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WASHINGTON INSIDER
Winter 2005
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President's Council on Bioethics
After a long summer break, the President's Council convened again in September,
on the 8th and 9th. The topic was "Ethical Caregiving in Our Aging Society."1
The council has been considering this topic over several meetings. Its importance
cannot be doubted. As experience with the aftermath of legalizing euthanasia in the
Netherlands shows, the "reason" for which people request assisted suicide is often,
in reality, that they are depressed. With increased social mobility and the breakdown
of the extended family in the United States, the elderly are frequently placed in
"elder-care facilities." If these are for-profit centers, the care is sometimes substandard.
2 In any case, loneliness and isolation often breed depression. Since some
people will argue that assisted suicide in these cases is "compassionate," it is important
to consider ethical alternatives before the political momentum behind such proposals
grows, in the states or in Congress.
It is expected that before the October meeting, the president will announce reauthorization
of the council, whose term was set to expire on September 30, for
another two-year term.
Leon Kass, who has served as the council's chairman since its inception, announced
that he would be stepping down as chairman, but would remain as a member
of the council. Catholics and others concerned about bioethics owe Kass a debt
of gratitude. While neither his substantive views nor his policy positions met with
universal approval, he worked hard as chairman to raise the visibility of bioethics
issues nationally, and to develop practical policy proposals.3
The president announced that Edmund Pellegrino, M.D., professor emeritus of
medicine and medical ethics on the faculty for clinical bioethics at Georgetown University
Medical Center, would be replacing Dr. Kass as chairman. Dr. Pellegrino has
had a long and very distinguished career in bioethics. He has always been a voice of
reason in a field too often ruled by utilitarian ethics. He is one of the founders of
Georgetown's Center for Clinical Bioethics. Dr. Pellegrino serves on the Circle of
Advisors for the Center for Human Life and Bioethics at the Family Research Council
(FRC) and serves on the editorial board of this journal.
International Developments
Before assuming the chair at the bioethics council, Dr. Pellegrino served on the
drafting committee for a statement by the United Nations Educational, Scientific and
Cultural Organization on the subject of bioethics. The general conference of UNESCO
had called for the preparation of a declaration in October 2003.
The UNESCO international bioethics committee, after receiving criticisms on a
first draft from governments and others, released its "Universal Draft Declaration on
Bioethics and Human Rights" in June.4 The draft, which imposes obligations only on
member states, will go to the UNESCO executive board and then to its general
assembly (which will meet from mid-September to mid-October).5
Not surprisingly for a "consensus" document of an international committee, the
draft is vague. For instance, and critically, it contains no definitions of essential
terms, such as "human being" and "human dignity." It does contain some promising
"principles," such as (a) "The interests and welfare of the individual should have
priority over the sole interest of science or society" (article 3); (b) "For persons who
are not capable of exercising autonomy, special measures are to be taken to protect
their rights and interests" (article 5); and (c) "Any preventive, diagnostic and therapeutic
medical intervention is only to be carried out with the prior, free and informed
consent of the person concerned, based on adequate information" (article 6). However,
the devil is in the details. What does "autonomy" mean, and what are its limits?
How significant is "sole" in reference to the interest of science or society from which
the individual is to be protected? What "special measures" are to be taken, for
example, for embryonic human beings, who are certainly incapable of exercising
autonomy? Only time will tell how these important matters are addressed by the
executive committee and the assembly.
In another important development, the European Union announced that it would
not develop a single "European" standard for the patenting of drugs derived from
bioengineering efforts. Instead, individual nations would be free to adopt their own
standards. The EU made this decision because of the controversies surrounding the
derivation and use of human embryonic stem cells.6
Senator Frist and Efforts to Undermine
the President's Policy on Stem Cell Research
The big news over the summer was the stunning announcement by the majority
leader of the Senate, Bill Frist (R-Tenn.), that he would support the effort to roll
back the president's policy. The defection of the majority leader makes it all but
certain that the Congress will overturn the president's policy.
Frist said he would support legislative efforts to create additional human embryonic
stem cell lines by permitting federal funding for such lines whenever they are
created. (The president's policy, in contrast, limits federal funding to any lines that
were in existence before August 9, 2001.) Frist stated that he supported the use and
destruction of embryos kept in cryogenic storage by in vitro fertilization (IVF) clinics.
