforts to protect agricultural markets seemed to be deemed more important than efforts to protect the public health....We may have been lucky that these zoonotics did not spread to cause further harm, but who is to say what the next agent will be like? The next step in solving such turf issues will involve recognizing the primacy of prevention and control of human disease." [17]

Even in a minor outbreak, our present health care system cannot cope. The meningococcal outbreak in Sydney in August, 2002, garnered a top-of-the-page 3 headline in the Sydney Morning Herald: "Hospitals swamped as parents panic". Hospital emergency departments across Sydney have been struggling to cope…

The State of Missouri has been so worried about a major disease outbreak that in its Public Health Emergencies: Environmental Issues assessment, published in 1999, almost the first half of the 11 pages was devoted to pandemics. Some excerpts: [18]

'76 swine flu and '97 Hong Kong flu outbreaks

…two more recent outbreaks have caused great alarm in the medical community. In 1976, a swine-type influenza virus appeared in a US military barracks (Fort Dix, New Jersey). Scientists determined it was an 'antigenically drifted variant of th feared 1918 virus. Fortunately, a pandemic never materialized…

In March, 1997, scores of chickens in Hong Kong's rural New Territories began to die--6,800 on three farms alone. The virus was especially virulent, and made an unusual jump from the chickens to humans….

While the outbreak highlighted the success of the surveillance network, it also showed how dangerously mutable influenza viruses can be. In their most sinister forms, such as the 1918 Spanish Flu, they can be as deadly as any disease known to man.

Measure of Probability and Severity

Health officials age there is a high probability we will see another dangerous new strain of the influenza virus sometime in the future, accorting to the Missouri Department of Health. In fact, a world-wide influenza outbreak on the scale and severity of the Spanish Flu is not far-fetched, an, in fact, is expected by many experts….

Impact of the Hazard

For planning purposes, it would be reasonable to assume a rapid movement of a pandemic flu virus from major metropolitan areas to rural areas of the state. The effect of a pandemic on individual communities will be relatively prolonged--weeks to months. The impact of the next pandemic could have a devastating effect on the health and well being of Missouri citizens an the American public. CDC estimates that in the US alone:

·          Up to 200 million persons will be infected.

·          Between 40 and 100 million persons will becoe clinically ill

·          Between 18 and 45 million persons will require outpatient care.

·          Between 300,000 and 800,000 persons will be hospitalized.

·          Between 88,000 an 300,000 people will die nationwide.

·          Effective preventiv and therapeutic measures--including vaccines and antiviral agents--will likely be in short suppoly, as well as antibiotics to treat secondary infections.

·          Based on the CDC's preliminary estimates, economic losses from the next pandemic may range from $71 million to $166 billion, depending on the attack rate.

In a strange irony, the nation with the biggest push in xenotechnology, the USA, also has a health crisis on its hands, one in which thousands of ageing people are being pushed out of the health system because they cost too much in terms of physicians' insurance premiums. Thus, the section of the community that is the most likely to be carriers is the least able to report sickness. As for the recommendations that Missouri made to be prepared, they are trying but with funding for essential services cut to states all around the nation, their health care crisis and Australia's, and the UK, and and and--who amongst nations would be prepared for even a pandemic of a quickly manifesting, identifiable disease for which there could be vaccines at the ready? And then there is the problem of carriers.

We have two problems there. The problem of humans and the "goods" as they are termed. Each can harbour without any signs, as this excerpt from Infectious Diseases of Mice and Rats explains.

Infection Versus Disease

     A common misconception, even among senior scientists and laboratory animal specialists, is that infection is synonymous with disease. Bacterial infections of rodents include pathogens, opportunists, and commensals, of which the last two are by far the most numerous as constituents of the normal flora on mucosal and body surfaces. Similarly, the viral and parasite pathogens of rodents vary considerably in pathogenicity. Also, it is important to distinguish between subclinical(inapparent, covert, or silent) and clinically apparent infections. Two types of subclinical infections are recognized: dorman (the agent can be recovered) and latent (the agent cannot be recovered by direct methods and its presence must be inferred by indirect methods).

