WHO Expert Advisory Committee on

Developing Global Standards for Governance

and Oversight of Human Genome Editing

HUMAN GENOME EDITING:

POSITION PAPER
WHO Expert Advisory Committee on Developing
Global Standards for Governance and Oversight
of Human Genome Editing

HUMAN GENOME EDITING:

POSITION PAPER
WHO Expert Advisory Committee on Developing Global Standards for Governance and Oversight of Human Genome Editing. Human Genome
Editing: position paper

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Contents
Acknowledgements............................................................................................. iv
Executive summary............................................................................................. vi
Background information..................................................................................... 1
Preventing premature use of human genome editing.......................................... 2
Governance framework....................................................................................... 2
Recommendations.............................................................................................. 3
Leadership by WHO and its Director-General.......................................................................... 3
International collaboration for effective governance and oversight ................................. 4
Human genome editing registries.............................................................................................. 4
International research and medical travel .............................................................................. 4
Illegal, unregistered, unethical or unsafe research and other activities ........................... 4
Intellectual property..................................................................................................................... 5
Education, engagement, and empowerment.......................................................................... 5
Ethical values and principles for use by WHO.......................................................................... 5
Review of the recommendations................................................................................................ 5

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Acknowledgements

The governance framework and the recommendations on human genome editing form a pair of reports
that have been developed by the WHO Expert Advisory Committee on Developing Global Standards for
Governance and Oversight of Human Genome Editing.

These publications have been developed under the direction and coordination of Ms Katherine Littler (Co-
lead, Health Ethics & Governance Unit), under the overall guidance of John Reeder (Director, Research for
Health) and Soumya Swaminathan (Chief Scientist).

Dr Piers Millett (consultant, United Kingdom of Great Britain and Northern Ireland) provided support to
the project and was the lead writer of the publications as well as the meeting reports of the Committee.
Dr Emmanuelle Tuerlings (consultant, Switzerland) also provided support and contributed to the writing
of the documents.

WHO wishes to thank the following individuals and organizations for their contributions to the development
of these publications.

WHO Expert Advisory Committee on Developing Global Standards for Governance and
Oversight of Human Genome Editing

WHO is most grateful to the Co-Chairs, Dr Margaret Hamburg, former Commissioner of the U.S. Food and
Drug Administration and former Foreign Secretary, National Academy of Medicine, United States of America
and Justice Edwin Cameron, Inspecting Judge of Correctional Services, South Africa, and the members of
the Committee for their invaluable guidance, expertise and great support throughout the project and the
conceptualization and development of the three publications (by alphabetical order):

Dr Mohammed Alquwaizani, Saudi Food and Drug Authority, Kingdom of Saudi Arabia (member until 2
June 2020)
Professor Ewa Bartnik, Universtiy of Warsaw, Poland
Professor Françoise Baylis, Dalhousie University, Canada
Professor Alena Buyx, the Technical University of Munich, Germany
Professor Alta Charo, University of Wisconsin, United States of America
Dr Hervé Chneiweiss, CNRS, INSERM, France
Associate Professor Jantina De Vries, University of Cape Town, South Africa
Dr Cynthia Holland, the Australian and New Zealand Infertility Counsellors Association, Australia
Professor Maneesha S. Inamdar, Jawaharlal Nehru Centre for Advanced Scientific Research, India
Professor Kazuto Kato, Osaka University, Japan
Professor Robin Lovell-Badge, The Francis Crick Institute, United Kingdom

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Dr Jamie Metzl, Atlantic Council & OneShared, United States of America

Dr Ana Victoria Sánchez-Urrutia, SENACYT, Panama
Professor Jacques Simpore, Université Ouaga I, Burkina Faso
Professor Anne Wangari Thairu-Muigai, Jomo Kenyatta University of Agriculture and Technology, Kenya
Professor Xiaomei Zhai Chinese, Academy of Medical Sciences & Peking Union Medical College, China

All authors and members of the WHO Expert Advisory Committee on Developing Global Standards for
Governance and Oversight of Human Genome Editing declared their interests according to WHO standard
procedures. None of the interests declared were found to be significant.

To the experts and organizations who participated in the in-person meetings, the online meetings and
webinars and provided valuable inputs through sharing their experiences and insights on human genome
editing. The Annexes of the Governance Framework and Recommendations on Human Genome Editing list
the participants in meetings, consultations and webinars.

The many individuals and organizations who participated in the first and second online consultations
on the governance framework on human genome editing. Their valuable inputs and comments have
contributed to the development of the governance framework.

