METAPHYSICS IN GENETIC ENGINEERING: CRYPTIC PHILOSOPHY AND IDEOLOGY IN THE "SCIENCE" OF RISK ASSESSMENT

Philip J. Regal

1. Introduction

 There has been much concern that organisms that have been modified with powerful recombinant DNA techniques might sometimes be dangerous. Could it be unsafe to eat a particular 'transgenic' or 'genetically engineered' fruit or grain, for example?
    It is the question of ecological risks, though, that has been intensively discussed by scientists and government agencies for over a decade. This concern has been greatest because if dangerous new forms of life begin to reproduce in nature and spread, it is improbable that they could be recalled. Humans have been helpless to stop non-indigenous rogue species that have gone out of control and caused enormous economic damage, for example, such as fire-ants, zebra mussels, or killer bees in the Western Hemisphere, or Chinese mitten crabs in Europe.
    There has been more or less a consensus among those scientists who have published analyses of ecological risks that most genetically engineered organisms (GEOs) should be ecologically safe, though a minority could cause great problems. Yet after years of analysis and discussion, the scientific community is still divided over what this generality should imply for regulatory oversight.
    Industry and DNA research scientists tend to argue that careful oversight would cost them too much time and money, especially considering that the chances are that most laboratories are doing safe work. Their world is one of intense competition. And, despite the tens of billions of dollars that have been invested to develop biotechnology, many companies have difficulties raising enough venture capital even to stay in business. They argue that even a careful regulatory system could not guarantee complete safety.
    Other scientists and public interest groups have argued that although potentially dangerous projects will be in the minority, there must be a legitimate effort to screen them out. Though 100% safety cannot be guaranteed, a competent regulatory system could reduce the risks considerably and would be worth the cost.
    This disagreement over regulation has been exacerbated by the fact that it has proved impossible to draw a clear line that would divide planned projects into those for which risk evaluations will prove to be simple and inexpensive, and projects where data requirements could grow to be complex and expensive.
    It is under such pressures from competitive recombinant DNA scientists and industries, under pressures from governments hopeful that their huge investments will pay off, clashing with criticisms from less organized scientists and citizen groups, that risk assessment cultures have been evolving within government agencies and in industry. What sorts of cultures have been developing?
    The risks of primary concern have been ecological, yet there has been a tendency within the cultures of risk assessment not to staff with scientists who are educated in modern principles of ecology and evolution. One finds instead many lawyers, chemists, microbiologists, geneticists, agronomists. Government regulators tend not to ask ecologically relevant questions from applicants. They tend not to base broad policy decisions on ecological and evolutionary knowledge and principles. They tend not to sponsor ecological and evolutionary research and education programs that would strengthen the quality of risk assessment. They tend to make important decisions without providing clear scientific expanations.
    Yet the defenders of such trends within the cultures of risk assessment claim that they are being 'scientific' and that they are not sacrificing quality. How is this claim defended? How can non-experts claim to be making 'scientific judgments' if they do not gather scientific data and are not ready to detail in print how they evaluate what data there is? Their defense is based primarily on world-view, (or Weltanschauung), that is not recognized to be world-view.
    At one end of the spectrum of what various types of risk assessors mean by 'risk assessment,' when it is said that "we have this situation under control, we are experts in scientific risk assessment" this does not as it might seem necessarily mean that they know how to draw valid scientific conclusions.
    Instead there is a genre of risk assessors that speaks in the context of management science. To say that "we are experts in risk assessment" or that "we have sound risk assessment procedures" may mean that they have developed protocols for processing paper work; and "scientific risk assessment" means that the papers are routed past people with scientific degrees, whether their educations have been in appropriate fields or not, or whether their analyses are used in decisions or not. Quality is too often judged in terms of how efficiently paper work can be moved through the system. (Alternatives to this genre of thinking about risk assessment have been discussed in papers in Krimsky and Golding 1992)
    Managerial definitions of quality risk assessment beg us to ask what criteria biotech regulators use for developing the content of the forms to be filled out, for picking scientists to review the forms, and both for specific actions and broad policy decisions. In what ways do ancient philosophical ideas, ideology, and politics enter into 'scientific' decisions? Much of what passes for 'scientific thinking' in biotech risk assessment is world-view that is not recognized to contain metaphysical beliefs that have ancient cultural roots, such as essentialism and Platonic or Aristotelian cosmologies. It is called 'scientific thinking' because it follows the perspectives and reasoning of influential personalities in science.
    This will be the basic theme of the present essay. What are some examples of ancient philosophy and modern ideology that have been passing as empirical science? What can the history of the development of biotechnology reveal about the ways in which firm scientific knowledge and broader world-views have become commonly confused with one-another? Why did society wait so long to begin to deal with the potential down-side of biotechnology? What are the implications for whether society can safely continue to promote the use of recombinant DNA techniques?
 