Frist took the same position in 2001 when the issue was the focus of intense
national debate.7 (It will be recalled that in the election preceding that Congress, the
candidates were split on this issue—Al Gore supported human embryonic stem cell
research and cloning, while George Bush opposed both.) However, during the intervening
years, Frist, who will be a candidate for the Republican presidential nomination
in 2008, gave signs that he no longer held this position. At least it was widely
believed that, whatever his personal views, he would not publicly undermine the
president. Those hopes were dashed on July 29.
It is worth paying close attention to Frist's statement.8 It embodies most of the
logical, factual, and ethical mistakes made by those who advocate the use of human
embryonic stem cells.
Senator Frist began his long statement on the Senate floor by accurately placing
this question in ethical and historical terms. As Frist acknowledged, "stem cell research
presents the first major moral and ethical challenge to biomedical research in
the twenty-first century." Thus, we must "get it right," because "it will define us as a
civilized and ethical society forever in the eyes of history." Correctly understanding
that the twenty-first century will surely be the "Biotech Age," with great promises
and great perils intertwined, Frist stated, "We are, after all, laying the foundation of
an age in human history that will touch our individual lives far more intimately than
the Information Age and even the Industrial Age before it." To guide us in this age,
we need, according to Frist, principles that will "stand the test of time."
From that promising beginning, Senator Frist went rapidly off track. He said he
felt compelled to support research using IVF embryos because (1) the embryos will
be destroyed in any case, and (2) research using them holds the promise of great
cures. He stated that drawing the line at the destructive use of frozen IVF embryos,
while protecting others, was "principled" and would be effective.
Frist's argument in many ways turned upon an analogy he made to organ
transplantation. Frist, who is a transplant surgeon himself, pointed out that he removes
an organ for transplantation only after the donor has died. He noted that the
medical community had agreed upon "brain death" as the criterion for making a
determination that the subject had died. However, this very analogy proves the case
against Frist and against the use of IVF embryos. With organ transplantation, the
donor is dead (assuming that we accept, as some bioethicists do not, the brain-death
criterion), while with embryonic stem cell research, the human being (the embryo) is
alive; indeed, it is the "transplantation" that kills it.
Sadly, Frist, a man of medical science, slipped into the practice of many who
would convince us to destroy embryonic human beings—he used misleading language.
For instance, he referred to the IVF embryo as a "blastocyst." This language effectively
dehumanizes the embryo, suggesting that it is something different from a human being.
Embryos go through various stages, including the blastocyst stage, but they remain
human beings, as they were from the first moment (the single-cell zygote stage).
Further, it is simply untrue to say IVF frozen embryos will be destroyed "anyway."
As Richard Doerflinger discussed in his last column, efforts at embryo "adoption" are
well under way. Furthermore, regardless of one's view of the morality of embryo adoption,
there is all the moral difference in the world between a situation in which an embryo
dies (after or during IVF storage) and one in which a scientist kills a still-living embryo.
The former is a natural death (although admittedly in bizarre circumstances); the latter is
the intentional killing of a human being. Every human being, embryo or not, is going to
"die anyway"—that is the fate of everyone who has ever lived (in the womb or out).
However, our civilization has never allowed that fact to furnish an acceptable reason to
kill any particular living human being today. Rather, our central ethical premise is that
the life of every living human being is to be respected equally with every other. In the
1920s, the world's most eminent medical community, in Germany, descended into the
contrary view, and the tragic, if "logical," results of that descent are instructive.9
Frist recognized an ethical dilemma, but he asserted that we could solve it by
increased ethical oversight (by the National Institutes of Health). Although this
argument is frequently made by advocates of embryo research, it is obviously illogical.
"Ethical oversight" of unethical practices does not magically make them ethical. (Nor
does "parental consent," another "ethical fix" that Frist insists on. Parents cannot
licitly consent to the killing of their children.)
Thus, it is clear that the line Frist would draw, justifying the destruction of IVF
embryos but not other embryos, is far from "principled." Whatever the senator's
subjective intention, his support for research on embryonic stem cells is, in fact,
unprincipled. There is no principle by which some human beings may be freely
subjected to lethal violence that does not endanger all other human beings as well.
