Case 5, 2007

A Diagnosis of Biosecurity:

1. Synthetic Biology & 2. Syndromic-Surveillance

Lyle Fearnley and Anthony Stavrianakis

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his paper is framed as a diagnosis of biosecurity through two case studies: syndromic surveillance and

laboratory biosecurity within, but not limited to, synthetic biology. Both cases address the problem of

how to effectively deal with futures which cannot be known on the basis of risks and probabilities. The

normative demand to deal with unexpected futures is a norm of security that the Anthropology of the

Contemporary collaborative (http://anthropos-lab.net) has called preparedness.

As a technical term, preparedness is a way of thinking about and responding to significant problems that

are likely to occur (e.g. a bioterrorist attack or the spread of a deadly virus), but whose probability

cannot be feasibly calculated, and whose specific form cannot be determined in advance.1

Through this diagnosis, we suggest that the non-probabilistic character of contemporary biological

problems requires attention to biopreparedness, in addition to biosecurity and biosafety.

In the disease surveillance case, we show that new understandings of emerging diseases exposed the

insufficiency of existing risk-based public health. The case examines how local public health departments

and federal government agencies turned to a new technology—known as syndromic surveillance—to

rebuild a capability to detect the unexpected epidemic. In the laboratory, on the other hand, the

dominant mode of security is still probabilistic risk management and the reduction of security to

technical safeguards. The second set of case materials suggest that, as with the forward looking

technologies in syndromics, laboratory practice must find methods for thinking and responding to

events whose probability cannot be calculated. Given the concerns from organizations such as the

NSABB with national security and the development of “responsible” science, how can these concerns be

made a part of laboratory practice? This is the question of finding venues, both inside and outside the

laboratory and connecting them to methods that develop preparedness capabilities.

Syndromic surveillance technologies have been built, but there remains the problem of how to

incorporate them into public health practice. This is the problem of connecting methods to venues, a

problem demanding the invention of equipment. Such invention must ask: what are the organizational

norms and forms through which these techniques and technologies can be incorporated into an

effective practice? Historically public health managed disease in terms of risks and probabilities. The

effective use of syndromic surveillance necessarily involves a re-working of public health practice

through the invention of new equipment.

As a diagnosis, the paper locates both blockages and opportunities at stake in the development of

biopreparedness equipment. Why use a diagnostic? Or rather, what is it that diagnosis does and does

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not do? It does not aim to find examples to prove a theory. There is certainly an orientation, a general

“pain” which can be pointed to, but no hypothesis in need of a proof. The philosopher Gilles Deleuze

writes eloquently of what can well characterize the challenge facing the human scientist working today;

“We are wrong to believe that the true and the false can only be brought to bear on solutions, that they

only begin with solutions.”2 A diagnosis is not about uncovering solutions, but about stating the problem

correctly. Deleuze quotes Bergson when he writes that, “the truth is that in philosophy and even

elsewhere it is a question of finding the problem and consequently of positing it, even more than of

solving it.”3 As with the medical practice of diagnosis one must identify the malady; the question of its

remedy is only possible once the malady has been defined and located.

Moreover, this is a diagnostic of equipmental platforms. In the diagnostic of equipmental platforms the

remedy to the problem diagnosed is the invention of equipment. Why equipment? We are not just

diagnosing a technical failure, that is to say a failure of means to achieve specific ends, although it may

include that. Concern solely with direct and consequentialist means-ends relationships are insufficient

because they do not account for how technologies are taken up in practice. A diagnosis consists of the

identification of blockages within sets of truth claims, affects, and ethical orientations designed into a

practice.

Through the use of Rabinow and Bennett’s Diagnostic of Equipmental Platforms, our diagnosis of these

two cases led us to identify a critical problem-relation between the development of methods and their

location in venues. According to the document, a method establishes a “structural joint” between

practical governance and an object.4 This is the organization of activities oriented within a form

appropriate to their realization. The site in which this organizational form is composed is a venue. In the

terms of the Diagnostic:

a venue in equipmental composition characterizes the scene, site, or setting in which specialists work on

design and synthesis. Such venues may have been already stabilized or institutionalized, they may

coincide with the articulation of the practice itself, or they may emerge through the practice of

equipmental composition. The venue is not a neutral scene in which specialists work, nor is it only the

site within which a given mode of composition is advanced. Rather, it is a facility. That is to say, when

composition is successful, the venue facilitates rather than obstructs the design and synthesis of specific

interfaces.5

Our diagnosis aims to locate the emergence of biopreparedness methods and venues, and calls for

further inquiry into blockages and opportunities at stake in this emergence.

