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FDA tries to downplay these figures, stating that although a “substantial number of pigs were lost around the time of birth . . . these losses were slightly higher in the group comprised of progeny derived from clonesitalic added (FDA, 2006: F??). Increases in pre-weaning death rates of 21% and 85% for progeny of Hamline and Duroc clones, respectively, compared to progeny of non-clone comparators do not constitute “slightly higher” death rates. Again, FDA interprets data in such a way to minimize the potential effect of cloning.

The study also included data on blood clinical chemistry and hematology at three points during the pigs life: between 3 and 30 days old, between 12 and 15 weeks old, and at approximately 24 weeks old (see Tables F-12a and F-12b in FDA, 2006). Data were taken on 18 hematology parameters and 35 clinical chemistry parameters. Just after birth, more hematology values for offspring of comparators were considered outliers compared to those of offspring of clones. Thus, some 5.5% of all the hematology values for offspring of comparators were considered outliers compared to 3.9% of the hematology values for offspring of clones. By the end of the study, the rate of outliers in the hematology values had declined in offspring of comparators from 5.5% to 3.5%, while that figure increased in offspring of clones from 3.9% to 4.9%. The clinical chemistry parameters show a similar pattern. At the start of the study, the rate of outliers of clinical chemistry values for offspring of comparators vs offspring of clone was similar—3.4% and 3.2%, respectively. By the end of the study, the rate of outliers in clinical chemistry values had declined in offspring of comparators 3.4% to 2.7%, while that figure increased in offspring of clones from 3.2% to 4.3%. The finding that the percentage of outliers for both hematology and clinical chemistry parameters increases over the course of the study for offspring of clones, while it decreases for offspring of comparators, suggests that clones may have more problems later in life.

The FDA looks at the 18 different hematology variables and the 35 different clinical chemistry variables and attempts to explain away any differences as not having much biological relevance or how the values could be artifacts based on handling or when the animal was fed. It’s as though the FDA is trying to interpret the data in a way to lead to the conclusion that all these blood measurements do not really differ between offspring of clones and offspring of comparators.

In sum, contrary to FDA, we feel the data on offspring of clones are disturbing— particularly the increase in preweaning death rates of offspring of clones compared to offspring of comparators and the increases in the rate blood measurements (both hematology and clinical chemistry) being considered outliers (e.g. extreme values) to increase over time with the offspring of clones while it decreases over time with offspring of comparators. The fact that any differences were seen in offspring of clones compared to offspring of comparators deserves much more scrutiny. Clones are known have much higher preweaning death rates compared to non-clones. The fact that preweaning death rate of offspring of clones was higher, depending on clone source, compared to offspring of non-clones, suggest that some of the adverse health impacts in clones are being passed on to their offspring and so should deserve much more scrutiny. Instead, FDA tries to

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