 2: History

2.1 An Idealistic Beginning for Molecular Biology and Genetic Engineering

 Recombinant DNA techniques were developed beginning in the 1970s out of the visions, techniques, and discoveries of molecular biology. Molecular biology in turn had been earlier developed in significant part out of the reductionist and deterministic visions of Max Mason and Warren Weaver at the Rockefeller Foundation.
    It is now understood, as a result of the research of Pnina Abir-Am, Lily Kay, Robert Kohler, Edward Yoxen, and other historians of science, that in the 1930s Mason and Weaver used the financial and political resources of the Rockefeller Foundation to fashion and promote a new philosophy and practice of biology. The new biology would be based on philosophical reductionism agendas that had been suggested earlier by Hermann Muller and Jacques Loeb. Biology would become 'the chemistry of the gene.'
    Thus, from the 1930s to the present there have been two cultures of biological scientists. There have been traditional biological scientists, making investigations into the structure, physiology, evolution, behavior, adaptations, and ecology of diverse life forms on earth. Their intellectual roots go back to the anatomists, breeders, naturalists, and physiologists of the 18th and 19th centuries who studied organisms in their natural habitats and in the laboratory.
    And, there have been the molecular biologists, conducting research into the nature of genetic chemistry and protein synthesis, and promising that one day traditional biology will become obsolete and biology will be rebuilt by them 'from the ground up.' Their intellectual roots trace for the most part back to chemistry and physics. These scientists were mostly chemists and physicists and yet they came to claim that theirs was the 'true' approach to the study of life. Their claim to 'own' biology, a field of knowledge that lay largely beyond their expertise, rested on the reductionistic argument that they were developing knowledge of 'the' supposedly basic chemical substance of life.
    Mason and Weaver themselves were refugees from quantum physics. They sought to preserve ancient deterministic and reductionistic dreams against the growth of quantum mechanics, by transplanting the reductionistic/deterministic dreams that they considered to be 'true science' to a new biology. Thus, they not only sponsored new and powerful analytical techniques to find and characterize the hereditary material. They also encouraged the new community to use reductionistic/deterministic and utopian terms of discourse in applying for grants, reporting research findings, making awards, etc. (References in Abir-Am 1987, Kay 1993, Regal 1989)
    The dreams of Mason and Weaver were part of a venerable tradition. Theory reductionism or philosophical reductionism has long been tied to the ancient dream that one day all knowledge will be unified and reduced to concepts in the physical sciences, and will be reduced to simple deterministic predictive models that will allow control over physical, organic, and human nature.
    The social sciences and humanities will ultimately be reduced ontologically, epistemologically, and discursively to biology with no residue (e.g. Wilson 1975). Biology will in turn be reduced to chemistry, which will reduce to physics, which will reduce to a simple deterministic unity that will allow precise predictions at all levels of life.
    The quantum mechanics of the 20th century was only one decisive blow against this vision of the unity of knowledge. But the vision had become so much a part of Western intellectual thought, an ingredient in science policy funding, and so powerful a motivator for scientists, that it did not crumble in the face of mounting evidence against it. (Ayala and Dobzhansky 1974, Einstein and Infeld 1966, Fuerst 1982, Koestler and Smythies 1969, Lindley 1993, Mayr 1982, Popper 1982, Regal 1990, Rosenberg 1994)

2.2 Utopianism

 The new biology that Mason and Weaver aimed to shape would be not merely abstract scientific knowledge and theory, but would include a social agenda. The promoters and practitioners promised to determine the structure of the gene and to use this information to correct social and moral problems including crime, poverty, hunger, and political instability.
    From the perspective of a theory reductionist, it was logical that social problems would reduce to simple biological problems that could be corrected through chemical manipulations of soils, brains, and genes. Thus the Rockefeller Foundation made a major commitment to using its connections and resources to promote a philosophy of eugenics.
    The Rockefeller Foundation used its funds and considerable social, political, and economic connections to promote the idea that society should wait for scientific inventions to solve its problems, and that tampering with the economic and political systems would not be necessary. Patience, and more investment in reductionist research would bring trouble-free solutions to social and economic problems.
    Mason and Weaver helped create a network of what would one day be called molecular biologists, that had little traditional knowledge of living organisms and of communities of organisms. It shared a faith in theory reductionism and in determinism. It shared utopian ideals. It learned to use optimistic terms of discourse that brought grants and status. The project was in the general spirit of Bacon's New Atlantis and Enlightenment visions of a trouble-free society based on mastery of nature's laws and scientific/technological progress (e.g. Eamon 1994, Mcknight 1992).
    Historians such as Soraya de Chadarevian and Nicolas Rasmussen are in the process of detailing later phases in the development of molecular biology, during the 1950s, that were also wrapped in enthusiastic social idealism. For example, after the atomic bomb was developed and the atomic age was proclaimed, what is known today as molecular biology was promoted as a part of 'biophysics.' This was to be the peaceful side of physics that would solve untold human problems.

