Vishnee Seenundun
Consultation Co-ordinator
HFEA
Paxton House
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.

Sincerely,

Tania Simoncelli
Marcy Darnovsky