     Most natural infections due to pathogens in mice and rats are subclinical. Thus, clinical manifestations of pathogen infections in these species have only limited diagnostic value. Also, it cannot be overemphasized that aberrations in research results due to natural infections often occur in the absence of clinical disease. Thus, prevention of infection, not merely prevention of clinical disease, is essential. [19]

Xenotechnology complicates the subclinical to a degree that makes each species a constant subclinical vetting nightmare. And we're not even talking about mutation of viruses, yet another headache with the burden of disease we are fighting against even now.[20]

 Although (a member of the NHMRC panel), in the Sydney public meeting, sought to reassure, in saying "We have lived with pigs for thousands of years," no mention was made of the Fort Dix outbreak, the recent  Nippah and Hendra outbreaks, [21]which also "surprised" scientists, nor the fact that in the foot-and-mouth outbreak in the UK in 2001, the Roslin's Institute's funding was pulled for their transgenic pig project as soon as the outbreak hit the media (is investor wariness re corporate liability going to be the only way to slow what became clear was rampant laissez faire xenotechnology worldwide?)

 In fact, neither the public meeting, nor the NHMRC showed any of the concerns that hit the xenotech industry every time an outbreak occurs. This side of the story was told by the ABC News during the UK swine fever outbreak in 2000, and while the Nippah virus was still active at least in the news, in Malaysia. Yet this was not part of the presentation, nor the Guidelines, and certainly is not a factor in the push to go ahead.

 Genetic transplants under threat from disease

American researchers have confirmed what many in the medical fraternity feared, that viruses lying dormant in pigs and other animals could cause serious diseases in healthy, fit humans. Not just any disease though, potentially deadly new viruses reminiscent of AIDS, Nippah and Ebola. The latest findings have devastated the prospect of genetically engineering transplants for humans being harvested from animals an industry potentially worth tens of billions of dollars. Swine fever is spreading throughout the UK pig herd and Nippah virus is still active in Malaysia, now threats to humans has shut down research into genetically modified pig transplants, both here in Australia and overseas. Research was published showing that pig viruses had jumped a species to mice. Throughout the world as a result, pig to people research is being abandoned, Australias only program looking to plant genetically engineered pig cells into diabetic patients has also been suspended, following those fears of humans being stricken with pig viruses. [22]

  On the subject of membrane glycosylation, (a member of the NHMRC panel) spoke of it as a way to make the technology work in the terms of 'and another problem we've solved'. We were not told any other point of view such as: "However, if membrane glycosylation is reduced or removed, the pig's immune-recognition system could be damaged and a currently subdued PERV might reactivate and cause diseases that are transferred with the organ." [23]

 Perfusion was spoken about enthusiastically by (a member of the NHMRC panel) in the Sydney meeting and also by Dr. Breen in his interviews.[24] Stated, in the public meeting:  patients after having had perfusion years ago, exhibited no signs that anything had changed with them as far as pig cells, etc. On this point I spoke to a Committee member afterwards, saying that Peter Collignon wrote differently about this (his paper cited in the NHMRC Guidelines, as a matter of fact) and the Committee member said that the Committee knew this, but yet, NO ONE contradicted when their colleague made this public statement of assurance. This is just one example of what made a public information meeting sound like a sales talk.

But let's say that xenotransplants go ahead. What are we going to do about monitoring? Is monitoring optional, as the NHMRC suggests: "While it is expected that…most patients will adhere to the request for lifelong monitoring, individual recipients may withdraw their consent."  In our free society, we are not contemplating quarantining the recipient, the contacts with the recipient, the activities the recipient undertakes, making the recipient and all contacts wear masks. And what about refraining from sex, (or having children, such as the UK has mooted), restricting work in certain industries? Access to public transport, right to travel abroad or into our country? And how far do we define contacts with others as a risk? Do we restrict how they live? For instance, retirement communities would be perfect incubation units for disease. Do we have special hospital wards for suspicious symptoms' holders? What about a recipient married to a pilot? What do we do if recipients disobey what they agree to? Because the air they exhale, the bodily fluids they leak, dead or alive, could kill innocents - recipients are dangers to society, without society even knowing.