The technical contributions of colleagues at WHO headquarters: Dr Avni Amin, Dr Samvel Azatyan,
Efstratios (Stratos) Chatzixiros, Dr Erika Dueñas Loayza, Mr Ghassan Karam, Dr Ivana Knezevic, Dr Olufemi
Taiwo Oladapo, Dr Yuyun Maryuningsih, Dr Soumya Swaminathan, Dr Jacqui Stevenson, Professor John
Reeder, Dr Andreas Reis, Dr Anna Laura Ross and Dr Si Hyung Yoo.

The authors of the two reports commissioned by the WHO Expert Advisory Committee on Developing
Global Standards for Governance and Oversight of Human Genome Editing: Ms Nicola Perrin (independent
consultant), Dr Güneş Taylor and Dr Christophe Galichet (The Francis Crick Institute), United Kingdom.

Colleagues at WHO headquarters Ms Elena Egorova, Ms Gloria Haselmann, Anne-line Nippierd Imbsen and
Ms Sophie Spillard for their administrative support throughout the project. Special appreciation is also
expressed to the external teams who provided administration support for the meetings that have been
held in Singapore (14 November 2019) and in Cape Town, South Africa (24-26 February 2020).

WHO gratefully acknowledges the financial support provided by Wellcome Trust for this project and
for the development of these publications.

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Executive summary

The recent application of tools, such as CRISPR-Cas9 (clustered regularly interspaced short palindromic
repeats; Cas9 nuclease), to edit the human genome with the intention of treating or preventing disease
and the gaps in our scientific understanding, in addition to some of the proposed applications of human
genome editing, raise ethical issues that have highlighted the need for robust oversight in this area. The
COVID-19 pandemic has clearly demonstrated the importance of using new tools and methods to combat
serious diseases and highlighted the potential benefits of human genome editing research. It also reminds
us of the need to develop technology carefully, with robust testing and quality assurance measures in
place to maximize benefit and minimize harm. The balance between benefit and harm, safety and speed,
and innovation and access is relevant to all of human genome editing.

In December 2018, the World Health Organization (WHO) established a global, multidisciplinary expert
advisory committee (the Expert Advisory Committee on Developing Global Standards for Governance and
Oversight of Human Genome Editing, hereafter called the Committee) to examine the scientific, ethical,
social and legal challenges associated with human genome editing (somatic, germline and heritable).
The Committee was tasked to advise and make recommendations on appropriate institutional, national,
regional and global governance mechanisms for human genome editing. Its remit did not include a review
of matters to do with safety and efficacy. Committee members were drawn from each of the WHO regions
– Africa, the Americas, South-East Asia, Europe, Eastern Mediterranean and Western Pacific.

The 18 members of the Committee worked for two years and developed several products and new
initiatives. The governance framework on human genome editing, along with the recommendations of
the Committee, form a set of two publications that provide advice and recommendations on appropriate
institutional, national, regional and global governance mechanisms for human genome editing. A position
paper on human genome editing provides a summary of these two publications.

During its work, the Committee reviewed the current literature on human genome editing research and its
applications, considered existing proposals for governance and relevant ongoing initiatives, and gathered
information on a range of topics relating to the different uses of this technology. The Committee consulted
widely with individuals and representatives of organizations including, but not limited to, United Nations
(UN) and other international agencies; academies of science and medicine as well as other national or
professional bodies; patient groups and civil society organizations.

The governance framework and the recommendations on human genome editing form a pair of reports
that have been developed by the WHO Expert Advisory Committee on Developing Global Standards for
Governance and Oversight of Human Genome Editing. This position paper provides a summary of these
two publications.

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Background information

The World Health Organization (WHO) Expert Advisory Committee on Developing Global Standards for
Governance and Oversight of Human Genome Editing (hereafter called the Committee) was charged with
reviewing the literature on current human genome editing research and its applications, considering
existing proposals for governance and relevant ongoing initiatives, and soliciting information about
societal attitudes towards the different uses of this technology.

To better understand the scope of activities relevant to its charge, the Committee mapped current,
potential and speculative human genome editing research (governance framework, Box 3).

To update previous efforts to map the current scientific and technical capabilities, the Committee
commissioned a report on important developments, including in the understanding of relevant basic
science, different types of human genome editing, the tools being used for genome editing and the targets
being exploited.

To improve gathering of data on what research is underway or planned for human genome editing, the
Committee, early on in its work, recommended that a registry be set up using the International Clinical
Trials Registry Platform,1 which WHO subsequently established.