It is in this light that one must view Frist's argument that IVF embryos should
be used in destructive research because doing so holds the promise of great medical
cures and treatments. First of all, it is simply untrue that research using embryonic
stem cells is more promising than research using non-embryonic (adult, cord blood,
or placental) stem cells. In fact, the only cures and treatments for living human
beings that have been achieved to date use non-embryonic cells.10
Remarkably, Frist acknowledged this. He even acknowledged that techniques
may be on the horizon11 that will make it "unnecessary" in the future to destroy
human embryos to get embryonic stem cells.
However, Frist asserted that problems with existing human embryonic stem cell
lines make it necessary to create new and additional ones. He claimed that existing
lines are fatally "contaminated" by mouse feeder cells, and that insufficient lines are
available for research in any case. Both assertions are false. The "contamination" (if
it exists) can be removed,12 and there are many existing stem cell lines that have yet
to be made available.13
Of course, Frist's point about the scientific need to create additional lines, as
well as his argument about their medical promise, is ultimately irrelevant. Even if
great cures and treatments were certain to be achieved and no embryonic stem cells
lines were currently available for research, it would still be unethical to kill one
(embryonic) human being during research, even research that aims to help another.
Frist claimed to be enunciating "principles that would stand the test of time." Sadly,
he announced no principles at all.
Politically, however, the fact that Frist is a doctor and surgeon (as well as
Senate majority leader) means his defection on this issue is likely to have a powerful
effect on other senators (and will provide them with political "cover" as well). There
is a strong bipartisan political effort to overturn the president's policy. If a bill such as
the Stem Cell Research Enhancement Act of 2005 (S. 471) does pass in the Congress,
and President Bush vetoes it as promised, the president will have an unparalleled
opportunity to teach the nation about the science and ethics of stem cell research,
and we must hope he will use it.
State Developments
Frist's position was echoed by another powerful politician with national ambitions,
Governor Mit Romney of Massachusetts. Faced with his legislature's effort to
pass a bill authorizing human embryonic stem cell research and cloning, Romney
pledged to veto the bill, and offered an alternative. Romney's alternative would have
permitted IVF embryos to be used in destructive research if other embryos were
protected and cloning was banned. The legislature ignored his compromise offer,
however, and passed the bill over his veto.14 As passed, the Massachusetts bill contains
the all-too-common evasions—which include making false distinctions between
"pre-implantation embryos" (referring to the first fourteen days of embryonic life) and
other embryos15 and between "reproductive cloning" and somatic cell nuclear transfer.
16 The bill removes the protection of the law from the "pre-implantation embryo"
and authorizes the creation of human embryos to be destroyed in research.17
In California, the first stem cell research grants were made by the Independent
Citizens' Oversight Committee, as authorized by Proposition 71.18 However, the grants
were formal only—no money came with them. Indeed, there may never be any funds
to dispense if pending lawsuits against the Proposition 71 committee prevail in court.19
Texas opened a cord blood storage bank.20 Indiana, which outlawed cloning in
May, is soon to follow suit.21 (In a related development, Histostem, a South Korean
company, announced plans to open the world's largest cord blood bank in India.22)
While stem cell battles raged in many state legislatures, many of those legislatures
also continued to pass, or consider, bills that restrict abortion to one extent or
another, including partial-birth abortion bans, born-alive infant protection acts, and
parental consent and notification laws. Such state laws are likely to find their way to
the Supreme Court.
The Supreme Court
On September 30, John Roberts was sworn in as chief justice of the Supreme
Court, replacing William Rehnquist, and on October 3, President Bush nominated
Harriet Miers to replace Sandra Day O'Connor. The new justices will join a court that
will consider many issues of importance, including (1) a challenge to the attorney
general's ban on the use of drugs covered by the federal Controlled Substances Act in
assisted suicide in Oregon,23 (2) a challenge to New Hampshire's parental notification
law because it does not provide for a "health exception,"24 and, likely, (3) an appeal
of a circuit court ruling that overturned the federal Partial-Birth Abortion Ban Act.25 It
is also likely that the Court will soon hear an appeal from a federal district court's
ruling upholding an Ohio statute that provides for parental consent (not just notification)
before a minor girl may get an abortion.26
The upcoming decisions of the Supreme Court will play a vital role in shaping
our culture toward death or toward life. Many will test the holding in Planned Parenthood
v. Casey (510 U.S. 1309 [1994]) that the state has a valuable interest in protecting
life. The law in this area is unclear, and it will be the Supreme Court that provides
clarity. Therefore, it is vitally important to confirm judges who are honest about basic
science (no confusion or dissimilation about when life begins or what "cloning" is, for
example) and who respect the limited role of the judiciary under our Constitution.27
Marriage Protection
The federal Marriage Amendment (renamed the "Protection of Marriage Amendment")
languishes in the Congress. Thus, efforts to protect marriage are taking place
on the state level.