I. Biopolitical Equipment in Question

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The concept of biopower developed by Michel Foucault articulates the historical emergence of a form of

power over life. As he put it in the first volume of The History of Sexuality, “power would no longer be

dealing simply with legal subjects over whom the ultimate dominion was death, but with living beings,

and the mastery it would be able to exercise over them would have to be applied at the level of life

itself.”6 In the Diagnostic, Rabinow and Bennett argue that biopolitics is biopower made equipmental,

that is, a set of methods, venues and purposes (among other elements) combined into a practice. In

French Modern, Rabinow describes how urban planning in nineteenth century France turned the figure

of biopower into practical mechanisms, constructing “the planned city as a regulator of modern

society.”7 Foucault elaborated that “the mechanisms introduced by biopolitics include forecasts,

statistical estimates, and overall measures. And their purpose is not to modify any given phenomenon as

such, or to modify any given individual insofar as he is an individual, but, essentially, to intervene at the

level at which these general phenomena are determined, to intervene at the level of their generality.”8

What is crucial is that these mechanisms are working on a particular kind of object, the well being of the

population. Population, a term from the early 17th century, is an object known through, among other

kinds of calculation, normal distributions and subject to interventions on its health and welfare. Foucault

also described the biopolitical governance of a population as an apparatus of security. “…The apparatus

of security inserts the phenomenon in question … within a series of probable events,” he claimed.9 For

our purposes, one of the general features of the apparatuses of security Foucault investigates is the

space of security. This space, Foucault tells us, following the Newtonians in Physics and Lamarck in

biology, is called the milieu. “The specific space of security refers then to a series of possible events; it

refers to the temporal and the uncertain, which have to be inserted in the given space.”10 The milieu is

then the space of calculation. In this paper, we emphasize that biopolitical equipment relies on a

probabilistic ontology: a form of reasoning that bases judgment and government on the calculation of

risks and probabilities.

In addition, both Foucault11 and Rabinow12 specify that the emergence of biopolitical mechanisms

produced novel domains of knowledge, expertise and power. In the Diagnostic, Rabinow and Bennett

argue that biopolitical equipment produces a specific kind of expert, the social technocrat. These are

experts who normalize human collectivities: “social technocrats work with probabilistic series in fields of

normalization. Such work requires a stable venue in which large amounts of material, produced and

collected by social technicians, can be gathered, stored, and distributed in an ongoing fashion.”13 This

stable venue, in the terms of the Diagnostic, is a governmental venue. The governmental venue is the

site where social technocrats collect and analyze information in terms of probabilistic risks in order to

normalize a security milieu. In this paper, we address two sites where contemporary problems are

challenging the facility of such venues.

II. Syndromic Surveillance and Re-Working Biopolitical Equipment

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In this section, we discuss the practice of local public health departments in the United States in relation

to the figure of biopolitical equipment. Our argument is that local health departments are historically,

technically, and even legally bound to operate through biopolitical equipment. Yet in the contemporary,

these health departments face a biosecurity problem-space characterized by new norms of security,

new ontologies of disease and new technologies of surveillance. To practice in this problem-space has

required a kind of “re-working” of the biopolitical that involves figuring interfaces between biopolitical

equipment and this new normative domain.14

In the United States, public health emerged as an institution through the formation of local health

boards or departments during the nineteenth century. In her overview history of public health in the

United States, Elizabeth Fee notes that “the first organized expression of concern for public health came

not from the federal government, or even the states, but from the rapidly growing eastern cities.”15 Yet

historians emphasize that the significance of early public health was not any specific technique. As

Barbara Rosenkrantz puts it, “the field of public hygiene exemplified a happy marriage of engineers,

physicians, and public-spirited citizens providing a model of complementary comportment under the

banner of sanitary science.”16 Instead of a single technique, what was significant about early public

health departments was the figuration and implementation of biopolitical equipment.

Despite some local peculiarities, early public health in the United States broadly shared a biopolitical

equipmental framework with the hygienists, sanitarians, and others operating in Europe and

elsewhere.17 Perhaps most apparent was the way public health conceptualized disease as a problem of

population health.18 As Savitz and co-authors argued during a recent debate in the pages of the

American Journal of Public Health, “public health can be defined solely by its goal: maximizing the health

of human populations.”19 William Coleman links the hygienic approach to disease with a transformation

in the idea of the population, from an index of national strength to a pathological problem. “For the

hygienist,” he writes, “the principle concern was man in the mass.”20

The collection of information about death and disease, and subsequent statistical analysis of this

information, is fundamental to the development of a biopolitical—a population oriented—public health.

