30 Artillery Lane
London E1 7LS
Dear Vishnee Seenundun,
We are writing to express our concern regarding the HFEA's
public consultation on sex selection, and to encourage you to
ensure that strong policies are upheld and further developed
against non-medical sex selection.
The Center for Genetics and Society is a U.S.-based non-profit
public interest organization working to encourage responsible
uses and democratic governance of the new human genetic and
reproductive technologies. In our work, we look to the HFEA
as a model for responsible regulation, and consider that your
work carries critical weight for international policy making
well beyond the UK. Conversely, we feel that the HFEA would
do well to consider U.S. experience in this field, where a virtual
absence of regulation has led to a shortchanging of ethical
and social considerations and an unacceptable level of permissiveness
in the fertility industry.
In general, we are concerned by the way in which the consultation
document, "Sex selection: Choice and responsibility in
reproduction" frames the consultation process around "risks
to health" and "reliability of outcome" with
little if any discussion of the overarching social and ethical
implications associated with sex selection techniques. While
health risks and reliability are important considerations, using
them as the main criteria to determine a technique's acceptability
precludes any discussion of social concerns or desirability
of the technique, and assumes its inevitable use once conditions
of safety and reliability are met.
We are particularly concerned that "risk" and "reliability"
are offered as the main standards to analyze pre-implantation
genetic diagnosis (PGD) as a non-medical sex selection method.
Preselecting embryos for sex marks a clear departure from medical
uses of this highly controversial technology. Allowing this
use of PGD would open the door to customizing children and undermine
its legitimate uses.
We are surprised that the HFEA would decide to include PGD
at all in this consultation process on sex selection, given
that the agency rejected PGD for these purposes a short time
ago. We hope this decision was not driven by recent cases in
the U.S. where such use of PGD reportedly occurred, and would
be dismayed if this consultation process were to be used as
an opportunity to lower the UK's standards to U.S. levels. The
HFEA's 1999 policy prohibiting PGD for use in non-medical sex
selection is appropriate and should be maintained.
We believe that any form of non-medical sex selection, even
for so-called "gender balancing" is discriminatory,
since it reinforces a devaluation of one sex in favor of the
other. From a wider policy perspective, such a practice condones
the use of low-tech sex discrimination in other parts of the
world, where strong cultural pressures to have male children
have led to the widespread use of female infanticide and selective
abortion. Technical improvements in preconceptive sex selection
techniques referenced in the consultation document speak nothing
to these discriminatory aspects, and should not guide HFEA's
policy on this matter.
A weakening of sex selection policies would initiate a dangerous
and probably irreversible trend towards allowing these technologies
to be driven by technical feasibility rather than social need.
We hope your consultation process will strengthen standards
against non-medical sex selection, and that the UK will continue
to provide leadership to the world on this matter.