ALIVE’s Opinions against Using Cloned Animals for Food.

2009.4.6

ALIVE Submitted Public Comment Concerning Using Cloned Animals for Food (the contents are posted below).

<Related Sites>

Foods Derived from Cloned Cows and Swine, and From the Offspring of Cloned Animals (plan)
Public Comments Collected from March 12 to April 10, 2009
http://www.fsc.go.jp/iken-bosyu/pc1_shinkaihatu_clone_210312.html

Letter is address to:
The Cabinet Office Food Safety Commission Evaluation Office
"Safety Assessment of Newly Developed Food Technology and its Effects on Health"

ALIVE's Opinion Concerning Foods Derived from Cloned Cows and Swine, and From the Offspring of Cloned Animals (plan)
April 6, 2009 (Fusako Nogami, ALIVE)

1) The Summary of ALIVE's Public Comment.

Safety Assessment of Newly Developed Food Effects on Health (Safety Assessment) concluded that foods derived from cloned cows and swine, and from the offspring of clones, are as safe as food from
conventionally bred animals, therefore the cloned animal food is as safe as the meat currently sold on the market.

However a lot of people are skeptical about the safety of cloned food and feel cloning itself is unethical. This is because people consider cloning animals blasphemes animal welfare and disturbs biodiversity.
Life modification technology does not comply with our sense of nature, which we have cultivated since long ago. The technology encourages mass-production of single kind of specie while manipulating life. It
does not fit with human culture and our perspective of life and nature. We should not rely on the Food Safety Commission to decide this significantly important issue. We should spend a lot of time to
discuss with experts who have broader knowledge and wide perspectives. We should not let the discussions focus only on the food safety.

2) Birth and Growth with Pain

According to Safety Assessment, high spontaneous abortion, fetal mortality and stillbirth rates are commonly observed in Cloned Animals produced by using Somatic Cell Nucleus Technology. These developmental defects have been attributed to placental problems. The fetus tends to show symptoms such as a hypertrophy of internal organs or dropsy.
For example, calf fetuses that die right after the birth show heart, cardiac and kidney structure deficiencies. They also have problems with their tendon structure. Calf fetuses that survive one week after the birth showed surface rewarming, respiratory system deficiency, ascites, fat disease, peromelia and digestive organ dysfunction.

These problems are attributed to the deficiency in recapitulation of embryonic gene and the mother experiences miscarriage and a lot of pain. The fetus that is born from the unhealthy mother's body likely
to have gene deficiency. "Newly Developed Technology" gives animals mental and physical pain. Such technology certainly is harmful to animal welfare and should not be accepted.

3) Safety Tests

The Special Research Team concluded that in theory the DNA of cloned cows and pigs, that survived six months, share the same base sequence as the donor. It is not the creation of a brand new kind of living body therefore it is not possible for the cloned cows and pigs to develop allergies. To confirm his conclusion, toxicity and allergy tests of cloned animal meat and milk were conducted on rats and mice.
They were fed cloned cow and pig milk. The results showed there are no threats from cloned animal meat and did not detect any allergic reactions.

However environmental factors, mental stress or other complicated factors cause allergies. Therefore such tests are not legitimate. Moreover humans and rats/mice are different, so the testing results
are not convincing.

4) High Risk of Abnormality in Off-Springs

Safety Assessment concluded that once cloned animals survive a certain length of time, their growth will stabilize and they will develop in a healthy way. Also, off-spring of the cloned animals by artificial
insemination will be healthy and normal.

However it has been only ten years, since the first cloned animal was produced in the UK. Therefore nobody has conclusive evidence of the future of cloned animals’ off-spring. It is risky to conclude that
the off-spring will be healthy and normal. Genes change according to the environmental shifts. Human cannot control the changes in environment, thus any unexpected phenomenon can occur anytime. It is
nonsense to conclude the off-spring are safe, at this point.

5) Cloned Animals and Mass Producing Products

Safety Assessment reports that 3,374 embryos of Cloned Animals from Somatic Cell Nucleus developed 317 cow fetuses. This means there is only 9% rate of success. Most of the attempts end up in miscarriage or implantation does not take successfully, after artificial insemination. The Ministry of Agriculture, Forestry and Fisheries stated that it is unrealistic to use cloned animal food as commercial
products, since the success rate is so low (Ministry of Agriculture, Forestry and Fisheries Committee, House of Councilors, March 4, 2009)

The first generation of cloned animals have high a mortality rate, but Safety Assessment concluded that when cloned animals survived more than six months, the quality of meat is as good as the animals bred by artificial insemination. Therefore the meat is safe. This conclusion is a direct path to mass production of cloned animal meat. However the problem is that off-spring of cloned animals are not created by
cloning, so the products that use the off-spring's meat will not be labeled as "cloned meat", when they are sold. This will mislead a lot of consumers. People have shown discomfort about cloned animal
food, yet consumers will have no way of knowing whether the products they buy contain cloned meat or not.

6) Cloned Animals and Import

Once Japan confirmed that cloned animal food is safe, this opens the gate to cloned animal meat import, from countries such as the US. As we experienced in the BSE safety measures, it is impossible us to keep our eyes on to the meat processing that happens overseas. Japan should not accept cloned animal meat from the US. Japan imports half of the food it consumes, thus Japan should strictly regulate food imports, which will secure the safety of imported food

Since the end of World War II, meat consumption in Japan has risen sharply. This has caused a decrease in Japan's food self-sufficiency rate, increase in obesity or other diseases. We do not need any other forms of meat, because a lot of people are concerned about their health and are trying to reduce meat consumption.

7) Losing Biodiversity

Over the centuries, all living forms have evolved in the complicated environment on earth. Genes and our bodies are changing constantly to fit in the environment. Biodiversity is necessary.

However cloning destroys biodiversity. Clone technology demolishes uniqueness of individuals, genes and spices and biodiversity. Risks of cloned animal mass production on biodiversity should be carefully
assessed.

8) Life Ethics

Standardizing one specie effects various parts of our life and environment. However the focus of the discussions and the debates is only on "food safety". The food safety commission makes all the
decisions. This is not logical and fair. People in Japan should play a very important role in such important discussions, since the new technologies like cloning conflict with our sense of life and nature,
which we have cultivated for a long time in our history.

A lot of Japanese people are not comfortable about eating cloned animal meat. From this, we can assume that the business opportunities for cloned food is small. Japanese people do not want their tax money to be spent on such meaningless research and the government should know this.

* 80% of People are against using Cloned Animals for Food.