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Science & Society

No time to waste—the ethical challenges


created by CRISPR
CRISPR/Cas, being an efficient, simple, and cheap technology to edit the genome of any organism, raises
many ethical and regulatory issues beyond the use to manipulate human germ line cells

Arthur L Caplan1, Brendan Parent1, Michael Shen2 & Carolyn Plunkett1,3

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he term “CRISPR” has gained a lot of 1980s, but it is only during the past few years the scientific and clinical benefits, while the
attention recently as a result of a that scientists realized their potential to edit other camp argues that editing the human
debate among scientists about the the genomes of any organism, from microor- germ line is too unsafe, or crosses an invio-
possibility of genetically modifying the ganisms to plants to human cells and, most lable ethical line [3].
human germ line and the ethical implica- controversially, human embryos. The ......................................................
tions of doing so. However, CRISPR is not CRISPR/Cas system is not a breakthrough
just a method to edit the genomes of embryo- technology in the sense that it enables “. . . there is a danger that
nic cells, as the public discussion might genome editing; biologists have been using CRISPR’s affordability and
have implied; it is a powerful, efficient, and transcription activator-like effector nucleases
reliable tool for editing genes in any organ- (TALENs) and zinc finger nucleases (ZFNs)
efficiency could run roughshod
ism, and it has garnered significant attention to edit genomes for some time. However, over long-standing and valid
and use among biologists for a variety of those technologies are expensive, technically concerns about the generation
purposes. Thus, in addition to the discussion challenging, and time-consuming, as they and release of [. . .] GMOs.”
about human germ line editing, CRISPR require protein engineering to target specific
raises or revives many other ethical issues, DNA sequences. CRISPR/Cas, in contrast,
......................................................
not all of which concern only humans, but recognizes its target sequence via guide RNA However, rather than the use or not of
also other species and the environment. molecules that can be cheaply and easily CRISPR to edit human germ cells and
...................................................... synthesized. A standard molecular biology embryos, there are more immediate ethical
laboratory can now edit genes or whole concerns that need to be addressed. CRISPR
“. . . CRISPR raises or revives genomes of many organisms, as CRISPR/Cas is already being used to modify insects,
many other ethical issues, not does not require sophisticated knowledge or animals, plants, and microorganisms and to
expensive equipment. produce human therapeutics [4]. Since such
all of which concern only work has been going on for years—or even
humans, but also other species

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his has rekindled the ethical debate decades—the CRISPR technology may not
and the environment” about modifying the human germ appear to create new ethical problems in
line. Notwithstanding the talk about these contexts. However, there is a danger
...................................................... “designer babies,” CRISPR/Cas offers new that CRISPR’s affordability and efficiency
CRISPRs are short DNA sequences with possibilities to render humans immune to a could run roughshod over long-standing and
unique spacer sequences that, along with range of diseases, or to repair fatal gene valid concerns about the generation and
CRISPR-associated (Cas) proteins, constitute defects in a human embryo. Prominent release of genetically modified organisms
an adaptive immune system in many bacte- researchers have therefore called for a (GMOs). The recent characterization of a
ria and archaea against invading bacterio- voluntary moratorium on germ line genome new type 2 CRISPR system from Francisella
phages [1]. By using short RNA molecules modification in humans until scientists and novicida demonstrates that the toolbox of
as a template, Cas makes highly sequence- ethicists have jointly analyzed the implica- genome editing technologies is ever-
specific cuts in DNA molecules that can be tions of doing so [2]. The debate boils down expanding [5]. Consequently, there is an
exploited to insert genes or to precisely to two sides in a “go/no-go” standoff. One urgent need for effective, global regulations
modify the nucleotide sequence at the cut group insists that research on human germ that govern the testing and environmental
site. CRISPRs were first identified in the line editing should advance in order to reap release of GMOs.