On the surface, public health departments collect information about death and disease simply in order

to guide intervention. But the very object that public health governs—the healthy population—is itself

constituted by transforming this statistical information into norms of health. There is an intimate

connection between the collection of information about disease, the definition of a statistically normal

health, and the possibility of an expert judgment about when, where, and how to improve the

population’s health. The historical development of the public health department is based on a

fundamental coherence between practices of governance and practices of truth.

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The practice of the public health department historically involves the collection of information about

morbidity and mortality in daily, weekly, or other series. The health department must be seen as a

governmental venue, where “large amounts of material, produced and collected by social technicians,

can be gathered, stored, and distributed in an ongoing fashion.”21 Social technocrats operating in this

venue mediate practices of truth (the collection of health data) with practices of governance

(interventions to normalize or improve population health). Through a method of modulation, social

technocrats (e.g. epidemiologists) make expert judgments about the relationship between collected

information, statistical normals, and the population as object of governance. Put simply, they attempt to

modulate the population—as represented by statistical data--such that it corresponds with probabilistic

norms of health. The historical incorporation of biopolitical equipment within public health practice

therefore relied on the stable coherence of an object (population-body) and an ontology (probabilistic),

stabilized through the work of social technocrats operating in a governmental venue.

Today, the new ontologies of emerging infectious diseases and bioterrorism pose problems for the

stability of biopolitical equipment in public health. Public health science now widely acknowledges that

the timing and character of many future outbreaks of disease is unknowable. Microbes are now known

to emerge from wilderness reserves, acquire drug-resistance, and continuously evolve.22 As Stephen S.

Morse put it, “early warning of emerging and reemerging diseases depends on the ability to identify the

unusual as early as possible.”23 In addition, since 1998 public health experts have vehemently discussed

biological terrorism as a public health problem, while acknowledging the unpredictability of this

biological threat.

While the identification of the unusual retains a reference to a present normal, the ontology of

emergence reframes the relationship between the population and disease in non-probabilistic terms.

That is to say, in discussions around emerging infections or bioterrorism, the risks posed by disease to

the health of a population cannot be understood through the calculation of probabilities. The ability of

the social technocrat to modulate statistical data—data that will guide expert judgment about how,

when and where to improve population health—breaks down. Preparing for the appearance of

unexpected disease events subsequently became a new norm of public health.

To address concerns about emerging infectious diseases and biological terrorism, public health

departments and federal agencies turned to the development of new technologies of surveillance.

Through new surveillance technologies, they hoped to build a capability to rapidly detect the

unexpected epidemic. To do so, they took advantage of expanding medical computerization and a

broader audit culture that produced a diversity of novel populations of health data. Most of this health

data (including 911 calls, pharmaceutical sales, and ER triage data) was non-diagnostic—that is, it made

no reference to the diagnosis of individual cases of specific diseases. Syndromic surveillance—as early

versions of these systems were known—monitors such non-diagnostic data sources for aberrant

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increases in certain symptoms of illness. Data is collected in real or near-real time: numbers come in

either continuously or in frequent daily batches. Syndromic surveillance aims to detect precisely the

epidemic that is unexpected or unusual, and to do so rapidly.

However, the use of syndromic surveillance in public health practice has been notoriously problematic.

Public health departments did not smoothly incorporate these apparent techniques of preparedness. In

particular, the production of information by syndromic surveillance systems has required a re-working of

the relationships between knowledge and governance in public health. While technologies have been

built, insufficient attention has been given to how these technologies interface with existing

(biopolitical) equipment. With what methods and in what venue should syndromic surveillance operate?

In a later section of the paper, we examine how experts from both inside and outside public health

aimed to configure interfaces between public health, new disease ontologies, and new norms of

security.