2.3 Philosophy or Ideology?

 One can argue that the social vision in which molecular biology was imbedded and that was promoted by the Rockefeller Foundation served conservative interests, whatever the politics of individual scientists. It infused society with reasons for resignation to a genetic fatalism. At the same time it raised calming expectations: science and technology would bring grace.
    Reductionistic visions had long served the interests of physicists and chemists. They served as blueprints of an intellectual/social hierarchy that mandated a place for them at the top, and that also helped them to obtain research support. These visions came to serve the interests of molecular biologists similarly. In this sense the theoretical simplification of life has been opportunistic. One can argue that the philosophies of theory reductionism and utopianism thus have graded into ideologies as they have become useful to a range of interests, both inside and outside of science, and that they should be called ideologies rather than philosophies.
    I do not object to this general argument. Philosophy has often served ideological functions. But I will not make an effort to characterize individual ideas as 'ideological' each time they have been used in self-serving ways, in contrast to detatched philosophy. This would distract from the main purpose of this essay which is to begin sketching the ways in which Western philosophical concepts have become confused for 'hard science' and have even become used in regulatory policy.

2.4 Idealists do not Prepare for Problems

The history of molecular biology helps to explain why its promoters did nothing to prepare their enterprise for the likelihood that there would be grave concerns and serious risks when genetic engineering would one day become possible. It helps to explain why the scientific community today is unprepared to deal with the potential risks and other societal, political, and economic issues raised by biotechnology.
    Science and society are becoming aware of the plethora of potential problems only at this late date in the history of molecular biology and biotechnology largely because the unbridled idealism and optimism of the social agenda that gave birth to that research community, and the self-interest that held idealism in place, left little room for doubts.
    There was also the contributing fact that so many of the early sponsors and practitioners were physical scientists who had little knowledge of or interest in patterns of evolutionary adaptation, or the tragic history of ecological disturbances by species that were introduced to new areas with idealistic expectations, etc. They were not experts in intricate economic and social issues. If the developing network had been more intellectually open, there might have been balanced discussions, more realistic expectations, and preparation for the future complications that genetic engineering would bring.

2.5 Asilomar: Too Little, Too Late, and no Follow-through

Doubts about the Grand Agenda of molecular biology did surface in the 1970s with the famous Asilomar and Gordon conferences. But the network of molecular biologists that had been woven on a loom of idealism was largely unprepared to deal in a few short days with the many doubts that suddenly arose once genetic engineering became a reality.
    Observers such as Clifford Grobstein have commented that virtually the only issue that was raised at these conferences that was actually pursued thereafter was the 'biohazard issue' -- the concern that a seemingly harmless 'non-wild-type' laboratory GEO might escape and unexpectedly turn out to be able to cause a global catastrophe. Academic ecologists ignored this debate among the molecular biologists. It seemed indeed improbable that organisms that are bred to be highly specialized for life in the laboratory and modified in some arbitrary way might escape and turn out to thrive in nature and even go on to do unprecedented damage.
    This biohazard issue was quite different from the 'biosafety issue' that began to concern academic ecologists by 1984. It was fast becoming possible to engineer 'wild-type' GEOs that would be able to thrive in nature. In some cases the traits that were to be added to them would not be arbitrary from an ecological point of view. There would be novel and powerful traits that could increase the competitive abilities of the host species or expand the range of resources that it could exploit. For example, if a new type of resistance to disease were added to a 'wild-type' fish or plant, it could give the transgenic population a great competitive advantage and make it a likely candidate to become a destructive rogue species.
    The earlier biohazard issue, though, became a dramatic 'attention-grabber' that unfortunately diverted discussion away from other important concerns that had been raised. Yet it was the most manageable concern, for it was unlikely to begin with, and it could in any event be dealt with by developing containment protocols. And thus the biohazard issue became traumatic for the DNA scientists but, in the end, the focusing of publicity on it allowed genetic engineering research to proceed. There would be no need to freeze or rethink the funding structures, systems of career ladders, and the broad social expectations that had been created. Grobstein wrote,

 Despite the creation of an NIH-led [National Institutes of Health] interagency committee for federal coordination, a forum for concerted deliberation on the excluded Asilomar agenda never came into existence. So the public policy debate and, to some degree, the public impression of recombinant technology remained fixed on worst-case scenarios symbolized by the Andromeda strain. (Grobstein 1986)