1 Division of Medical Ethics, New York University Langone Medical Center, New York, NY, USA.
2 Institute for Systems Genetics, New York University Langone Medical Center, New York, NY, USA
3 Philosophy Department, The Graduate Center CUNY, New York, NY, USA. E-mail: cplunkett@gradcenter.cuny.edu
DOI 10.15252/embr.201541337 | Published online 8 October 2015

ª 2015 The Authors EMBO reports Vol 16 | No 11 | 2015 1421


EMBO reports Ethical challenges with CRISPR Arthur L Caplan et al

Current national and international regula- Agency (EFSA) conducts risk assessments, potentially eradicate disease by eradicating
tions provide inadequate guidance and over- while final approval of a genetically modified disease vectors and invasive species [8].
sight for these applications. As such, they do animal or plant falls to the European This involves research with the Aedes
not foster public trust in the safety of Commission (EC). Analogous to the USA, aegypti mosquito, which transmits dengue
CRISPR-edited organisms or the regulatory human therapeutic applications are regu- fever, and certain subspecies of the Anopheles
agencies charged with monitoring them. The lated and approved by the European Medici- mosquito that carry the Plasmodium para-
concern is that public misunderstanding and nes Agency (EMA). Other countries with site. Researchers at academic centers and
mistrust of GMOs will hinder scientific intense biomedical research programs like- private biotech firms are exploring so-called
progress and valid uses of CRISPR. Thinking wise have their own regulatory and over- gene drives to block disease transmission
through—and getting right—the regulations sight schemes. Internationally, there is no by editing the female mosquito so as to
and research ethics for these applications of unified guidance for the modification of non- render it incapable of carrying the disease.
CRISPR might also help to create an ethical human organisms other than the Biological Others aim to induce sterility in male
framework for human germ line editing. and Chemical Weapons Convention, which mosquitos to prevent reproduction, or limit
seeks to prevent research into and develop- the lifespan of their offspring. Such methods

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n the USA, the regulation of genetically ment of biological weapons. could effectively destroy an entire species
modified animals and insects is done by and could have significant environmental

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a number of regulatory agencies that ome applications of CRISPR in consequences.
comprise the Coordinated Framework for animals improve current standard Gene drive is a powerful tool that makes
the Regulation of Biotechnology, which was practices in the biomedical sciences. it more likely that the edited trait will be
created in 1986 to facilitate inter-agency For example, some research projects require passed on to offspring through sexual repro-
regulation of biotechnology. Its scope and animal lines that are specifically bred for duction. When genetically modified organ-
regulatory approach has not been revisited certain mutations. Using CRISPR to generate isms are introduced into the environment
since 1992 [6], but individual agencies these lines produces less genetic variability and mate with wild-type organisms, their
within the Coordinated Framework—the than standard breeding techniques and helps offspring generally have a 50% chance of
Food and Drug Administration (FDA), the researchers to introduce mutations that inheriting the modified genes (Fig 1). The
US Department of Agriculture (USDA), and more accurately represent the human introduction of a few edited mosquitos or
the Environmental Protection Agency (EPA)— genetic defects they study [7]. Though there animals is therefore unlikely to have much
have issued their own guidelines on particular are standing ethical issues implicated by this of an effect. However, gene drive actively
applications. practice, such as animal welfare, using copies a mutation made by CRISPR on one
...................................................... CRISPR for this purpose does not challenge chromosome to its partner chromosome and
existing regulations of laboratory animals. thereby ensures that all offspring and subse-
“The concern is that public Other applications in animals, however, quent generations will inherit the edited
misunderstanding and pose novel ethical concerns. In particular, genome. Over generations, this would lead
CRISPR could be used to replace expensive to a noticeable effect: for example, in lower-
mistrust of GMOs will hinder TALENs, ZFNs, and other methods of genetic ing transmission rates of dengue fever or
scientific progress and valid modification to improve food for human malaria. The use of gene drives, though, also
uses of CRISPR” consumption. For example, CRISPR could be poses a much larger risk to the environment,