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III. Safety and Security in the Laboratory

Synthetic Biology and SynBERC

Synthetic biology, broadly conceived, is the effort to make biology easier to engineer. Over a period of

three years (2004 -2007) multiple research projects from fields as varied as engineering, chemistry,

mathematics, computer science, biology, anthropology, law and ethics were being thought and

practiced in relation to one another in order to propose biological solutions to contemporary world

problems. In the version of “Synthetic Biology” spearheaded by MIT, it is an engineering ethos applied to

biological systems. The Synthetic Biology Engineering Research Centre (SynBERC) is housed at UC

Berkeley and made up of five partner institutions including Harvard, MIT, Prairie View A&M and UC San

Francisco. The emergence of this institutional form and disposition of scientific practices in August 2006

was contingent on various research programs, individual laboratory works, sets of networks and

personal relations at play from many years beforehand.

What is important to note is that the fields of molecular and cell biology, systems biology, synthetic

chemistry and metabolic engineering were engaged in key interactions to create a constellation of

projects which had the shared goal of making biology amenable to rational design. In response to the

initial proposal from 2004 and in verbal communication between the NSF and Director Prof. Jay Keasling

a fourth thrust in addition to the three scientific thrusts was added and integrated in order to approach

the wider research and policy questions that this scientific practice raises, ranging from ethics to legal

questions. It was crucial to the NSF that SynBERC be not only a dynamic form for solving technical

scientific questions, but that it have the resources and capabilities to be reflexive about its own practice

relative to the wider mutually formative relations that constitute it. The impetus for this kind of reflexive

work can be seen in other NSF funded projects such as the Arizona State University “Center for

Nanotechnology in Society” (ASU-CNS).

A good example of the concern to find inventive ways of thinking about the kinds of techniques and

technologies emerging from this corner of the post-genomic world is the “Future Brief” paper by Rob

Carlson, written just after the first international synthetic biology conference at MIT in 2004 (SB1).

Carlson, a founding member of the Molecular Science Institute (MSI) in Berkeley along with Roger Brent

(MSI) and Drew Endy (MIT), wrote of the security milieu in which synthetic biology operates and

suggested that “*o+ur greatest challenge is to avoid imposing rigid regulations on biological tools and

skills that are intrinsically flexible. Rather than focusing on specific threats, we should instead create a

dynamic response capability, based on a broad technological and economic infrastructure that prepares

us to deal with novel challenges as they arise.”24 Indeed, Carlson is critical of the impulse characteristic

of those within and without the rDNA field to impose strict controls of licensing and distribution in the

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attempt to take precautionary measures. “...such measures are not likely to be effective. Worse, they

will instill a false sense of security.”25

The task for Thrust 4 has been to design and develop collaborative approaches to address issues of

concern to synthetic biologists, ethicists, human scientists, policymakers, private sector and the many

related publics, through the design and implementation of collaboration. The developments in synthetic

biology have been an opportunity to invent new forms of collaborative practice. Standard approaches to

the governance of biology have sought to anticipate how new scientific developments will “impact

society,” positioning themselves external to, and downstream of, the scientific. This positioning, for

example, was mandated by the Human Genome Initiative and the so-called ELSI project (ethical, legal,

and social implications). By contrast, the “Human Practices” frame of Thrust 4 at SynBERC is an approach

that fosters a co-production among disciplines and perspectives from the outset. The value of

collaboration is that its goal is to build a synergistic and recursive structure within which significant

challenges, problems, and achievements are more likely to be clearly formulated and successfully

evaluated. The reason for stating the mandate for Thrust 4 is that in a situation in which Thrust 4 is

asked to consider “the biosecurity” problem relative to synthetic biology, we think it is worth asking

what problems can be worked on relative to the Research Centre by those involved and through a

collaborative practice. The challenge in thinking about preparedness is to identify the object we can

work on and how we can work on it.

As we highlighted relative to the first set of case materials, the population is the correct object to

intervene on in within the (biopolitical) regime of security. Safety is equated by Foucault with the

traditional problem of sovereignty, that is, the problem of territory and the question of how the

territory can be fixed and protected. Foucault identifies a shift in which this problematic is de-

emphasized in favor of a different set of problems. The problem identified is essentially that of

circulation, how it can happen and how it can be allowed to happen “in such a way that the inherent

dangers of this circulation are cancelled out.”26 This is a great characterization of the state of

contemporary science, which on the one hand is comfortable with a “sovereign” relation to the

territorial laboratory space (controlling, protecting, fixing, and enlarging through grants, albeit subject to

real sovereign power) and on the other is subject to interventions which take up scientific inquiry in

terms of its place within the circulation of knowledge and objects and the calculation of the risk of this

practice and its objects relative to a population. For those charged with the problem of science in a

security milieu, the question is usually posed of how to make that which is out of calculation, calculable

and thus amenable to control, whilst maintaining the flow of knowledge, capital, symbolic power etc.