To understand what policies governed research and development and clinical use of human genome
editing in different countries, the Committee made use of a 2020 survey of documents relevant to policy
(legislation, regulations, guidelines, codes and international treaties) for germline human genome editing
(not for reproduction) and heritable germline human genome editing (for reproduction).2

To ensure a participatory process in the course of its work, the Committee consulted widely and solicited
information about societal attitudes towards a number of areas of research and clinical use of human
genome editing technology. The Committee consulted with international organizations, regional
organizations, national health ministries, national regulatory authorities, national research institutes,
national boards of technology, patient groups and patient advocates, civil society organizations, indigenous
groups, campaign groups, industry associations, private companies, national academies, bioethics
committees, professional societies, universities, medical schools and academic research institutions, as
well as other relevant experts and interested parties. Participants from 29 distinct groups contributed to
the Committee’s meetings. The Committee also held two in-person and 15 online topic-specific meetings
drawing on contributions from 71 distinct groups. The Committee has also developed a glossary of key
terms intended for a non-specialist audience.

1 WHO launches global registry on human genome editing (accessed 27 June 2021).
2 Baylis F, Darnovsky M, Hasson K, Krahn T. Human germline and heritable genome editing: the global policy landscape. CRISPR J.
2020;3(5):365–77. https://doi.org/10.1089/crispr.2020.0082

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Preventing premature use

of human genome editing

To help ensure heritable human genome editing does not proceed prematurely to clinical trials, the
Committee recommended, and the WHO Director-General subsequently made, a policy statement in July
2019 clarifying that “it would be irresponsible at this time for anyone to proceed with clinical applications
of human germline genome editing.”3

Governance framework

The Committee was tasked to advise and make recommendations on appropriate institutional, national,
regional and global governance mechanisms for human genome editing. Its remit did not include a review
of matters to do with safety and efficacy of human genome editing.

The Committee developed a governance framework that draws from good practices in the governance
of emerging technologies and applied them specifically to human genome editing. The framework is
intended to help those tasked with strengthening oversight measures, regardless of whether this is at the
international, regional, national or institutional level. The Committee recognized some of the necessary
governance structures and processes already exist; these may need to be reinforced or amended. Where
such structures and processes are lacking, gaps must be filled. The governance framework provides tools
to help.

To maximize the positive impact and minimize the potential harms of human genome editing, the
Committee identified procedural and substantive values and principles to inform both how and what
decisions are made (governance framework, Table 3).

To assist in tailoring oversight measures to human genome editing, the framework explores five specific
challenges in: (i) postnatal somatic human genome editing; (ii) prenatal (in utero) somatic human genome
editing; (iii)  heritable human genome editing; (iv)  human epigenetic editing; and (v)  enhancement. For
each, the Committee identified a series of questions that should be considered when reviewing or creating
oversight measures.

3 Statement on governance and oversight of human genome editing (who.int) (accessed 27 June 2021).

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To help take advantage of the full range of individuals and organizations able to influence or control the
direction of research and possible future uses of human genome editing, the governance framework
reviews 12 sets of tools, institutions and processes. These range from laws and regulations to professional
self-regulation and the role of professional bodies, to public advocacy and activism. It is intended as an
indicative list of options for those working to strengthen oversight measures and will need to be tailored to
the specific circumstances of the user.

To demonstrate how the various components of the governance framework come together in practice, the
Committee used seven scenarios: (i) somatic human genome editing clinical trials for sickle-cell disease;
(ii)  somatic human genome editing clinical trials for Huntington disease; (iii)  somatic human genome
editing and unscrupulous entrepreneurs and clinics: (iv) somatic human genome editing and epigenetic
editing to enhance athletic ability; (v)  heritable human genome editing (for reproduction); (vi)  heritable
human genome editing and unscrupulous entrepreneurs and clinics expanding assisted reproduction; and
(vii)  prenatal (in utero) somatic human genome editing clinical trials for cystic fibrosis. These scenarios
illustrate the practical challenges that might be encountered in the future when implementing good
governance for human genome editing research.

To ensure that the governance framework reflected broad input and would be suitably comprehensive,
realistic and practical, the Committee shared draft copies of the text during its development. The Committee
held two online consultations on the governance framework. The first consultation was held from 15
January to 7 February 2020 and resulted in 325 unique responses from individuals and organizations in
32 countries. The second consultation was held from 14 July 2020 to 19 August 2020 and resulted in 69
unique responses from individuals and organizations in 23 countries. Comments received were used by
the Committee to refine and improve the governance framework.

Recommendations

Following careful reflection and deliberation, the Committee produced a series of recommendations in
nine discrete areas. The Committee noted that its recommendations are subject to the limits of WHO’s
mandate and resources. In implementing these recommendations, the Committee wished to stress the
importance of avoiding unfunded mandates.