...................................................... used to increase the muscle mass of animals,


render farmed animals less susceptible to
as they have the potential to decimate an
entire species, eliminate a food source for
FDA guidance issued in 2009 states that disease, enhance nutritional content, or other species, or promote the proliferation of
the genetic modification of an animal, regard- create hornless cattle that are easier to handle invasive pests.
less of the animal’s use, meets the criteria for [4]. Research groups and private biotech
......................................................
veterinary medicine and is thus regulated by companies are currently assessing whether
the FDA’s Center for Veterinary Medicine such genome edits are feasible and safe. So “The use of gene drives,
(CVM). Genetically modified animals used to far, no genetically modified animal has ever though, also poses a much
study human diseases and drug testing are been approved for human consumption; the
regulated by the FDA’s Center for Biologics approval of genetically modified salmon for
larger risk to the environment,
Evaluation and Research. The Center for human consumption has been pending at the as they have the potential to
Food Safety and Applied Nutrition (CFSAP) FDA for years. But it is not clear what criteria decimate an entire species . . .”
and the USDA are brought in if the effects of a the FDA—or any other agency involved—
proposed modification will affect processes uses for assessing the safety of genetically
......................................................
or products that they oversee—for example, edited animals for human consumption. Scientists have already called for strict
food safety or pest control, respectively. These regulatory processes must be more biosafety measures and public review when
There are potential roles for the EPA, the transparent and accountable. it comes to introducing edited animals and
Department of the Interior and the US Fish insects into the environment [9]. Yet, many

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and Wildlife Service, on a case-by-case basis. here is another, potentially much questions remain unanswered: Can off-target
The EU has a more centralized regulatory more dangerous and controversial, effects of CRISPR—unanticipated mutations
scheme in which the European Food Safety application of CRISPR, namely to leading to undesirable phenotypes—be

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Arthur L Caplan et al Ethical challenges with CRISPR EMBO reports

Wild type MATING Gene drive

Gene drive chromosome Endonuclease gene WANTED


Wild type chromosome Possible effects: OUTCOME
• Render females incapable
Endonuclease Decrease
NO CUT of carrying a disease
incident of
CUT • Induce sterility in males malaria or
• Limited lifespan of offspring dengue fever

BREAK

NON-HOMOLOGOUS HOMOLOGOUS
END JOINING RECOMBINATION

SIDE EFFECTS

Mosquito larvae
are an important food
source for many species.

Mosquitoes are an important food


1 Drive 1 Drive 2 Drives source for many bird species.
1 Wild type 1 Mutated
target site …
CHANGE OF ECOSYSTEM

Wild type Gene drive


Anopheles

Figure 1. Gene drives can be used to alter population-wide traits.


A gene drive is preferentially inherited by all offspring and would quickly spread itself in the target population. The endonuclease cuts the homologous wild-type chromosome;
repairing the break using homologous recombination therefore copies the gene drive onto the wild-type chromosome. Gene-drive technology could be used to eradicate
diseases, such as malaria or dengue fever, by targeting wild populations of disease-transmitting mosquitoes but could have unanticipated secondary effects on other species.
Figure adapted from [9].

controlled? What are the effects on animals plants have gone on for decades in the USA TALEN-edited organisms would no longer
or humans who eat genetically edited insects and Europe, and, more recently, globally. classify as transgenic organisms in sensu
or animals? Will wiping out an entire Agriculturally important plants have strictu.
species—albeit invasive, or disease-bearing, been genetically manipulated to make these In the USA, the Coordinated Framework
such as mosquitos or ticks—upset the less susceptible to disease and pests, more under the purview of the USDA, the FDA,
ecological balance? Will edited organisms be productive, and more resilient to changing and the EPA provides guidance on agricul-
able to survive in natural environments, and climates. What makes CRISPR different from tural applications of genome editing, but
if so, for how long? Addressing these ques- other methods of agricultural genetic engi- their regulations only cover “plant pests”—
tions requires far more regulatory oversight neering is that it no longer requires the animals, bacteria, fungi, or parasitic plants
than currently exists anywhere in the world. insertion of foreign DNA into the plant that can directly or indirectly damage crop
genome using a virus, bacterial plasmid, or plants or parts thereof. This stipulation

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diting the genomes of crops and trees other vector system. Various commentators enters the regulatory process when parts of
is not new, and debates over the pros have therefore called for changes in the pest DNA are inserted into a host organ-
and cons of genetically modified (GM) regulation of GM plants because CRISPR- or ism, or when certain viral vectors are used.