Asilomar 2.0

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One effort at thinking through the safety and security challenges of synthetic biology culminated in the

white paper report “From Understanding to Action: Community-Based Options for Improving Safety and

Security in Synthetic Biology”. The paper is indicative of the “proceduralist” approach which took the

1975 Asilomar convention as its model and was a mixture of technical criticism and what some have

called “science and society.”27 The report suggests that “self-governance” is a preferable mode of

governance compared to “outside regulation.” The most significant aspect of the report is the use of

Asilomar as the gold standard of such self-governance

In this proceduralist framing, moving from knowledge to action requires consensus and agreement on

what is deliverable before action can be executed. The assumption behind this relationship of

knowledge and action is that what people reliably know is adequate for action. The position that

suggests knowledge about how to self-govern is axiomatic comes from a model developed in the 1970s

at Asilomar when biotechnology was reacting for the first time to wider concerns regarding safety and

security of the emerging field. If the ‘how’ of governance is already known, then what is needed is

information to be collected on possible interventions, voted on and implemented. The assumption is

that there are no new risks that have emerged since this framework was developed.

What changes does synthetic biology make to already-known risks? The report attempts an analysis of

possible biosafety and biosecurity risks collapsed under a single logic (i.e. no conceptual distinction is

made between safety and security). Generally in the field, biosafety concerns are relative to the

laboratory practices of scientists, and mainly exist under the risk of accident relative to safety

techniques, whilst biosecurity identifies risks relative to the threat of malicious use. However, the report

is conflicted between a commitment to the usefulness of expert advice and also a position stating the

community believes it has both the resources and knowledge to deal with the safety and security issues

of synthetic biology. One example of this is the suggestion to make advice about experiments of concern

freely available to both members and non-members. The conflict arises when the report suggests that

there is a need for expert advice, whilst members themselves say they have already both formal

resources such as safety committees and personal contacts that fulfill these functions.

The main concern in the Asilomar mode is to frame the problem of biosecurity in terms of biosafety. The

question then becomes how to make people accountable to a process of regulation, even once that

group expands, such that bad practitioners can be identified. This mode of thinking is not redundant, on

the contrary, in a stabilized field it is necessary. However, they are insufficient for the hard task of

developing a daily practice in which those aspects which cannot be reduced to biosafety can be worked

on.

NSABB

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The National Science Advisory Board for Biosecurity was created at the recommendation of the National

Research Council report “Biotechnology research in an age of terrorism” (known as the Fink report). In

the December 2006 NSABB / NIH co-sponsored white paper on security and synthetic genomics, the

question asked is whether de novo synthesis escapes the purview of the extant system regulating Select

Agents, and what oversight system can mitigate misuse while minimizing restrictions on beneficial uses?

The biosecurity concerns named by the NSABB as posed by synthetic genomics are that it enables the

synthesis of a select agent (SA) by nontraditional means, and perhaps without USDA review. It is

possible to develop and produce agents that resemble and have the attributes of specific SAs without

being clearly identifiable as an SA on the basis of its sequence and that scientific advance outstrips list

based regulation. Their recommendations are for safety training (especially given that many have

engineering backgrounds), guidance for which sequences current regulations require authorization,

screening, mandated and improved software and an enhanced understanding of sequences associated

with virulence.

These all seem sensible safety and security measures. Highlighting the points made from Foucault’s

discussion of the concept of security, the NSABB rejected recommendations including the restriction of

access to new information about SAs, monitoring sale of equipment and the surveillance of students. In

the report from June 2007 on “life sciences and dual use” the NSABB developed a recommendation for a

framework within which the Government can develop a comprehensive system of identification and

review of dual use research, where dual use is identified as research with benevolent and malevolent

“potential” applications. The general framework is to minimize risk of misuse and maximize open

exchange of information. The recommendations have five elements which highlight a number of points.