On the important human genetic aspect of xenotechnology, what are we to do? This has not been addressed by the Guidelines. The capacity of PERV to be transferred to offspring was mentioned by (a member of the NHMRC panel), but the significance was never picked up in the public meeting, nor has it to date, by the Committee. In the UK, having recipients agree to not have children has been discussed, but with the public risk wholly dependent on trusting a recipient not to, the only way to make sure that children do not occur, is to have recipients also agree to be sterilized, something that I do not think has been considered anywhere, though the case of xenotransplantation heightens the importance of the individual to historically unprecedented levels, at the risk of our entire species.

And how do we monitor and deal with corporations? In August 2002, the New York  Times reported that it took eleven months for the US FDA to recall faulty implant tissue. [25] "The agency said 27 people had developed serious infections after receiving tissue implants processed by the company, and one of them had died. The Centers for Disease Control and Prevention learned about possible problems with the tissues in November." The precautionary principle meets the profit principle.  When these two principles meet the cost-cutting needs of government, we have this outcome (from the UK's xenotechnology industry lobbying group): ""Given that it is likely that the Government's concern with risk is associated with cost…" [26]

One reason that outbreaks have spread is the wish by agencies and politicians, to "not alarm". The reasons for this range from the laudable to the less so, but the motivation has led to the problem of the public being told that the risk is lower than it is, or that, and in the case of xenografts this is happening now, that the risk is quantifiable and low, when it is in fact,  both unquantifiable, given that the number of possible diseases and their virulence is entirely unknown, and of globally catastrophic potentiality.

The 2002 Zoonose Workshop stated in its conclusions, that (internationally and within nations) coordination was poor, information inadequate between agencies and to the public, misinformation common, and science woefully still at a surprisingly low level of knowledge about how disease works, especially when put against the ability to bring on disease risk. This workshop had heavy representation and funding from industry, and it shows in the uncharacteristic timidity in which it approaches xenotechnology.

Many different determinants contribute to the emergence of new zoonotic agents, and it is rare that these factors act singly. Among the forces that shape their emergence are human demographics and behavior; technology, industry, and agriculture; economic development and land use; international travel, commerce, and military expeditions; microbial adaptation and change; and breakdown of public health measures. Indeed, social and environmental changes are accelerating, in both the developed and developing worlds. The developed world has the greatest travel and transport, providing particular risks for rapid spread....Some observers also suggest that xenotransplantation...may inadvertently introduce new zoonotic infections to recipients of such material. This risk raises the burden of preventive responsibility on scientists and research groups conducting such trials....Many gaps remain in our understanding of zoonotic agents and the diseases they cause. More research is needed on the pathogenesis of zoonotics in relation to host biology....Despite spectacular achievements in microbial genetics and genomics, we know relatively little about how most zoonotic agents are maintained in nature or how they respond to environmental (often anthropogenic) changes. The precise ecological factors that lead to human infection and emergence are murkey, and textbook descriptions of the epidemiology of most zoonotic diseases are at best simplistic. In order to more effectively prevent or control zoonotic diseases, it will be necessary to better understand the ecology of their respective etiologic agents. [27]

Despite the increased attention put to zoonoses now in the United States, due to the West Nile Fever, the National Academy of Sciences still warned in August 2002, that genetic manipulation of animals poses serious risks to the environment and human health, partly because "the efforts to manage risks are disorganised and probably inadequate." [28]
 

Some lessons from the BSE Inquiry:

By 1994 the Spongiform Encephalopathy Advisory Committee (SEAC) evaluated the risk of transmissibility to humans as remote only because precautionary measures had been put in place.

The Government did not lie to the public about BSE. It believed that the risks posed by BSE to humans were remote. The Government was preoccupied with preventing an alarmist over-reaction to BSE because it believed that the risk was remote. It is now clear that this campaign of reassurance was a mistake..... The link between BSE and vCJD is now clearly established, though the manner of infection is not clear. [29]

 The 20/20 Hindsight excuse:

It could not be said that there could be a future excuse of safety "based on what we knew at the time", nor a risk so low nor a cost/benefit analysis that justifies, that we could pass even trials as an arguable procedure.