In 2000, 70 percent of Nebraska's voters approved a state constitutional amendment
limiting marriage to one man and one woman. The amendment was struck
down by a federal district court. The state is appealing the decision.28 It would not be
surprising if the Supreme Court eventually decides this and similar cases.
New York's highest court is currently hearing arguments in a lawsuit claiming
that the New York state constitution gives same-sex couples the right to marry. (A
lower court had granted that right.)29
In 2000, California voters approved Proposition 22, which defined marriage as
between one man and one woman. Nevertheless, in September, the California legislature
approved a bill that legalized same-sex marriage if performed in California. The
purported justification was that Proposition 22 applied only to couples married outside
the state, despite clear evidence that the people of California intended to cover all
marriages within California.30 The day after the new bill was passed, Governor Arnold
Schwarzenegger announced that he would veto it,31 which he did on October 3.
In Massachusetts, where their supreme court held that the Massachusetts constitution
permitted same-sex marriage, an effort to amend the state constitution by
ballot initiative to ban civil unions was certified by the attorney general. However, in
the best case, the measure will not appear on the ballot until 2008.32 At roughly the
same time, the Massachusetts legislature rejected an amendment that would have
legalized civil unions for same-sex couples while outlawing same-sex marriage.33
Conscience Protection
On July 7, the full Senate Appropriations Committee approved a weakened
version of a bill previously approved by the House to protect the freedom of conscience
of hospitals and doctors to refrain from performing abortions.34 The bill now
goes to a joint House and Senate conference committee, where it will be decided
whether the bill will contain strong or weak conscience protection language.
Meanwhile, in the states the conscience rights of pharmacists have risen to the
fore. In New Hampshire, for instance, state law allows the "morning-after pill" to be
sold over the counter (without a doctor's prescription). While that is regrettable, the
law does provide for conscience protection for pharmacists—they need not dispense
the pill if doing so violates their conscience.35 In Illinois, however, no such protection
exists. Rather, all pharmacists are required to sell the "morning-after pill" over the
counter. As a result, several pharmacists have sued, challenging the law.36 In Massachusetts,
lawmakers passed, over Governor Romney's veto, a bill requiring all hospitals
to provide the "morning-after pill" to rape victims. The bill also permits pharmacists
to distribute it over the counter (in consultation with a doctor).37 In California, a
bill requiring pharmacists to do so (unless they have previously notified their employer
of their objection to doing so) passed in the legislature. It is now awaiting
action by Governor Schwarzenegger, who has not said whether he will veto it.38
The federal Food and Drug Administration recently delayed final action on
whether to make the "morning-after pill" available over the counter.39
William L. Saunders, Jr.
Director and Senior Fellow
Center for Human Life and Bioethics
Family Research Council
Washington, D.C.
Notes
1
The council's report, "Taking Care: Ethical Caregiving in Our Aging Society," was
released on September 29. It is available online at http://www.bioethics.gov/reports/
taking_care/index.html.
2
Allan Carlson, "Elder Care Politics 101: How Misguided Public Policy Has Created
a Crisis," Family Research Council (FRC) Family Policy 14.4 (2001), http://
www.frc.org/get.cfm?i=WA03I68, and "Rebinding the Generations: Solving the Elder Care
Crisis," FRC Family Policy Lecture (November 21, 2002), http://www.frc.org/
get.cfm?i=PL03I01; Kenneth L. Connor, testimony before the Senate Special Committee
on Aging (October 20, 2003), http://www.frc.org/get.cfm?i=TS03J01.
3
William L. Saunders, Jr. "Furor over the President's Council's Bioethics Report,"
FRC Op Ed commentary (April 16, 2004), http://www.frc.org/get.cfm?i=AR04D03&f=
PR04D02.