 3: Sociology

The leaders of the genetic engineering community -- Grobstein's 'special interest group' within the scientific community -- continued to focus on 'containment' as though it were 'the' sole issue of concern, and they did nothing to prepare their science, or society, for the other challenges that lay ahead. The issues that surely lay ahead included the engineering of ecologically competent GEOs that were intended to thrive in nature, food safety, and the enormous institutional and socioeconomic impacts that many expected.
    Molecular biology continued to train young scientists narrowly only in chemistry and physics -- sometimes also in physiology, microbial genetics, medicine, or agronomy. The biotech community retained its strong taste for theory reductionism, in addition to reductionistic laboratory methods, despite brushing closely with the fact that the entry of GEOs into the world of ecology, the food supply, and the economy would have intricate effects.
    Molecular biology continued to consider itself to be a predictive science even as promises were being made that genetic engineering would allow control at higher levels of intricacy and organization, where the emergent properties are not always well understood. Molecular biologists on the whole did little to educate themselves to the discoveries and conceptual developments in ecology and evolutionary biology.
    The recombinant DNA community had bad experiences with sensationalistic journalism. These, together with an increasing desire for industrial confidentiality, inspired an atmosphere of defensiveness and even secrecy in their community. Recombinant scientists developed strong ties with the business and financial world and many became entrepreneurial themselves. This alliance created an economically and politically powerful pressure block to oppose effective regulation (Krimsky 1991, Wright 1994). Public desires to regulate biotech for safety reasons were strongly opposed by leaders of the biotech community for economic reasons. Careful regulation of biotech would mean costs in terms of time and money for laboratory workers and industrialists alike. Moreover, the business community, with which recombinant DNA scientists were forging partnerships, had long held strong resentments against all sorts of regulation. The antiregulatory philosophy of the Regan/Bush administrations in the 1980s, and of neo-conservatives before and after the 1980s, are well known.
    One also saw a distinctive strain of 'rugged individualism' take root among some of the more entrepreneurial molecular biologists. It is distinctive in the sense that self-proclaimed 'individualists' of this species have not been adverse to lobbying for enormous public subsidies. This type of rugged individualism had long been popular in the business community. Its devotees had long proclaimed themselves to be scientific 'realists' and 'objectivists' because they felt that they were not swayed by the misguided sentimentalities, communal idealisms, fears, and superstitions of the masses.
    Ayn Rand, author of The Virtue of Selfishness, and The New Left: The Anti-industrial Revolution, is the apostle of so-called 'objectivism.' She argued for a philosophical revolution based on rationality, individualism, anti-collectivism, self-interest, science, progress, and technology. Self-proclaimed 'objectivists,' commonly equate 'scientific rationality' with the facts, theories, and reasoning that they use in daily life. 'Irrationality' is the thinking of those who do not think like them.
    An egocentric point of view is a common human trait, not restricted categorically to self-proclaimed objectivists (Regal 1990). But objectivists seem especially ready to believe that they are experts on a wide variety of scientific, economic, and philosophical subjects even when they are uninformed. Labeling oneself 'an objectivist,' or a 'rationalist,' or a 'scientific thinker' seems to give one added confidence in one's particular point of view.
    The equation of scientific rationalism with world-views by objectivists results in a way of speaking that obscures the distinction between empirical fact and reasoned or absorbed opinion. This way of speaking exists among biotech leaders at least to the degree that it has complicated policy discussions of risks and benefits in which I have participated. For example, some biotech promoters will speak as great scientific authorities about ecological and evolutionary principles (as they imagine these), but they will refuse even to read the professional ecological or evolutionary literature. They will ignore such scientific considerations on the grounds either that ecological principles are self-apparent to them, or that ecologists are not true scientists. [Some biotechnology leaders have not understood that there is a difference between professional ecologists and 'environmentalists' (or understood the differences between mainstream environmentalists and 'deep ecologists'), and so from their point of view it might have been true that (what they thought of as) 'ecologists' were not true scientists.]
    Another example of the confusion that one sees among objectivists: The economic dreams and promises of the biotech industry are often spoken of as though they are reliable scientific predictions of things to come. It is, again, as though by making the labels 'objective' and 'predictive science' part of one's self-identity, all of one's strong beliefs must by definition be objective and predictive.
 

 4: Philosophy and Risk Assessment

Given this history, it is no surprise that a great deal of risk assessment in biotechnology has been philosophical beliefs that do not recognize themselves to be philosophy.
    Leaders of the biotech community have insisted that their claims that the technology will always be safe and effective have been based on solid science, and that any doubts or concerns have been based on anti-science, rather than on different scientific paradigms.
    The fact is that most of the economic promises of the biotech community are years overdue and biotech companies go out of business at a very high rate. Even superficially, their social dreams and their effectiveness claims have not proved to be true scientific predictions in most cases (Also, even in this infancy of genetic engineering, there have been accidents and near-accidents. See Doyle et al. 1995, Regal 1994).
    There is indeed magnificent solid science in molecular biology, and some biotechnology products are already useful. But there is also confusion over how to use reductionistic scientific findings to make predictions at higher levels of organization. Thus, investment in most biotechnology companies has not paid any returns.
    Predictions seemingly 'based on' solid science are not necessarily scientific. A pedestrian example: Suppose one were to claim that they could predict with scientific certainty the time at which a pizza will be delivered, because they base their prediction on the solid science of the chemistry and physics of cooking times and the acceleration characteristics of the delivery vehicle. This would not be a truly reliable scientific prediction, because physics and chemistry are only the elementary terms in a delivery equation. Delivery will also depend on traffic, road conditions, the state of repair of the vehicle, and the ability of the driver to navigate.
    Organization at the levels of tissues, organisms, and communities of organisms are many times more intricate than city traffic and sleepless pizza delivery persons. The work-day dream of theory reductionists has been that by specializing one will be able to reliably generalize. This dream can be a great motivator for young scientists who have been persuaded to devote their lives to the study of small bits of nature, but it is not necessarily a realistic expectation.
    Spokespersons for the biotech community claim that they will accept safety regulations so long as they are based on 'true science.' But one soon learns that they may have in mind criteria that other scientists would not agree are 'true science.' Thus, the larger question for the sociology and philosophy of science is who gets to define true science? Should it be the scientific community at large, philosophers of science, experts in appropriate fields, or only those scientists in political/financial control of science policy? What exactly would be the true science on which safety can be based if it is not modern ecological and evolutionary principles?
    A cynic may point out that the demands for 'true science' sound suspiciously like arguments from the tobacco industry that there is no scientific proof of negative health effects from tobacco, and that arguments to the contrary are 'non-scientific' and have been made by 'enemies' of the industry. A cynic may point to the recently uncovered strategic campaigns by industry lawyers to control language to control the public image of tobacco, and guard against liability. (See for example the special issue of the Journal of the American Medical Association July 19, 1995) Thus  the arguments from biotech leaders about what 'true science' is would be merely tactics to distract.
    The possibility that there is a strategic campaign of attention-diverting rhetoric at work in the case of biotechnology should not be ruled out. There is an enormous amount of money and political power at stake at university, local, national, and international levels; and power has never confined itself to transparent strategies. Lawyers, lobbyists, and corporate strategists are active at the intellectual/policy leadership level in the biotech community, and they aggressively locate centers of power in national and state capitals to shape a favorable image of biotechnology and to get laws and subsidies that will be favorable to it.
    Whatever the political maneuvering may be, idealistic thinking did dominate in the beginnings of molecular biology. True philosophical confusion has taken place and does exist, and these have had at least a significant effect on ways of thinking in the biotech community and on the quality of risk assessment. These are realities that do deserve analysis and future research.
    Next, what have been some of the traditional philosophical beliefs that have commonly been mistaken for scientific thinking in risk assessment, and how have they translated into practice?