Leadership by WHO and its Director-General

WHO and its Director-General should demonstrate both scientific and moral leadership, by: (i)  being
open about the opportunities and challenges inherent to human genome editing; (ii) clearly stating the
ethical aspects of human genome editing (including a statement on somatic human genome editing to
address equitable access to the benefits of research and priority setting and, for heritable human genome
editing, at a minimum, reiteration of the Director-General’s statement of July 2019); and (iii) outlining the
consequences of failing to address the ethical issues before us if we develop and use technologies without
prior careful reflection and intentional collaborative decision-making.

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International collaboration for effective governance and oversight

WHO should work with others to develop and implement a shared vision for an on ongoing international
process to: (i)  identify and develop points of agreement or convergence; (ii)  establish a process for
identifying key decision points; (iii) explore opportunities for collaborative engagement, standard-setting,
investigation and oversight; and (iv)  share information on relevant existing and planned policies (laws,
regulations and guidelines).

In the interim, the Director-General should institute a cross-institutional approach, including to: (i) task the
regulatory strengthening and capacity building teams within WHO’s Department of Essential Medicines and
Health Products to begin working on integrating human genome editing into their activities; (ii) convene
a meeting of regulators from Member States on the feasibility of international agreements, capacity-
building needs and possibilities for harmonization; and (iii) task the Science Division to convene meetings
on human genome editing in each of the six WHO regional offices with regulators, medical and scientific
leaders, patient groups, civil society organizations and other relevant bodies.

Human genome editing registries

WHO should: (i) ensure that clinical trials using somatic human genome editing technologies are reviewed
and approved by the appropriate research ethics committee before inclusion in the Registry of human
genome editing clinical trials; (ii) request that national and regional clinical trials registries make use of
keywords to identify clinical trials using human genome editing technologies; (iii) develop an assessment
mechanism to identify clinical trials using human genome editing technologies that may be of concern;
(iv) establish a small expert committee to regularly monitor the clinical trials Registry and to develop and
review a set of international standards for clinical trials involving human genome editing for the clinical
trials Registry; and (v) support members of the scientific community to develop an additional basic and
preclinical research registry.

International research and medical travel

The Director-General, in consultation with his new Science Council, should make a policy statement that
somatic or germline human genome editing research should only take place in jurisdictions with domestic
policy and oversight mechanisms. WHO, with guidance from the Science Council, should integrate into all
of its relevant activities a focus on fostering responsible international research and medical travel.

Illegal, unregistered, unethical or unsafe research and other activities

WHO, with advice from its recently established Science Council, should charge the Science Division to
lead an effort to create a multisector collaboration to develop an accessible mechanism for confidential
reporting of concerns about possibly illegal, unregistered, unethical and unsafe human genome editing
research and other activities.

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Intellectual property

WHO should: (i) work with others to encourage relevant patent holders to help ensure equitable access to
human genome editing interventions; (ii) encourage industry to work with resource-constrained countries
to build capacity to take advantage of human genome editing inventions; and (iii) convene a meeting of
those holding or applying for patents relevant to human genome editing, industry bodies, international
organizations, such as the World Intellectual Property Organization and the World Trade Organization, and
those involved in establishing or running relevant patent pools to explore the potential for the adoption of
appropriate ethical licensing requirements.

Education, engagement, and empowerment

The Director-General should: (i)  call upon the United Nations Secretary-General to establish a United
Nations interagency working group on frontier technologies that facilitates global dialogue and produces
a report outlining the implications of innovative technologies, including human genome editing, and the
ethical frameworks to guide their application; and (ii) call for an inclusive dialogue on the future of human
genome editing, including scientific, ethical and societal aspects.

WHO should: (i) develop models of best practice of inclusive multidirectional, multistakeholder dialogue,
and supporting materials, that can be applied to human genome editing; and (ii) explore how best to
include in decision-making under-represented groups that are interested in human genome editing.

Ethical values and principles for use by WHO

WHO should charge the health ethics and governance unit in the Science Division to lead an effort to create
a set of officially endorsed and clearly defined ethical values and principles for use by its expert committees
and in WHO deliberations. These values and principles should be built on public health goals and priorities.
These should go beyond the WHO workforce, and provide an important road map for progress towards the
Organization’s goals.

Review of the recommendations

In no more than 3 years, WHO’s Science Division should initiate an extensive review of these recommendations
and the progress made to implement them. This review should not take longer than 18 months and
should take into account scientific, technological, and societal changes, adequacy of implementation and
assessment of impact, and potential future needs or concerns.