 Liability. Sovereign liability is already a reality, and given that governments are involved, both in permitting, regulating, and funding xenotechnology, they would be the most obvious targets for transnational legal suits, especially since a pandemic would cause a domino effect of corporate bankruptcies. Even now, how is insurance risk being calculated, and who is the final guarantor? Whatever the claims--breach of duty of care, malfeasance, manslaughter, and claims could be many and varied; even given certain conditions, genocide, in our more extremist times, --the liability for purposely inserting the capacity for an unknown number of diseases into the human species is an incalculable, for which it looks like society will pay, in all ways.

 As to profits, when the NHMRC mentions in the guidelines "pressure" to proceed with xenotechnology, it crucially does not mention where the pressure comes from. The public only sees the sufferers, just as they do now in the efforts to limit medical liability.

 An investors' newsletter advises, in "Smart Investors Ignore Genomics, Look to New Products":

"Other long-term trends also favor the industry. One is a graying population, said Jim Cavanaugh, president of Healthcare Venture Partners. His firm has started a number of companies that focus on "regenerative medicine" including  Human Genome Sciences, as well as xenotransplant companies BioTransplant and Diacrin. Along with Genzyme, Diacrin is testing a treatment for Parkinson's and Huntington's diseases that involve transplanting fetal pig cells into patients' brains. "In the next 7-10 years we think the CNS (central nervous system) area provides great opportunities for product development. These markets will grow with increasing aging population," said Cavanaugh.

…. Yet another positive indicator that is sometimes overlooked is the huge amount of government funding that goes into biomedicine. Most of the money doled out by the National Institutes of Health (NIH), an agency whose budget is also set to double within a few years." [30]

This issue is not one for any country to deal with alone, because xenotourism is already a concern, spawned by expectations of competing regulations. That competition between nations exist, is illustrated below, in this lobbying paper from the UK.

The UK is a World-leader in xenotransplantation, as it is in a number of areas of science, and has made past investments to achieve this status. The economic gains to accrue from providing such World-leading technology to other countries, or in attracting high technology companies to the UK should not be ignored. We therefore advise that xenotransplantation research should continue to be properly funded (arguably increasingly so as progress is made and we begin the move from research to development) and that the Government recognises that xenotransplantation is one reason of many for the continued public support for UK science (from the science base and the Higher Education Funding Councils through to Government's Departments). [31]

Who is recommending and pushing this technology here? Because of competing interests, full disclosure is imperative

(A member of the NHMRC panel) used the USFDA as an argument for xenotechnology. Whatever state of approval the technology has in the US, the problem of a revolving door in regulatory agencies, and lobby money to add to the pressure to conform to important business interests, makes this an inappropriate statement of advocacy to use in Australia. We are, however, suffering from an increase in both lobbying and revolving doors (e.g. Peter Reith, Michael Wooldridge going straight from Minister to lobbyist to their former departments). The extent of conflicts of interest is not known about by the public, but it affects decisions and advice given to government, and the citizens of the nation every day. Therefore, since the NHMRC is taking an advocacy position, the members must be judged as if they were recommending the public to buy shares in a company. We are investing in the health of our species, and we cannot afford compromised advice.

Every member of every Committee and Working Group should by law, be required to declare their interests, for there are certainly such conflicting interests now, that they would preclude advice given should they be in the business of investment advisors. By interests, I mean all grants [32]and lobby group connections in the field, and all funding and sources for same, plus any pending possible conflicts of interest. These are currently undisclosed, yet as living from grant to mouth is a reality of science and research,  they are an intrinsic part of the reason why certain members have certain points of view. The public needs to know, in all proposals.


Informed consent has been discussed, but, as in the user pays principle being stood on its head, informed consent when it is discussed in the guidelines has been, in reverse of how it should be considered. The informed consent that needs to be obtained is the informed consent of the population in the democratic exercise of their will. There has not been enough information disseminated, not enough public discussion as to the public health and social issues, not enough public forums.

 "As to ethics, people tend to think of ethics as some sort of arcane,  impractical enterprise, and therefore, optional. (this tendency has been increased by the kind of discussions that have been made prominent in the cloning/stem cell debate.) But it needs to be said loud and clear: putting people at risk without their informed consent and/or without hope of possible benefit is unethical and of prime importance in any consideration of going ahead with something that affects us all." - Laura Purdy

In a democracy, there should be no thumbs-up without democratic informed consent. This process is not informing, nor is it open government.

