Royal Hospital for Women Department of Reproductive Medicine Template for response Part B of the Ethical Guidelines on the Use of Assisted Reproductive Technology in Clinical Practice and Research, 2007 This template has been provided to prompt feedback. Questions are not compulsory. You may manipulate this template to suit your desired submission – including the addition of organisational logos. Please delete the questions you do not wish to address. Submission via NHMRC Public Consultation Website Once you have created your account, please upload your competed template to the NHMRC public consultation website. Submission via post or email The ‘offline submission form’ MUST accompany your submission. To assist the ART Working Committee in the consideration process, please submit your comments as a Word document (or equivalent). Not confidential Template for response Name: Department of Reproductive Medicine Royal Hospital Organisation*: for Women, Randwick, NSW *Please only include the name of the organisation here if the submission reflects the views of the organisation 5 Ethical principles for clinical practice of ART General Questions Section 5.2 Q6. Paragraph 5.2.1 – Should there be exceptions to the restrictions/limitations on accumulating gametes/embryos in some situations? e.g. for fertility preservation in children, young people and adults undergoing chemotherapy, for the purposes of preimplantation genetic diagnosis, and/or for women with reduced ovarian reserve. Restricting the accumulation of gametes/embryos does not apply to current practise and is often performed for reasons of fertility preservation, low ovarian reserve, advanced maternal age and PGD. This should be taken into account. 6 Donation of Gametes Specific Questions Section 6.1 (see also Section 7.1) Q11. Should there be a standard way that data is collected and stored to facilitate linkage? o If so, how? o Should this guidance be included in the ART guidelines? There should be a national registry. The NSW registry collects this data. If it was national this would also make it easy to make sure the donor did not donate to more than five families across Australia Not confidential Template for response Q14. What assistance is required to support parents in telling their children about their genetic origins? o Should this guidance be included in the ART guidelines? o How, and by whom, should this assistance be provided? e.g. Is there a role for community practitioners such as GPs and maternal-child health nurses? Parents should be supported and assisted in a standardised way by counsellors at the clinic in which the ART was performed. A protocol should be developed and links to other resources be given. Section 6.2 (also relevant to donated embryos) Q16. In the best interest of the child, should there be an age limit for: o male gamete donors? o female gamete donors? o Male and female gamete providers for donated embryos? If so, what do you think the age limit(s) should be? There should be an age limit for anonymous donors (male 45 years, female 35 years) in order to maximise the chance of pregnancy and reduce the burden of disease. There should not be an age limit on known donors as family/genetic linkage may outweigh the other issues. Q17. Should there be an age limit for female recipients of gamete or embryo donation? o If so, what do you think this age limit should be? Perhaps there should be an age limit of 50 however more importantly the health of the recipient should be thoroughly assessed and risks of pregnancy discussed. Mothers over 50 are at almost three times the risk of low birth weight, premature birth, and extremely premature birth; their risk of extremely low birth weight, small size for gestational age, and fetal mortality was almost double. Not confidential Template for response Section 6.5 Q20. In view of developments in other countries allowing women to receive compensation above medical and travelling expenses for donating eggs, should it be permissible for Australian women to also be compensated for the reproductive effort and risks associated with donating their eggs? (See also Section 13 Surrogacy) There are significant risks to women travelling overseas for anonymous egg donation including the risks with regards to multiple embryo transfer and unknown genetic origins which is detrimental to the psychological health of the child. Australian clinics should be able to compensate women for egg donation and comply with the donor register so that the health of the child is cared for. Section 6.10 – 6.11 Q24. Do you think that the current ethical guidance is adequate? o Should information about the number and sex of half-siblings be available to donor-conceived persons? o Do you think that more information about half-siblings should be available to donor-conceived persons? e.g. identifying information. Information should be available with informed consent. IVF Australia has a program called siblinks that allows half siblings to contact each other Specific Questions Section 8.3 Q38. Should limits apply to the duration of storage of gametes - recognising that if stored for fertility preservation purposes, they may not be used for decades? o If yes, what do you think the maximum duration should be? o If no, what difficulties do you perceive and how should the storage of gametes be managed? Embryo storage should be 5 years with assessment and review at that time Gamete storage should be ten years with review Not confidential Template for response 9 Information giving, counselling and consent Specific Questions Section 9.2 Q42. Among the information which should be discussed, should there be specific reference to the significance of biological connection between donor-conceived persons and the donors of gametes, and to the right of these donor-conceived persons to knowledge of their genetic parents and siblings? (see also questions in relation to Section 5 and Paragraphs 6.1.1 and 6.1.2) This must be discussed, many women find it hard to imagine a child and the impact of decisions on that child as they are simply focused on achieving a pregnancy. The dialogue regarding the health of the child must begin in early phases of counselling. Section 9.8 Q43. When a child or young person with stored gonadal tissue or gametes reaches adulthood, how should the ongoing consent arrangements be managed? i.e. the transition from parental consent to the consent of the individual. The age for consent for medical procedures Is generally 16 years however with regards to storing gametes if a payment was required many young adults would have difficulty with this and may make a decision they regret later. This is something to consider. Not confidential Template for response 10 Record keeping and data reporting Not confidential Template for response 11 Sex selection Specific Questions Section 11.1 Q49. Are there any circumstances under which it is appropriate to allow sex selection for non-medical purposes? e.g. for family balancing, to replace a lost child, for cultural purposes? 6 out 10 staff were against sex selection in any situation. 4 out of 10 members were open to sex selection however long term data is still needed in terms of the risks to the child. This depends on whether an IVF/ICSI/PGD embryo is at increased health risk as compared to a naturally conceived pregnancy. There is some data suggesting slight increased health risks in IVF babies (hypertension) however we do not have large amounts of long term data for PGD. Q50. Do you think that it is ethically acceptable for ART to be available to individuals solely for non-medical sex selection purposes, e.g. for family balancing, to replace a lost child, for cultural purposes, when the individuals are neither infertile (physically or socially), nor have reduced fertility? This should not be medicare rebateable 12 Preimplantation genetic diagnosis Not confidential Template for response 13 Surrogacy Specific Questions Section 13.2 Q57. In view of developments in other countries, should there be compensation, more than expenses, for gestational mothers congruent with the reproductive effort contributed? Gestational mothers should be appropriately compensated more than just expenses. Not confidential Template for response 14 Innovations, training and quality assurance Not confidential