4.1 Reductionism

Just as physicists once assumed that all things would be understood if the properties of basic atomic particles were understood, molecular biology began as an exercise in imagining that all life can be explained and accounted for by a similar conceptual reductionism of life to the properties of the molecule of heredity and its arrangements. Reductionist enthusiasm went beyond developing methods of analysis to determine chemical structures (methodological and constitutive reductionism). There was a leap in logic to the belief that knowledge from lower levels of organization give one knowledge at all higher levels of organization (theory or philosophical reductionism).
    Enthusiasts have assumed that the lens of reductionist simplicity allows them to understand higher levels of organization, when in fact it may sometimes throw intricacy so out of focus that it appears insignificant. To the enthusiast, there is no significant difference between the Humpty Dumpty who sat on the wall and the pile of Humpty Dumpty pieces that all the king's men could not figure out how to put back together --for it is sufficient to know that both are basicially chemicals.
 This ambitious claim to knowledge has extended into the policy area. One example of reductionism in policy: The U.S. Food and Drug Administration has accommodated the industry by agreeing that genetic engineering is 'nothing but' an extension of traditional breeding, because it is 'nothing but' moving genes around, and therefore genes and their products which are foreign to a species do not constitute food additives. GEOs will be as safe as organisms modified by traditional breeding techniques, and so screening and food labeling will not be necessary.
    Therefore, the addition of genes for scorpion or spider venom to the tissues of corn or soybeans (to protect against insect damage), for example, should not have to go through expensive testing to assure that food from such plants is safe. Genetic engineering is said to simulate a natural process and to be equivalent to traditional breeding which is in turn merely a slight modification of normal sexual reproduction -- since they all supposedly reduce to 'mixing genes.'
    Yet if one planned to spray the venom or other new pesticide on the crops, expensive testing would be required before the new pesticide could be marketed. The implications of this philosophical gambit mean millions of dollars saved by a biotech company every time it develops a new genetically engineered product to be consumed. This is said to be science-based policy But public policy in this case is being based on reductionistic philosophy rather than on 'solid science.'
    In fact, genetic engineering can raise greater concerns compared to traditional breeding in some applications. Recombinant DNA techniques potentially allow 'phylogenetic leapfrogging' of adaptive traits between totally unrelated species so that truly novel and potent adaptive combinations can be created. They allow genetic modifications without the traditional debilitating effects of the allelic substitutions that have plagued traditional breeding. They will eventually allow a reprogramming of the non-Mendelian portions of genomes that that control some of the most profoundly important biological features, but that traditional breeding cannot penetrate and reprogram. They often produce startling 'genetic side-effects' (Regal 1994).
    These facts raise especially clear concerns for ecological risks. Recombinant DNA techniques have special potentials to circumvent the inherent limitations of conventional breeding and to be used in powerful ways to modify organisms that could be destructive.
    The safety of food and working conditions are separate issues and involve different technical considerations from the question of whether rogue transgenic populations can sometimes be produced. There is evidence that 'genetic side-effects' may be especially profound in the case of GEOs because an organism's 'buffering' system may not recognize new biochemical processes and moderate their effects. More analysis of the implications of this is urgently needed, but it presently seems that major biochemical side-effects could result and sometimes cause problems for food safety (Regal 1994).
    In addition, it is now generally understood that allergenic properties can be passed on from genetic donors to transgenic foods.

