Family Research Council

May 26, 2009

Via Electronic Submission

National Institutes of Health
ATTN: NIH Stem Cell Guidelines
MSC 7997
9000 Rockville Pike
Washington, DC 20892-7997

Re: "National Institutes of Health Guidelines for Human Stem Cell Research"

(Draft Guidelines)

74 Fed. Reg. 18,578 (April 23, 2009)

Dear Director, National Institutes of Health:

On behalf of the Family Research Council (FRC), this document responds to the above-captioned public notice in which the National Institutes of Health (NIH) has requested comment on draft guidelines titled "National Institutes of Health Guidelines for Human Stem Cell Research." The draft guidelines were written to implement President Barack Obama's Executive Order 13505, issued on March 9, 2009.


Human embryonic stem (ES) cell research is legal and unrestricted by federal law (though some states have restrictions), so researchers can create and kill as many embryos as they choose for any reason. Family Research Council (FRC) submits comment in response to guidance from the National Institutes of Health (NIH) on federal funding of human ES cell research.

The current debate concerns whether taxpayers should pay for research in which embryos are killed for their stem cells. This debate is not about "stem cell research." It is legal to perform research with stem cells that exist throughout various body organs, such as pancreas, liver, bone marrow, nose, and brain, and it is legal to do research on stem cells that are derived from human embryos. The only question is whether the federal government should fund human embryo research.

FRC objects to funding human ES cell research for several reasons.

First, such research requires the destruction of human embryonic life and is therefore unethical.

Second, FRC believes that such funding violates the legal prohibition on funding research in which embryos are created, harmed, or destroyed in research, a law known as the Dickey-Wicker provision (P.L. 110-161, the Consolidated Appropriations Act, 2009), which first became law in 1996.

Third, funding such research creates an incentive for researchers to create more human embryos for destruction, and the proposed NIH guidelines are guilty of creating this financial incentive even though they propose funding human ES cells from so-called "leftover" embryos.

Finally, funding such research diverts limited federal funds away from stem cell therapies that have shown and continue to show real therapeutic benefit for patients suffering from over 70 conditions. The preoccupation with human ES cells is unfortunate given inherent biological barriers to using these cells in patients, such as tumor formation, immune rejection, and chromosomal abnormalities, among others. While such research is currently legal, FRC believes that the American public would be better served by NIH focusing funding on stem cell research showing benefit to patients experiencing a host of diseases. This is not a debate over the legality of the issue, but what is and what should be funded by the federal government.

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David Prentice Senior Fellow for Life Sciences

Dr. David Prentice is Senior Fellow for Life Sciences at Family Research Council. Up to July 2004 he had spent almost 20 years as Professor of Life Sciences, Indiana State (Full Bio)

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