ª 2015 The Authors EMBO reports Vol 16 | No 11 | 2015 1423


EMBO reports Ethical challenges with CRISPR Arthur L Caplan et al

The plant pest regulations also govern edits CRISPR- or TALEN-edited plants without any eliminate an engineered trait—whether the
to insects that are detrimental to crops, foreign DNA should not be subjected to the original gene-drive edit or the counter
plants, and trees, whereas applications of same regulatory regime and risk assessment edit—anytime after introduction [9].
CRISPR that do not use pests or pest parts to as transgenics. Since the EU is the largest One approach to address this problem
induce genetic edits fall outside current regu- market for agricultural products in the world, would be so-called terminator genes or self-
lations. Since the regulations frame the inser- other countries are now waiting to see limiting genes that limit the lifespan of edited
tion of DNA as genetic material from a whether the EC will change its definition of organisms or make engineered organisms
“donor organism,” it is also unclear whether transgenic and its regulations before they more fragile or easy to kill. In addition, edited
the regulations cover copies of pest DNA that move on with marketing edited crop plants. insects and animals should also be tagged to
are synthesized in the laboratory. be able to assign responsibility and liability
......................................................
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he US Coordinated Framework for the for damages. It would also enable researchers

“Without clear safety and


Regulation of Biotechnology was to better track the flow of gene edits through
created to facilitate a unified a population of insects or animals.
testing guidelines, and public approach to biotech regulation, but it is no