4.2 Essentialism

There has been considerable essentialism in the thinking of the biotech community that has been confused with 'scientific thinking.' Policy was being made before 1985 according to the argument that GEOs will be generically safe because they are basically unnatural, overloaded with excess metabolic functions, etc. -- as though there would be an 'essence' of GEO and they would all share these characteristics and thus all be safe. (And note, this argument that GEOs are necessarily unnatural contradicts the above argument that transgenic foods do not need to be regulated because they are necessarily natural.)
    Scientists who have studied biosafety have mostly backed off from such essentialism, and realize that GEOs must be considered on a case-by-case basis. Some may be safe and others dangerous (Colwell 1989, Regal 1985, 1986, 1988, 1994).
    But one still finds significant evidence of essentialism  among regulatory officials who have stated that hundreds of (so-called) releases (into confined field plots for testing commercial potential) have shown nothing unexpected, and that because 'nothing bad has happened,' it is scientifically demonstrated that GEOs will be categorically safe (references in Regal 1994).
    Some biotech leaders have also argued that an ecologically incapacitated plant such as corn or wheat would be an appropriate scientific model for all GEOs, as though all GEOs would all share 'the essence' of transgenic corn.

4.3 Essentialism Extended to Human Motivations and Abilities: Ramifications for the Quality of Regulation

Another significant example of essentialist thinking: Biotech promoters too often insist that persons with concerns about biotech form a category and share an essence. When individuals or groups raise economic, safety, ethical, or social questions about specific projects, promoters commonly insist that those who raise these diverse questions are all basically 'enemies' of biotech who are scientifically ignorant, anti-progress, Luddites, and afraid of each and every genetic engineering project. 'Objectivists' see in questions that are put to them, confirmation that the masses are all ignorant and fearful of progress.
    Ecology is not a true science in the eyes of biotech leaders. They see ecology as non-reductionistic, non-technological, and anti-progress. The report of the Ecological Society of America on the safety of GEOs has been received with suspicion, for example, by leaders of the biotech community (Tiedje et al. 1989).
    A cynic might argue that such accusations, made in such a highly political climate, are not reflections of true philosophical confusion about essences, but are merely in the classic tradition of promoting ugly stereotypes and character assassination to marginalize critics (e.g. Keen 1986). Thus, the commonplace essentialism in popular culture allows the opening of a political space in which the stereotype of a 'Luddite' can become constructed and used as a scapegoat to divert attention and rouse emotions.
    Yet even if the cynic were correct, those who have been persuaded to believe the accusations and act on them, however the accusations were generated, do not recognize that they have fallen into essentialistic or typological thinking. Typological thinking does exist, and it is important to understand this.
    Thus one does find lax regulators who take the attitude that regulatory agencies exist to keep an irrational public calm. They do not seem to read or be prepared to discuss the growing scientific literature that outlines genuine scientific reasons to strive for quality in risk assessment. They too often rubber-stamp applications and staff with inappropriately educated employees. Pressures from biotech promoters has led to a culture of government regulators in which it is common to believe that regulation exists primarily to convince an irrational public that the government 'has everything under control.'
    Those who have argued that government regulation of biotech is not necessary have also glimpsed this. Henry Miller of Stanford University's Hoover Institute, has accused Terry Medley, a lawyer who heads USDA's Food Safety and Inspection Service, of seeking to maintain regulations to maintain bureaucratic status. Miller reported that Medley had been telling biotech scientists "that scientific evidence was of secondary significance in policy making; of greater importance were public perceptions of risk (no matter how misguided) and ensuring that U.S. policies conformed to those of our trading partners (no matter how economically regressive)" (Miller 1994).
    Miller's accusation that USDA officials will admit that that they feel that their risk assessment programs exist primarily for political purposes is consistent with a report by Wrubel et al. (1992). They found, in a study of USDA safety reviews of biotech proposals that there had been scant attention paid to asking useful scientific questions.
    The Wrubel et al. report came four years after an extensive report from the General Accounting Office of the United States Congress that found that The Department of Agriculture, The Environmental Protection Agency, The Food and Drug Administration, and the National Institutes of Health were making safety determinations without an adequate scientific basis (GAO 1988). The immediate response of USDA officials was that the GAO report was inaccurate. USDA officials then told us privately that they were improving their procedures. But the Wrubel report showed that there had been no detectable progress. As I write, USDA has proposed essentially the deregulation of transgenic crop plants. They have not published any scientific reasons for the proposed policy.
    A group of anonymous 'whistle blowers' at the U.S. Environmental Protection Agency(EPA) has published an extensive report that claims that EPA has bent to political pressures and compromised its biosafety oversight role, and has been forcing its employees to keep silent about risks -- Genetic Genie: The Premature Commercial Release of Genetically Engineered Bacteria (PEER 1995). This report was published through a group that represents the interests of public employees.
    I have worked closely with several government agencies for a decade, have served on the Scientific Advisory Board for the EPA, etc., and it has been clear that qualified scientists in the agencies are often shocked and demoralized that political pressures so often combine with scientific ignorance to determine agency policies. Agency heads are acutely aware that since the 'Reagan Revolution' there has been a strong anti-regulatory philosophy and that the promoters of biotechnology have developed close ties to the centers of power.
    Thus, efforts to reduce all concerns about biotech to 'irrationality,'combined with political pressures, has contributed to the development of a risk assessment culture that is unlikely to be able to make quality risk assessments. They have not been seriously preparing to meet the scientific challenges ahead.