4
U.N. Educational, Scientific and Cultural Organization, Universal Draft Declaration
on Bioethics and Human Rights (Paris: UNESCO, June 24, 2005), http://
portal.unesco.org/shs/en/file_download.php/11445d5a75d2306d7437f0626f35
e1c1Draft_EN.pdf
5
World Medical Association Ethics Unit, "Proposed UNESCO Declaration on Bioethics
and Human Rights," WMA Issue of the Month (August 2005), http://www.wma.net/
e/ethicsunit/whats_new_archives09.htm#.
6
"EU Will Abide Members' Different Biotech Laws," Wall Street Journal, July 19, 2005, A12.
7
Senator Frist, statement on stem cell research, 107th Cong., 1st sess., Congressional
Record 147.100 (July 18, 2001), S7846–S7851; and statement on embryonic stem
cell research before the Senate Health, Education, Labor, and Pensions Committee (September
5, 2001), http://frist.senate.gov/index.cfm?FuseAction=PressReleases.Detail&PressRelease_id=1071.
8
Senator Frist, statement on stem cell research, 109th Cong., 1st sess., Congressional
Record 151.106 (July 29, 2005), S9323–S9326; remarks as prepared for delivery,
http://frist.senate.gov/index.cfm?FuseAction=Speeches.Detail&Speech_id=257.
9
William L. Saunders, Jr., "The Human Embryo in Debate," in Human Dignity in
the Biotech Century, ed. Charles W. Colson and Nigel M. de S. Cameron (Downers Grove,
IL: InterVarsity Press, 2004), 115–135.
10
See, for example, Brad Hughes, "Real-World Successes of Adult Stem Cell Treatments,"
FRC Insight (October 4, 2004), http://www.frc.org/get.cfm?i=IS04J01.
11
See, for example, The President's Council on Bioethics, Alternative Sources of
Human Pluripotent Stem Cells, white paper (May 2005). See also "Production of Pluripotent
Stem Cells by Oocyte-Assisted Reprogramming," Joint Statement of Various Bioethicists
(June 20, 2005), http://www.eppc.org/publications/pubID.2374/pub_detail.asp.
12
In a study done by researchers at the Technion-Israel Institute of Technology in
Haifa, no evidence of human infection from embryonic stem cells grown on mouse feeder
cells was found (Michael Amit et al., "No Evidence for Infection of Human Embryonic
Stem Cells by Feeder Cell–Derived Murine Leukemia Viruses," Stem Cells 23.6 [June
2005], 761–771); see Gretchen Vogel, "Ready or Not? Human ES Cells Head toward the
Clinic," Science 308.5728 (June 10, 2005), 1534–1538. Researchers also found that cells
could be decontaminated and then used in humans; see Maria J. Martin et al., "Human Embryonic
Cells Express an Immunogenic Nonhuman Sialic Acid," Nature Medicine 11.2
(February 2005), 228–232.
13
According to the National Institutes of Health stem cell registry (http://
stemcells.nih.gov/research/registry/), there are seventy-eight approved stem cell lines eligible
for federal funding. Twenty-two of these lines are currently being shipped to researchers,
thirty-nine lines are still frozen, and sixteen failed to grow after being thawed.
(The status of one line is unclear.)
14
Gareth Cook and Scott Greenberger, "Romney Urges Changes to Stem Cell Bill,"
Boston Globe, May 12, 2005.
15
The term "pre-implantation embryo" or "pre-embryo" was originally developed to
mislead. (See William L. Saunders, Jr., "Embryology: Inconvenient Facts," First Things
148 [December 2004], 13–15). An embryo is an embryo. Before it implants, it is simply
an unimplanted embryo.
16
Of course, all cloning is reproductive, since all cloning results in the reproduction
of a living member of the human species. And somatic cell nuclear transfer is simply
the scientific definition of cloning.
17
An Act relative to Enhancing Regenerative Medicine in the Commonwealth, Massachusetts
Senate bill 2039 (June 2, 2005), Acts of 2005 (Session Laws), ch. 27, http://
www.mass.gov/legis/laws/seslaw05/sl050027.htm.
18
See my column in the Winter 2004 issue of the Quarterly (4.4, 671–674) for a
discussion of Proposition 71.
19
Edie Lau, "Stem Cell Funds Awarded," Sacramento Bee, September 10, 2005; Paul
Elias, "Lawsuit Hampers California Stem Cell Funding," Associated Press, May 10, 2005.
20
"State's First Cord-Blood Bank Opens Its Doors," Houston Chronicle, August 7, 2005, B2.