Finally, in terms of community consent, how could we possibly call this process and the information disseminated, democratic informed consent. The most shocking part of the Sydney meeting was the expectation, that in a city of five million people, a room with twenty chairs, and two hours, was all that was needed for the public meeting, on a decision that taken, could take us back to the times that the Decameron was written, or beyond. In the meeting, leading assertions and arguable claims were made to which there was no time, nor were there enough "public" in the room, to politely have the chance to refute.

A subsequent phone call requesting transcripts of the public meetings was answered this way:

"In answer to your question, No we won't be publicly providing a record of public meetings on xeno. We will be providing a report to the Working Party for them to consider, along with the written submissions. Neither the written submissions nor the public meetings will be made available to the public verbatim. They will be reflected in the next version of the Guidelines, but they won't be public records as such. But if there's anything we can help you with about angles etcetera, feel free to ring us, particularly …. at the NHMRC."

This is the most important health issue of our day, and one of which the public is almost wholly ignorant. At this point, this is how the process of decision-making looks: A secret process, with almost no participation expected, and a foregone conclusion as to the recommendations, regardless of the blithe reassurances at the meeting that they, the recommendations, were not finalised. How can we know what the submissions say, and criticisms are, if they are to go through the filter of the advocates themselves?


In summation:

1.        The epidemiological risks from xenotransplantion cannot be assessed as low when the mechanisms for transmitting xenozoonoses are intrinsic to the technology itself. The "risk" assessment as the NHMRC describes it, is hopeful, but incorrect, as there will be zoonosis as the result of xenotransplantation. We have inevitability here, not risk. The true risk is, therefore, the gamble we take of how long it will be before we get what level of pandemic, and how many we get in what period of time.
 
2.        There has not been a satisfactory effort to inform the public of the science and economics involved with this technology. It is anti-democratic to subject the public to these risks before they are adequately informed and can give democratic informed consent.
 
3.        Despite assurances to the contrary in the Sydney public meeting, the NHMRC is acting as an advocate of xenotechnology, and has both put a spin on information, consistently minimising problems and risks,[1] and limited information availability to the public.
 
4.        Immunosuppression of organ recipients and genetically engineered donor animals with human genes are currently employed in xenotransplantation. These techniques are said to be necessary to make xenotransplantation work – however they also increase the inevitability of transmission of new animal diseases, such as P.E.R.V. into the human population.
 
5.        Xenotechnology is a transitional technology with a permanent  legacy. With transitional status, this means that the results of it are even more likely to be a problem because the monitoring, quarantining, rules, which stretch resources in the first place,  have a low likelihood of being maintained when they are no longer in the forefront of any attention paid to them. With xenotechnoloby will have increased risk of poor monitoring, but an inheritance, forever,  of a genetic legacy from PERVs and other pathogens that we cannot filter out of the other species.
 
6.        A xenotranplantation trial is not a trial. Biologically and pathogenically, it is the real thing.
 
7.        Other solutions have not been adequately discussed. Op-out organ donation will immediately increase the human organ pool, and for a permanent solution, allotechnology, particularly, stem cells is the obvious path. It does not have the rejection nor zoonosis problems, and will clearly be the solution in the future.
 
8.        The bulk of projected xenotransplant recipients would not be in their dire state of organ failure, were attention paid to healthy living and preventive health care. This shift in emphasis is vitally needed when weighing needs and priorities, and in creating public health worldwide.
 
9.        Xenotransplanation is not for the common good. It is proposed to solve a health care issue of well-off (typically, ageing) customers of private corporations (in which pigs legally defined as "goods") to the detriment of the entire human population that will be put at risk. 
 
10.     The assurance of safety is based on systems that are not described as such, yet we have only to look to the recent B.S.E. Inquiry for an example a new human disease originating in animals due to innovative animal care, as well as an example of the catastrophic failure of a well-meaning regulatory system.
 
11.     The burden of monitoring and liability falls on a health care system already in funding crisis, both in Australia and nations in the forefront of xenotechnology.
 