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longer adequate in the age of CRISPR [6]. hese are not merely theoretical
engagement and discussion,
Even the EU’s stricter regulatory regime is scenarios. A private biotech company
the public’s trust in the safety not suitable to address all possible risks—in is developing GE mosquitos in Florida
of GE insects and animals will particular with gene drive—as it is designed with the aim of lowering the incidence of
follow the same path as GM to regulate transgenic organisms. Moreover, dengue fever by suppressing the population
food” given that CRISPR is cheap, easy to use, and of A. aegypti mosquitos. To date, the FDA
does not require sophisticated equipment or has not approved the trial; environmental
...................................................... expert knowhow, it has become a popular review and the public comment period are
The Animal and Plant Health Inspection technology worldwide, which will eventu- pending. Some Florida residents strongly
Service (APHIS), an arm of the USDA, ally require international standards for test- oppose the release of the GE mosquitos,
reviews applications for research on GM ing genetically edited organisms, releasing citing human safety and environmental
crops. APHIS has indicated that products them into the environment, and assigning concerns. They do have a point, as GE
resulting from CRISPR/Cas that only delete a liability for damage. Regulations should set organisms will not always move and behave
gene, in most cases, would not be regulated clear requirements for testing the safety and in predictable ways; GE mosquitos, for
because no new genetic material is inte- efficacy of edited organisms in carefully instance, even if released on an isolated
grated into the recipient genome. Substitu- controlled environments or contained island, might end up many miles away and
tions and insertions of genes would be settings that simulate their natural environ- have unanticipated effects on the environ-
reviewed on a case-by-case basis to deter- ments [8]. Gene drives in particular should ment such as crossbreeding with related
mine whether the inserted trait counts as a be approved only if the safety and efficacy species. Without clear safety and testing
pest. In recent years, APHIS has seen an of desired edits have been rigorously tested. guidelines, and public engagement and
increase in requests for non-regulation Finally, edited organisms should only be discussion, the public’s trust in the safety of
status by academic centers and biotech released in typical environments, whether GE insects and animals will follow the same
companies asking them to affirm that their on a farm or in a wild habitat, after public path as GM food.
products do not fall under current regula- consultation and appropriate consent of
......................................................
tions, and so do not warrant review for potentially affected populations.
safety and efficacy by federal agencies. The Regulations should also require the “It is not unreasonable to
current trend toward deregulation will development of methods to halt the effects think that, in the wrong hands,
promote research into a variety of applica- of edited insects or animals should they
tions of CRISPR, but the wide implementa- prove harmful to other organisms, the envi-
CRISPR could be used to make
tion of those edits without enforceable ronment, or humans. Such reversal, immu- dangerous pathogens even
oversight could be detrimental to ecosys- nization, and suppression drives would more potent”
tems, biodiversity, and human health. neutralize the effects of already-released
In contrast to the USA, the European Union gene drives by introducing new genes into
......................................................
(EU) has much stricter regulatory regime for the population to counter unwanted effects CRISPR is now being applied in many
genetically modified crops in agriculture. It from previous generations [9]. However, academic and industry laboratories around
requires an extensive risk assessment by EFSA these safety mechanisms are limited by the the globe. International treaties and policies
before the EC decides to grant or withhold same facts that limit all gene drives. As the are therefore required to govern the release
approval for use in the EU. EU regulation species must reproduce through multiple of GE organisms into the environment. The
currently considers all genetically modified generations for the desired trait to prolife- WHO’s “Guidance framework for testing of
crops or animals as transgenic—whether rate, the negative environmental impacts genetically modified mosquitos” for instance
this includes the insertion of foreign DNA caused by the original gene-drive population suggests updating the Cartagena Protocol on
or direct genome editing—and therefore cannot be immediately halted by a counter Biosafety [10]. Article 17 of the Protocol
subject to regulation and risk assessment. gene drive. Furthermore, natural mutations obligates parties to notify an International
However, there is ongoing debate arguing that cannot be prevented in the wild and might Biosafety Clearinghouse and affected nations

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Arthur L Caplan et al Ethical challenges with CRISPR EMBO reports

of releases that may lead to movements of would behoove these agencies to require that those who order biological material that
modified organisms with adverse affects on that researchers demonstrate sufficient could be misused have appropriate credentials,
biological diversity or human health. control mechanisms as a condition of using containment facilities, and training.
However, the document does not specify the CRISPR editing system.

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who will enforce the treaty, what prior test- There is yet another aspect of the genetic uch of the discussion about the
ing ought to have been conducted, what the editing of microorganisms to consider, as risks of CRISPR technology has
limits on organism viability should be, what CRISPR could also be used to synthesize and focused on using it to edit the
methods should be used to assess effects, or manipulate pathogens, including smallpox, human germ line. Yet, CRISPR has many
how to estimate damages or mitigate harms. the Spanish flu virus, avian H5N1 flu virus, potential therapeutic applications beyond
The treaty’s effectiveness is further limited and SARS. It is not unreasonable to think that, this specific use, ranging from cancer
by voluntary participation. Some significant in the wrong hands, CRISPR could be used to immunotherapy to treating infectious
players in the field of genetic engineering, make dangerous pathogens even more potent. diseases, to creating stem cell models of
including the USA and South Korea, are not ...................................................... disease. These applications constitute
parties to the Cartagena Protocol. genetic editing of human somatic cells and
“Ensuring that CRISPR/Cas the changes made are therefore not herit-