21
Act to Amend the Indiana Code concerning Health, Indiana Senate enrolled act
268 (May 23, 2005), http://www.in.gov/legislative/bills/2005/SE/SE0268.1.html.
22
"Banking on Cord Blood from India" (News in Brief), Nature Biotechnology 23.9
(September 2005), 1033–1034.
23
Gonzales v. Oregon, Supreme Court docket no. 04-623; Charles Lane, "Justices
to Hear Challenges to Oregon's Assisted Suicide Law," Washington Post, February 23,
2005, A6. See also my column in the Summer 2005 issue of the Quarterly (5.2, 237–
238) for a discussion of this case.
24
Ayotte v. Planned Parenthood of Northern New England, Supreme Court docket no.
04-1144; Linda Greenhouse, "High Court Re-enters Abortion Debate with Emotional Case,"
New York Times, May 23, 2005. The New Hampshire law permits a girl to ask a judge to
override the provision for parental notification, and it provides that notification is not necessary
if the girl's life is at risk. (One would think that it is precisely then, when a daughter's life
is at risk, that notice should be required.) In any case, adding a "health exception" to a parental
notification statute will render the statute useless, given the broad interpretation of "health" by
the federal courts to cover what amounts to mere mental unease. The FRC and Focus on the
Family submitted an amicus brief, which can be found at http://www.frc.org/get.cfm?i=CB05H01.
25
Carhart v. Gonzales, 413 F.3d 791 (8th Cir. 2005); Julia Preston, "Appeals Court
Voids Ban on ‘Partial Birth' Abortions," New York Times, July 9, 2005, final edition, A11.
See also my column in the Summer 2004 issue of the Quarterly (4.2, 250) for a discussion
of this statute and litigation.
26
Cincinnati Women's Services, Inc., et al. v. Robert Taft, et al., case no. 1:98cv289
(S.D. Ohio 2005); "Federal Judge Upholds Ohio Parental Consent Law, Delays Enforcement
to Allow Abortion Clinics Time to Meet Requirements," Kaiser Daily Reproductive
Health Report, September 12, 2005, http://www.kaisernetwork.org/gsa/dailyreports.jsp.
27
See, for example, Robert P. George, Judicial Activism and the Threat to the Constitution
(Washington, DC: FRC, 2005).
28
Citizens for Equal Protection v. Bruning, 368 F. Supp. 2d 980 (D. Neb. 2005).
29
Hernandez v. Robles, no. 103434 (N.Y. Sup. Ct. 2005); Samuel Maull, "Lawyers
Argue Gay Marriage before New York Appeals Court,” Associated Press, September 13, 2005.
30
For a critical analysis by a social liberal, see Debra Saunders, "A Marriage of Convenience,"
San Francisco Chronicle, September 8, 2005, B9.
31
Steve Lawrence, "California Senate Approves Bill Allowing Gay Marriage," Associated
Press, September 1, 2005; Michael Finnegan and Maura Dolan, "Citing Prop. 22,
Gov. Rejects Gay Marriage Bill," Los Angeles Times, September 8, 2005.
32
Raphael Lewis, "Reilly OK's 2008 Initiative on Ban of Gay Marriage," Boston Globe, September 8, 2005, A1.
33
Steve LeBlanc, "Mass. Legislature Rejects Proposed Amendment Banning Gay
Marriage," Boston Globe, September 14, 2005.
34
U.S. Senate Committee on Appropriations, "Appropriations Committee Reports
FY 2006 Labor, HHS, Education Spending Bill," press release, July 14, 2005, http://
appropriations.senate.gov/hearmarkups/07-14-05PRLaborHFull.htm.
35
Kathy McCormack, "Morning-After Pill Approved," Portsmouth Herald, June 17, 2005.
36
Associated Press, "Pharmacy Owners Sue Governor over Emergency Contraception Rule," September 14, 2004.
37
Scott S. Greenberger, "Lawmakers Override Governor's Contraception Veto," Boston Globe, September 16, 2005.
38
Mark Gladstone, "Bill Requires Pharmacies to Supply ‘Morning-After' Pill," Mercury News, September 9, 2005.
39
Joyce Howard Price, "FDA Delays ‘Morning-After' Pill, Seeks Public Comment
before Deciding Over-the-Counter Sales," Washington Times, August 27, 2005, A02.
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