American Anti-Vivisection Society
AAVS Campaigns: Animal Cloning

Point/Counterpoint

Point Cloning does not require special consideration because it is just another step in the evolution of assisted reproduction technologies (ARTs) that the industry is already using without regulation.
Counterpoint: There are significant differences between cloning and ARTs such as artificial insemination and in vitro fertilization, and these differences create novel concerns about the safety and ethics of cloning that are unique to this technology. First, no reproductive event actually occurs in cloning. Instead, cloning requires genetic manipulation, which involves a markedly different degree of human involvement and interference. Second, cloning is a highly inefficient and unpredictable technology that is characterized by high failure rates and serious complications, raising significant concerns for animal welfare. Lastly, animal cloning involves the same technology used to clone human cells and embryos, and is also critical for the proliferation of transgenic technology, which produces animals who have been functionally altered though the insertion of genetic material from different species, two research areas that are characterized by highly charged ethical debates. Each of these differences raises profound questions about the morality and ethics of advancing cloning technology, and highlights the importance of conducting an ethical review of animal cloning before commercialization is allowed to proceed.

Point The FDA conducts science-based risk assessments, so it is not equipped to consider the ethical issues associated with cloning animals for food.
Counterpoint: The FDA has repeatedly stated in press releases and news reports that it will factor ethical concerns into its decision on cloning animals for food. While the FDA is not set up to conduct its own ethical review, there is precedent for establishing a government-sponsored committee to thoroughly discuss ethical issues and advise the FDA on its findings. A similar committee was established by Health and Human Services (the Advisory Committee on Genetics, Health, and Society) to address the ethical and societal implications of human genetic technologies.

Moreover, several agencies, including the National Academies of Science, have called on the government to recognize and address the moral, ethical, and social implications of animal cloning, and 63% of Americans say they want the government to consider these issues. Establishment of an advisory committee that will discuss ethics, animal welfare, and labeling requirements is critical to ensuring that the FDA receives the guidance it needs to fulfill its promise and responsibility to consumers.

Point A clone is just a twin born a generation apart.
Counterpoint: A clone is not at all a twin. A clone may have nuclear DNA that is identical to the donor animal, but the clone carries different mitochondrial DNA and cellular molecules that affect development in unknown ways. Therefore, the individuals will be similar, but not identical, and the significance of these differences is unpredictable. In addition, it often takes hundreds of animals to produce just one clone, which is certainly not the case for twins.

Point The FDA has evaluated the risks posed by cloning to animal health and has found that cloned animals do not suffer any new problems.
Counterpoint: While cloned animals do suffer the same kinds of problems as animals produced using ARTs, cloned animals suffer from these problems at significantly greater and highly concerning rates. Numerous published studies show that there is a 95-99% likelihood that a cloned animal will die in utero or shortly after birth. A large proportion of cloned animals have also been documented as frequently suffering from severe physiological abnormalities and physical defects, such as impaired immune systems, respiratory distress, abnormally large heads or bodies, and organ dysfunction. No product or technology has ever been approved with such a dismal record. In addition, given the problems that are associated with ARTs, it is questionable whether this is even the appropriate benchmark to use in the evaluation of cloning safety. In any case, cloning is neither safe nor effective for animals, and the frequency and nature of the serious complications associated with cloning present unique animal welfare concerns which must be addressed.

Point The FDA is conducting a thorough investigation of the food safety of milk and meat from cloned animals and so far has found no indication that consuming cloned foods will increase risks to human health.
Counterpoint: Cloned foods may present risks that the FDA is simply unable to anticipate and does not know how to screen for. The FDA has acknowledged that because this technology is so new, it is difficult to know what questions to ask to evaluate the potential of heretofore unknown human health risks that may be associated with cloning. As Stephen Sundlof, director of the FDA's Center for Veterinary Medicine, said, "It's very difficult to ask for information about a hazard you really can't identify."

In such a case, it is wise to question the merits of introducing such foods. At the very least, if products from cloned animals are approved for sale to the public, it is advisable to require that cloned food products be able to be identified and traced in the event of a problem. Mandatory labeling of cloned products would facilitate this process.

Point The FDA says that labels on milk and meat from cloned animals are unnecessary because the food products cannot be distinguished from milk and meat from conventionally-bred animals.
Counterpoint: Regardless of whether there are differences in the fat or protein content of cloned food products compared to conventional products, there are significant differences in how the foods are produced. These are differences that American consumers are increasingly interested in, as evidenced by the success of the organic foods industry, and the proliferation of foods marketed as "free-range," "humanely raised," "cage-free," and "rbGH-free." Food safety is only one of the many concerns that consumers have about animal cloning, and labels are necessary to give consumers the information they need to make the decisions that are appropriate for them.

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AAVS Petitions FDA to Regulate Cloned Animals
Submit a Comment to the FDA

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