Good morning, and thank you for the opportunity to speak.
I'm an active stem cell scientist and I'm also chief of research at the Hospital for Sick Children, which is one the largest child health research institutes in the world. I am also deputy scientific director of the Stem Cell Network.
My colleagues have spoken about recent progress in stem cell research and its application to the clinic in Canada and worldwide. These really are exciting times for stem cell research. In particular, these new approaches to reprogramming cells from adult tissues into stem cells that regain the potential to make all the cell types of our body--so-called induced pluripotent stem cells, or iPS cells--really have transformed the way we think about studying human disease in a petri dish.
Already the Ontario iPS facility located at SickKids, for example, is taking samples of tissues from patients with developmental disorders such as congenital heart disease, neuro-developmental problems such as Rett syndrome and autism, and lung disorders like cystic fibrosis, and developing banks of patient-specific stem cells, these iPS cells. Then we can take these cells, distribute them to scientists, coax those cells to form the appropriate cell types in the petri dish—heart muscle cells, nerve cells, and lung cells, for those particular diseases--and then study those cells to determine what goes wrong in the disease and then how to fix it with new therapies.
In the future, however, this whole concept of being able to take adult cells and make stem cells, pluripotent cells that make every cell type, gives us the opportunity to think about population-based banks of normal iPS cells that could serve as sources of cells for cell therapy for many different diseases. We're not there yet. The technologies for generating iPS cells and for differentiating them into the right cell types for therapy, such as bone marrow stem cells, nerve cells, etc., are just not efficient enough yet to make such banking worthwhile. But the rapid progress of science here tells us that this will come in the future. And we need to stay on top of the science to be ahead of the opportunities to translate new advances into broadly available stem cell therapies for Canadians.
Science is moving extremely fast in this area, and this, of course, has ongoing implications for the regulatory environment for stem cell research. In Canada, human stem cell research, embryonic stem cell research, and iPS cell research are all governed by three separate regulatory instruments. There's the Assisted Human Reproduction Act, AHRA , the Tri-Council Policy Statement: Ethical Conduct for Research Involving Humans, the TCPS--we all like these acronyms--and the Canadian Institutes of Health Research's Updated Guidelines for Human Pluripotent Stem Cell Research. So we have the act, the tri-council statement, and CIHR's guidelines.
Of these, only CIHR's guidelines were really established specifically to address the ethical issues of all human pluripotent stem cell research, including the newly developed technologies we've been talking about that do not involve derivation of stem cells directly from human embryos. The CIHR has a stem cell oversight committee that is mandated to provide ethics review across the country of all human pluripotent stem cell research funding applications in CIHR-funded institutions in Canada. The guidelines cover essentially all of the major pluripotent stem cell initiatives that are taking place in Canada in academic institutions. And although they don't have regulatory application, they would have strong moral suasion on any commercial entities that are dealing in this area, most of which have arisen as offshoots of academic programs.
However, at present, the Canadian policy framework is in a bit of a state of flux. The tri-council policy statement is currently being revised by the Interagency Advisory Panel. As well, the constitutionality of several of the provisions of AHRA, the Assisted Human Reproduction Act, have been challenged before the Supreme Court of Canada, and the decision still outstanding. Furthermore, the AHRA is overdue for its mandated parliamentary review, which has the potential to have real impact on the field because of all these recent advances in stem cell research, which were certainly not contemplated by the crafters of the act. Moreover, given that only one regulation, regarding consent, has actually been adopted pursuant to the AHRA since it came into force in 2004, various aspects of the existing legislation do not have the necessary regulations in place.
So we have a lack of clarity regarding the application of present policy frameworks to new and emerging stem cell technologies, and that creates uncertainty for scientists, regulators, funders, and members of the public alike. It also has the potential to have an unintended impact on the advancement of research, for example, by restricting the parameters of permissible research in Canada.
Responding to these challenges in an informed, balanced, and evidence-based manner is crucial to both the continued success of the field of stem cell research--you've heard how strong that field is in Canada--and of course, on the other side, to the maintenance of public support for and trust in this work.
As an example of some of the issues that are unclear in the regulatory environment, definitional ambiguity--a terrible thing--occurs throughout. It creates a significant area of confusion for the application of these different provisions, particularly in the Assisted Human Reproduction Act.
For example, the legislation provides that human reproductive material, which is the basis of the legislation in the act, means a sperm, an egg, or other human cell, or a human gene, and includes any part of them. That's almost everything. If you actually interpret that norm literally, it could be construed in such a broad manner as to include almost any human cell or tissue, including iPS cells, as human reproductive material. Clearly that doesn't make any sense. A cell that you grow in a petri dish is not human reproductive material and cannot be used in human reproduction.
Given that iPS cells don't require the use of the material that we would normally consider as human reproductive material--that is, early embryos, eggs, or sperm--it seems that iPS cell research, unless it itself is being used to create reproductive material, should not be covered by the AHRA. Bringing iPS cell research under the ambit of that act would introduce more policy and regulatory hurdles, further uncertainty, and then potentially impact the growth and direction of the field in Canada.
The CIHR stem cell oversight committee has already considered these issues and has determined that the generation of iPS cells from tissue samples does not require the approval of SCOC, or stem cell oversight committee, because it does not involve the derivation of material from human embryos. It has to go through normal informed consent, but the use of any pluripotent cells that are derived that way would need SCOC oversight.
Interestingly, as the use of stem cells, pluripotent and otherwise, moves towards the clinic, I think the regulatory environment is actually clearer about their use in the clinic than it is about their research uses. Any cell-based therapy that requires extensive growth of cells outside of the body would fall under Health Canada regulation or the Food and Drug Administration in the United States. The extensive safety and efficacy data that is required before any new therapy can be introduced in clinical trials and eventually to market would be no different for stem cells than any other therapy. No special regulation is required, but the regulatory barrier for the application of stem cell trials, as was seen for the Geron embryonic stem cell trial for spinal cord injury, is appropriately high and should remain high.
The policy development committee of the Canadian Stem Cell Network, of which I am co-chair with Dr. Bartha Knoppers, who has probably appeared before this committee many times, is developing a policy statement on these issues around the advances in stem cell research and the regulatory environment. We propose the following overriding principles for regulation in the area of stem cell research and its application.
First of all, recognize the continued importance for ongoing scientific input into law and policy making in order to foster informed decision-making; encourage respect for scientific freedom while ensuring that any limitations that are placed on the research are justified in a free and democratic society; and promote the use of clear and transparent principles in regulatory frameworks, which should be harmonized across all regulatory instruments, against which new developments in research can be evaluated.
So these are exciting times, there are challenges, and I think the scientists, the regulators, the ethicists, and the clinicians need to work together.
Thank you.