12.     Xenotechnology is not for the public (or posterity's) good, even in our own country.
 
13.     As a world health issue, the cost of xenotranplantation means the poor can only gain disease.
 
14.     Sovereign liability in the instance of a pandemic is an incalculable, but of relatively piddling concern, when compared to the global political instability.
 


CONCLUSIONS

Xenotransplantation

> is not safe

> is not efficacious

> is not for the public good

> places an intolerable burden on public health systems that are already overstressed

> does not pass any risk assessment

> is not known enough by the public, its democratic representatives, nor discussed in the media, for the recommenders to say it passes any ethical criteria

There are better systems (such as organ donor opt-out) and better technologies (such as stem cell) using entirely our own species, that we should develop, not to mention preventive health.

We, therefore, should not give thumbs-up to the proposals, but stop the xenotechnology that already exists, recognising that xenotechnology is an efficacious  way to cause new plagues of new zoonoses as well as leaving a legacy in our genetic makeup that we cannot remove. Nature's warning "the public consequence could be catastrophic" [33] should be taken seriously.

Xenotechnology exposes our species, as well as other species, to new pandemics, is definitely not progress, given who stands to gain and lose, nor is it medicine for the public good.

As the NHMRC Guidelines say,

"As for other areas of medical research, an overriding consideration for xenotransplantation research is that it should serve the common good."

In dry economic terms: to save a life at the cost of our species is not cost effective.

And in wet compassionate terms: xenotechnology puts the short-term wants of a few against the rights of humanity itself.


RECOMMENDATIONS:

1.       An immediate stop to Australian xenotechnology as it exists (including stem cell and other research using mice and other species as cultures for human cells), as it is clear no other species is a safe proposition in a technology that functions by tearing away species barriers in many ways, let alone heightens susceptibility by immunosuppressing.

 2.       Australian cooperation and fostering of an international moratorium on xenotechnology, at least until there is broad international public understanding of the important aspects of this science: both in the health and international risk/benefit.


ADDENDUM: Appropriate tools for meaningful public consultation

  from Xenotransplantation by Fritz H. Bach and Adrian J. Ivinson, HMS Beagle:BioMedNet (an online magazine from Elsevier Science), Issue 119, February 1, 2002 (Also in Trends in Biology)

 Policies surrounding xenotransplantation, and many other emerging high-technology interventions, must balance opportunity and risk. Whereas traditional stakeholders, such as the researcher community, government agencies, and the commercial sector, readily contribute to the debates that influence policies, the voice of the public is seldom heard. Not only does this raise ethical concerns, but also it might ultimately prove to be shortsighted. Before any country settles unilaterally on comprehensive policies governing the practice of xenotransplantation, well-informed public opinion needs to be taken into account.



References:
[1] see, e.g. Pig bits OK for people: body "Researchers should be allowed to transplant parts from genetically modified pigs into human beings in controlled experiments, a national advisory body says…." The West Australian, 8 July, 2002 http://www.thewest.com.au/20020708/news/state/tw-news-state-home-sto63214.html
and
"Experts back animal to human transplants"ABC News, 8 July, 2002 http://www.abc.net.au/news/2002/07/item20020708071346_1.htm

[2] quoted in "Could this Pig Save Your Life?" New York Times Magazine, 3 Oct 1999

[3] The BSE Inquiry: The Inquiry into BSE and variant CJD in the United Kingdon http://www.bse.org.uk/index.htm

[4] "Xenografts: Are the risks so great that we should not proceed?", Peter Collignon and Laura Purdy (bioethicist, professor of philosophy, Wells College), Microbes and Infections 3, 2001, Éditions Scientifiques et Médicales Elsevier SAS

[5] see "Monkey meat riddled with SIV" by Tom Clarke, Nature, 25 March, 2002-08-17 http://www.nature.com/nsu/020318/020318-13.html 

[6] see "Recall is ordered at large supplier of implant tissue" New York Times, August 15, 2002

[7] The 4th National Symposium on Biosafety. PHS Perspective on Xenograft Transplantation, Louisa Chapman, MD, Medical Epidemiologist, CDC, Atlanta    http://www.cdc.gov/od/ohs/sympsium/symp31.htm

[8] "Interview with a Humanoid', by Nicholas Kristof, New York Times, July 23, 2002