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RISPR is also an enormously power- does not become touted as a able. In cancer immunotherapy, current
ful tool for synthetic biology to research focuses on adoptive cell therapies,
generate microorganisms for a broad
panacea for all genetic illness wherein T cells are harvested from patients,
range of applications, from the production of is crucial for proper application modified ex vivo to increase their potential
pharmaceuticals, biofuels, or chemicals to and dissemination of the to destroy tumor cells, expanded in number,
the remediation of pollution or disease diag- technology” and infused back into patients. One particu-
nostics and treatment. Gene editing allows larly promising approach involves chimeric
synthetic biologists to design and edit whole
...................................................... antigen receptor T (CAR-T) cells, which are
genomes of bacteria and viruses with new The use of technology to increase the engineered to express receptors with the
properties, but it raises the same concerns pathogenicity of bacterial or viral disease specificity of monoclonal antibodies on their
about accidental or deliberate release of GE agents falls under the purview of the Biolog- surface. CAR-T therapeutics have proven to
microorganisms into the environment. ical and Toxin Weapons Convention be particularly effective in trials against
In the USA, the regulation of genetically (BWC), an international treaty designed to acute lymphoblastic leukemia in both adults
modified microorganisms is under the prevent the creation and storage of biologi- and children. As researchers work to eluci-
purview of various agencies: the FDA, the cal weapons. However, the BWC covers date the mechanism by which these thera-
EPA, and the National Institutes of Health state actors—at least those who have signed pies achieve a robust response in order to
(NIH), but they lack sufficient control and it—but it was not designed to address optimize these cells to survive and carry out
monitoring capacity. The NIH has guidelines private companies or individuals. Moreover, their effector function in vivo, CRISPR is
for the use of recombinant DNA technology, as the tools needed to design and manipu- becoming an attractive option to edit the
of which CRISPR is one, that require notifi- late pathogenic organisms and the exact properties of CAR-T cells. Another therapeu-
cation and containment procedures based genetic sequences and instructions to do so tic application of CRISPR might help to cure
on the organism’s pathogenicity, virulence, become more readily available, the latent infections with HIV or herpes viruses
communicability, and environmental stabil- effectiveness of the BWC to prevent the by targeting and “cutting out” viral DNA in
ity. However, research not funded by the misuse of biological tools and knowledge is infected human cells.
NIH is not subject to these guidelines. The increasingly limited. With the rapid application of CRISPR/Cas
EPA requires notification of new chemical One way to achieve some control would in clinical research, it is important to
production, which covers some commercial be to regulate the tools of synthetic biology, consider the ethical implications of such
applications of synthetic biology, but the notably DNA synthesis. Many companies that advances. Pertinent issues include accessi-
agency relies on voluntary reports and does offer DNA primers, molecules, or even whole- bility and cost, the need for controlled clini-
not perform proactive audits and does not genome synthesis already monitor orders for cal trials with adequate review, and policies
monitor smaller scale operations. The FDA specific sequences from pathogenic organ- for compassionate use. Many cell-based
requires that drugs and biologics be proven isms. While this is an important move therapies come at a considerable cost, particu-
safe and effective before entering the by industry to prevent misuse, it does not larly patient-specific immunotherapies and
market, which covers synthetic biology- include all companies; moreover, an increas- stem cell treatments. Adding customized
based human therapeutics, but it does not ing number of companies are expanding their gene editing on top of that will further push
require specific containment methods to customer base beyond academia and industry the price of such treatments well out of the
prevent accidental release or design controls to private individuals. One possibility to reach of those with average means and
such as terminator genes. Only the NIH’s address this problem is to take the industry’s insurance, to say nothing of those who are
guidance was designed specifically to voluntary commitment further and create an uninsured, destitute, or rely on national
address genetically modified microorganisms, international clearinghouse with which health services to decide what is to be made
yet it is also the agency with the least regula- genetic sequence producers and sellers must available to patients. It also raises the issue
tory authority. As CRISPR becomes the register. It would require all registered compa- of educating patients to secure informed
primary method of genetic engineering, it nies to monitor their orders and make sure consent for research trials and clinical use.

ª 2015 The Authors EMBO reports Vol 16 | No 11 | 2015 1425


EMBO reports Ethical challenges with CRISPR Arthur L Caplan et al

clinical trials is already a challenge for regu- References


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