4.4 Platonic Cosmology

 I have been involved extensively in scientific workshops and policy discussions regarding biotech since 1984. A set of arguments that GEOs should be generically safe to release in nature had been determining U.S. policy and leading toward complete deregulation.
    These generic safety arguments turned out to be based on outdated ecological and evolutionary theory, and ecology/evolution in popular thought, that portrayed a perfect balance and organization of nature, the perfection of adaptive features. There was also the idea of plentitude, the notion that every creature that is possible has already lived (Regal 1985, 1986, 1994). Analyses of these ideas by academic ecologists and evolutionary biologists in the 1960s and 1970s had been rejecting them.
    The origins of the disproved ideas of balance and perfection of adaptation trace back easily to the origins of ecology and evolution in the natural theology of the 16th through 19th century. Natural theology maintained that God had created a perfectly harmonious universe with perfectly adapted creatures. These ideas trace back even earlier to the revival of Platonic and Aristotelian ideas about nature in 12th and 13th century Christian Europe. Greek cosmology became secularized and the mistaken belief was spread that Darwinian evolution produced a harmoniously balanced nature populated by perfectly adapted creatures (e.g. Bowler 1988).
    Thus, the basis of the arguments that biotechnology leaders were using to set United States policy on biosafety were Platonic and Aristotelian cosmologies that assumed that nature is organized in its basic essence in a highly logical and harmonious manner. And thus GEOs could only be less perfect than natural organisms and they could do nothing to upset the supposed balances.
    The implications for the quality of ecological risk assessment of the old view in contrast to the modern view are profound. In the Platonic view, nature is in harmonious balance and GEOs can only be imperfect and non-adaptive. They cannot compete with those creatures that the laws of nature have perfected and so they cannot upset that harmonious balance that the laws of nature have produced. Thus, for those who mistook Plato for a modern ecologist, supposedly solid 'science' indicated that no serious risk assessment is necessary. Risk assessment is only necessary as a facade, to keep a scientifically illiterate public calm.
    The newer findings in ecology and evolution demolish this comforting ancient view. The new findings indicate that the so-called 'balance of nature' is relative, tenuous, ad hoc, statistical, and organisms are far from perfectly adapted to nature. There is much room for organisms to be made that are competitively superior to those that already exist, and for a prevailing tenuous 'balance of nature' to be destabilized.
    This is not to say that every GEO will be ecologically dangerous. Nature will present significant challenges to GEOs, and much genetically engineering is done with ecologically attenuated laboratory organisms and row crops to which have been added non-adaptive traits. I have explained in a number of publications why most GEOs are of types that will fail to thrive naturally (Regal 1985, 1993, 1994).
    But there are nevertheless types of GEOs that could cause serious ecological problems, ranging from noxious but tolerable problems, to catastrophic ones. Thus, it is necessary to have risk assessment that is much more than a facade. And there must be serious scientific research and training to provide legitimate foundations for risk assessment (Regal 1987a, 1987b, 1989, 1993).
    The older Platonic and Aristotelian ideas are deeply rooted in Western culture and it would not be easy to flag them and mark 'warning' for all time, even if there were not economic and political pressures to pull out the warning flags. These old and misleading balance of nature ideas are an extremely serious problem for the quality of risk-assessment. For it will be very difficult to find politicians and regulators who will understand that the old balance of nature ideas are misleading Greek cosmology and who will mistakenly think that they are logical, scientific 'common sense' because they have a comfortable familiarity.

4.5 Monism and Public Policy

 Philosophers could help to explain that it is not rigorous science or philosophy to believe that there is only one truth or one approach to truth. They could help to explain why balance is needed in science policy. This would include balanced support for diverse approaches to the study of biology, and it would include full consideration of the spectrum of biological knowledge when making policy decisions about biotechnology safety.
    Leaders in molecular biology have pressed for funding and staffing in biology to be concentrated in molecular biology. They speak of phasing out the 'old fashioned' life sciences and at some time in the future rebuilding them from the ground up on the foundations of biochemistry. Such policies would result in the elimination of most scientific investigation into nature at its higher levels of organization. Their rationale is again reductionistic. Knowledge of emergent properties is supposedly illusions that will one day be reduced to chemical theories.