[9] Bernard Vallat, Director General, OIE Proceedings: Joint WHO/FAO/OIE Technical Consultation on BSE: public health, animal health and trade, 11-14 June, 2001 http://www.who.int/emc-documents/tse/ docs/Whocdscsraph2001.8p.pdf

[10] "Few who are infected show signs of illness" USA Today, August 7,2002

[11] "Public consultation needed on xenotransplants: A session on xenotransplantation at the AAAS this week highlighted the need for urgent public consultation" by Helen Gavaghan, The Scientist, Feb 22, 2002 http://www.biomedcentral.com/news/20020222/04

[12] "... Council has agreed to give the procedure the ‘thumbs-up’... We speak to Kerry Breen, Chairman…" ABC Radio National , 9 July 2002    http://www.abc.net.au/rn/talks/brkfast/stories/s601975.htm

[13] "State of the Art Report on Xenotransplantation (2000)", Council of Europe  http://www.social.coe.int/default_en.htm

[14] Ibid.

[15] Infectious Diseases of Mice and Rats (1991), Institute for Laboratory Animal Research, National Academy Press, Washington DC

[16] Red Cross "comment to FDA on draft guidelines Precautionary Measures to possible risk of transmission of zoonoses by blood and blood products from Xenoplantation Product Recipients and their contacts" http://www.fda.gov/ohrms/dockets/dailys/00/may00/050400/c000030.pdf

[17] pg 120 The Emergence of Zoonotic Diseases (2002) National Academy Press, Washington DC

[18] Public Health Emergencies; Environmental Issues, Missouri State Emergency Management Agency, August 1999

http:/./www.sema.state.mo.us/sh%20annex%20p.pdf

[19] pg 3,4, Infectious Diseases of Mice and Rats…

[20] "Killer flu can result from a single mutation" New Scientist, 25 August, 2002

[21] see "Outbreak of Hendra-Like Virus" CDC, April 9, 1999 http://www.cdc.gov/epo/mmwr/preview/mmwrhtml/00056866.htm

[22] "Genetic transplants under threat from disease: Interview: Professor Ron Trent - Chairman of the National Health and Medical Research Council Gene Advisory Panel ", ABC Country Hour, 18 August, 2000 http://www.abc.net.au/rural/sa/stories/s165118.htm

[23] "GE-Free New Zealand Submission to the Parliament Select Committee on Finance and Expenditure regarding the Hazardous Substances and New Organisms (Genetically Modified Organisms) Amendment Bill by Pat Clark. "  http://www.gefree.org.nz/RciRep/9.html

[24] see "Suggestion of using pig parts in humans" ABC News, 8 July, 2002   http://www.abc.net.au/am/s600960.htm

[25] "Recall is ordered at large supplier of implant tissue" New York Times, August 15, 2002

[26] -"Xenotransplantation -- Reply to the Government's response, from the Institute of Biology and British Electrophoresis Society" Institute of Biology  http://www.iob.org/editorial_display.asp?edname=395.htm&cont_id=26

[27]-pgs 114,115, "The Emergence of Zoonotic Diseases: Understanding the Impact on Animal and Human Health - Workshop Summary (2002)"National Academy Press, Washington DC

[28] Animal Biotechnology: Science based concerns, Board on Life Sciences, National Academy Press, Wash DC 2002  http://www.nap.edu/books/0309084393/html/

[30]  -"Smart Investors Ignore Genomics, Look to New Products: If you didn't own biotech stocks before the sector got red-hot, you're probably kicking yourself and wondering: Is there still money to be made?", April 3, 2000, BioSpace.com, http://www.biospace.com/articles/bio_smart.cfm

[31] "Xenotransplantation -- Reply to the Government's response,  from the Institute of Biology and British Electrophoresis Society" Institute of Biology, http://www.iob.org/editorial_display.asp?edname=395.htm&cont_id=26

[32] e.g. The Roche Organ Transplantation Research Foundation, and its links      http://www.rotrf.org/

[33] editorial, Nature, August 17, 2000



See subsequently: Animal-to-human transplants: Who pays, and with what? by Toshi Knell, New Doctor, the Journal of the Doctors Reform Society of Australia


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