Comparing the role and methods of bioethics across the Atlantic Ocean may reveal some interesting
differences. I have tried to pin down some general features as to explain why and how we differ from one another.

The way I see it, in most European countries the bioethical committees are far more modest enterprises than in the US. For instance in the Nordic countries, the "big" bioethical questions – abortion, euthanasia, cloning etc. – are mainly in the hands of bureaucrats and medical  professionals rather than moral philosophers (or theologians), and the health-claim based  arguments are seen as a moral trump card by which bioethical ideas are advanced in society. My impression is that in the UK the public impact of philosophically informed bioethics is somewhat higher; and in some countries of the mainland Europe the dominance of theologically inclined bioethics seems to be en vogue.

One of the reasons why bioethical methods develop the way they do lies in the social or political infrastructure in which they are situated and forced to operate. But far more interesting determining factors are the role of religion in the society and the rhetorical culture.

Examining the more or less traditional core questions of bioethics – namely abortion, euthanasia, embryo stem cell research, human genetic engineering and so on – reveals how many of them make relevant ethical topics first and foremost in a conflict with religious values. (Or to be even more specific, Christian values.) Why are these topics discussed in the first place? Because people have ideas of sanctity of life, of a human soul, of inviolable human nature and so on. Technology provides us outstanding means to perform “ritually unclean” things according to religious norms.

From a purely naturalistic-scientific point of view many of these at first sight ethical problems seem neither ethical nor problems: they do not produce significant amounts measurable suffering, nor are they in conflict with any plausible account of human rights (provided that defining “human” equals “person” equals naturalistic methods of defining personhood). Thus, the why and the how of bioethics seem to be determined by a clear-cut case of science versus religion. This much anyone can tell.

The tricky part lies underneath the surface. A careful observer may have noticed there are three sets of norms involved:

1. Norms of consequence: the question of whether something causes good or bad.
2. Norms of justice: the question of whether some commonly set rules (namely rights and duties) is abided.
3. Norms of “ritual cleanliness”: the questions of metaphysics and aesthetics – whether something is “clean” or “dirty” according to laws of moral cosmos, that is, whether the “laws of nature” have been breached.

Now, imagine a situation, where you need to justify a medical procedure to a person who is opposed to it. You have only the sets 1. and 2. at your disposal, whereas the person is convinced there is such a metaphysical thing as natural order of things, and what we’re about to pull off is somehow unclean (s/he’s a proponent of the set number 3.). We’ve all been there, right? Frustrating, isn’t it?

The thing is, the three sets of norms are a necessary part of human moral cognition and happily coexist within individual human skulls, but intellectually aren’t exactly easily commensurable. Moral philosophy gives fantastic tools for operating within the two first sets of norms, but the third set has been overlooked for centuries. We as moral philosophers are not exactly prepared to deal with these kinds of arguments in their own turf, and it seems they are yet more likely the domain of religious and anthropological studies in ethics. Hence we keep banging our heads to the wall when faced with the situation described above.

The role of religion and the norms of “ritual cleanliness” colour the bioethical debate and give dominance to certain questions over others, and explain why there’s just no observable progress in some issues. This is also a probable explanation for some of the differences in bioethical debate between the US and Europe. And further, differences within Europe. How much space is given to religious perspectives in these bioethical debates varies a great deal across the Atlantic (as it does within Europe).

Another thing is the rhetorical culture: whether it is rechtshaberisch, winning-or-losing –oriented, agonistic and aggressive, or more docile, deliberative and distinctive in having an open stance. The US is somewhat notorious for having a love of opinionated, rigorous debate culture. Against this kind of background it makes sense how the debates about bioethical issues are conducted – you’re either for or against, if you make a moderate middle-way claim, nobody’s that interested. (This may be caricaturizing a little.) Compared to Europe, the debate culture in most countries isn’t that aggressive, and this especially in the level of EU. Hence, when for instance a strong religious party imports bioethical arguments from their American associates to lobby for or against something, they can’t help looking a bit out of place. Having this pluralistic and open stance is a distinctively European feature in the bioethical rhetoric.

It’s not to say one way is better than another. An American bioethicist may claim European style of doing it produces only lukewarm compromises and subtlety, whereas a European can’t help feeling the American agonism too straightforward and black-and-white. But on the level of observation and explanation, why European bioethics is what it is and how it is conducted, maybe these three (the institutional scaffolding, the varying role of religion, the rhetorical culture) may shed some light on the matter.

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	Comparing Some Differences