4.6 Utilitarianism and Platonic Realism

Policy is still being made according to utilitarianism in combination with idealism or Realism, and this is again mistaken for 'scientific thinking.' The utilitarian premise that rightness or wrongness is determined by consequences quickly leads to the notion that costs and benefits can be scientifically calculated, and by the same standard, so that they can be weighed against each other. Yet academic philosophers understand that it has proved difficult to estimate social costs and social benefits in any truly scientific way. How can one identify the greatest good for the greatest number? Should estimations include future generations?
    A common argument in biotechnology has been that the risks are merely hypothetical and this must be weighed against the enormous future benefits. The fact is that it is impossible to be certain about the social benefits, especially in agricultural and environmental applications where the economic, social, and technical issues can be quite intricate. Some will surely get rich, but will society truly benefit in the ways that have been promised?
    Yet the teleological purposes of projects, the hoped for ideal outcomes, are treated as though they are scientific Realities, even though the industry is years overdue on most of its promises. Then regulators are asked to weigh these promises heavily against the supposed fact that the risks are merely hypothetical, do not conform to the ideal Reality, and hence have zero mass.
    Thus the outcome -- determined 'scientifically' -- will always be that the risks are negligible compared to the benefits. Regulators have been pressured by biotech proponents inside and outside of government to defining scientific risk assessment as a process of weighing risks against proposed benefits; and yet they argue that detailed socioeconomic analyses of risks and benefits should not be made because risk analysis must be strictly scientific and socioeconomic analyses are not scientific. There is a clear contradiction here, but it is not seen by  biotech promoters who have complete faith in the Realism of the proposed benefits.
    A further example: When the prices of biotech stocks have plunged because of unkept promises, the idealistic faithful have insisted that it is the market that is unreal, and the science is real. Consider responses to a 26 September 1994 issue of Business Week that was critical of industry management and a pattern of unkept biotechnology promises. (The special issue followed other criticisms from business analysts such as those in a special 20 page supplement to the May 20, 1994 Wall Street Journal, and Robert Teitelman's Gene Dreams: Wall Street, Academia, and the Rise of Biotechnology.) As a reporter summarized the responses,

 To people inside biotech companies, the stock market is what's unreal. ... [In response to the issue of Business Week, the insiders argue that:] The reality is the science, and the science is good. "The reality is that this is going to be the technology of the future," says Ed Fritzky, chairman and chief executive officer of Immunex Corp. ... the people in these companies all say the work will go on. Somebody will fund it. Somebody will make money on it, and those who bet otherwise will ultimately lose. (Ramsey 1994)

 5. Policy Implications

 This essay illustrates that much of what is supposedly science-based risk-assessment is actually Greek metaphysics. Thus, philosophers of science could do a great deal to improve the quality of risk assessment by helping regulators and the public to further identify and understand the differences between judgments based on credible scientific information and theory, and judgments based on world-views that include theory reductionism, essentialism, idealism, Greek cosmology, and utilitarianism masking as objective science.
    It should be mentioned that some 'environmentalists,' especially among the so-called 'deep ecologists,' also mistake their personal world-views for science. Some of them also mistake Platonic or Aristotelian models of the balance and perfection of nature for hard science. They may strongly oppose any human modifications of nature and may make the false claim that the science of ecology warns that any disturbance of nature is unsafe.
    But these idealizations of nature and the excesses of some of the 'deep ecologists' have been discussed for years. Professional ecologists been engaged for decades in experiments to sort out issues related to idealizations of nature (Botkin 1990, Pimm 1991). What are different models of balance? How natural or unnatural are various types of balance or imbalance? What constitutes truly dangerous ecological damage? The balance issue in this context has not been neglected nearly to the degree that the relationships between philosophy and science have been neglected in the context of biotechnology.
    The implications of reductionist and determinist thought for social policy issues with regard to biotechnology, biosafety, and balance in support for the life sciences have scarcely been examined by scholars in the depth that is required, especially considering the profound implications of these matters well beyond the biosafety issue.
    The philosopher Karl Popper, in The Open Society and its Enemies and The Poverty of Historicism, and elsewhere, has analyzed various aspects of reductionism, determinism, and 'scientism' in great detail with regard to political ideology, democratic freedoms, and academic standards and conventions in the social sciences and humanities. Thus, the interface between philosophy and social policy has not been strictly speaking neglected. Yet, treatments such as Popper's are so broad that they can seem remote from daily policy battles and Popper's analyses have too often been forgotten.
    The present example stresses that if historians, philosophers, and sociologists of science and technology will do their homework, they can have something important to contribute to a range of policy deliberations that are in progress as society enters the era of biotechnology -- an era that many have argued will surpass the Industrial Revolution in its impact on human institutions, economic patterns, life-styles, and values.
    There is much need for careful analyses of the rhetoric that is being used not only in risk issues but in debates and decisions related to the reshaping of economic patterns, redistributions of economic and political power, the reshaping of the relationships between citizens and insitutions, the structure and nature of scientific research, teaching, and beliefs, relationships between scientists and the public.
    Questions about the quality of risk assessment programs for the safety and effectiveness of GEOs are very important. But there is also an important need to more deeply analyze the relationships of reductionistic and idealistic world-views to science policy and funding, to the rhetoric of persuasion, and the relationships of science policy and techniques of persuasion to social, economic, and political dynamics and trends.

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For more about risk-analysis, see: Faulty risk-analysis methodology [EL] By Dr Robert Mann.

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