First they want to assess dual use potential relative to criteria which select research “of concern”. They

want to encourage “responsible” communication, open sharing, to write a code of conduct and lastly to

build a framework that “addresses the importance of education and training in biosecurity issues for all

life scientists and describes previous, ongoing and future approaches to meet these goals”28

Tools such as the writing of codes of conduct are echoed in Europe as a useful approach in addition to

technical capabilities such as screening software. Alex Kelle of the EU SynBIOSAFE project quotes the

British biosecurity scholar Malcom Dando who suggests that, based on responses from 1,600 life

scientists during 60 seminars in 8 countries, life scientists “do not share the threat perception

widespread among biosecurity experts concerning bioterrorism or biological warfare. They do not think

that their own work might contribute to the threat. Life scientists have practically no knowledge of

legally binding international regulatory instruments, such as the Biological Weapons Convention.”29

Indeed Kelle’s own research of last year shows just this. Kelle conducted interviews with 18 leading

practitioners within synthetic biology on their awareness and knowledge of “experiments of concern”,

SB2, the Sloan report, the NSABB and the Maryland project “Controlling Dangerous Pathogens”. It is

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significant that, for example, 13 of the 18 interviewed had never heard of the Fink report which then

established the NSABB. The real question then is not just how to raise awareness of “issues” among

scientists working within SynBERC but how to make something like the political ecology within which

their science is being practiced a meaningful set of issues to engage with relative to their daily practice.

Echoing a point made by Dr Roger Brent of the Molecular Science Institute, the June 2007 NSABB report

makes the important point that synthetic biology is one among a number of sub-disciplines within the

life sciences which have to be brought within a more comprehensive approach to the challenge of

biosecurity.30 This makes tying awareness-raising to daily practice especially significant.

The report suggests that while virtually all life sciences research has dual use potential the number of

‘truly’ dual use research of concern is minimal. Importantly they suggest that on the basis of this,

“misuse of dual use research of concern is therefore a low-probability high-consequence event, and this

is a significant factor in the NSABB’s formulation of oversight recommendations.”31 This is obviously

significant relative to the broader norm of preparedness emerging from US national security sites.32 The

NSABB then insists that the response should be to institute new biosecurity measures to minimize this

risk, i.e. to minimize the probability of a low probability event taking place - contra preparing for the

consequences of a high consequences event. Indeed this is the framing of the problem at the MIT side of

SynBERC Thurst 4 where they have focused on the safety and security concerns of synthetic biology and

are using Christopher Anderson’s Tumor Killing Bacteria work as a model for thinking through the design

of “fail-safe” organisms. Anderson’s work involves a K-12 e.coli capsule which effectively “hides” itself

from the bodies immune system in order to bind to tumor cells and destroy them

In a section of the 2007 report entitled “Need for engagement of the life sciences community” the

NSABB names a number of key areas they want to see worked on; a culture of responsibility and three

stakeholder areas, health, national security, and the vitality of the life sciences research enterprise.

“Responsible scientists have a duty to be aware of the potential for misuse of their scientific findings

with dual use potential.”33 What kind of responsibility is this? Not just a minimization of risk but a

preparation for consequences. At the level of the lab this might be as small as to defend the scientific

enterprise rhetorically or as large as interfacing with local, national and international public health and

security actors. The 2007 NSABB report cites an article in Nature; “biologists must begin a process of

self-regulation for projects that have potential applications in developing bioweapons – or risk the

imposition of restrictive controls from the outside.”34 Self-regulation has its genealogy from the 70s and

Asilomar and it is not clear that self-regulation is sufficient. What are the practices that are adequate to

defending free inquiry within this security milieu? The NSABB highlight an insight from the UK’s Royal

Society / Wellcome trust report from earlier in the year where they suggest that, “the challenge is to

think beyond the obvious and identify those avenues of research and technologies that present risks of

being misused for harmful purposes that are quite distinct from the original aims of the work. This needs

imaginative thinking as the vast majority of work falls into the grey area of having some potential for

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misuse.”35 This means both imaginative thinking relative to misuse and imaginative thinking relative to

high consequence events.

Almost across the board, both those within synthetic biology and in the wider post-genomic scene

thinking about security issues have, not surprisingly named the same set of concerns; criteria for

identifying “risky” work, clarity over rules, promotion of responsibility both through screening

technologies and codes of conduct that will maintain responsible science. “Responsible” etymologically

is a word from the 17th century, “to be morally answerable for one’s actions”, whose root is the Latin

“spondere” – to engage oneself. It is clear that whilst a juridical-legal framework for the governance of

these technologies is necessary it is not sufficient. Moral rules as outlined in things like codes of conduct

and pledges are to a large degree meaningless when not tied to daily activities and practices. To

paraphrase Foucault, exercise of the self is not practiced relative to the law but relative to the

unforeseen events of life.

As the NSABB go on to say, “the responsible conduct and communication of dual use research of

concern depend largely on the individual conducting such activities. No criterion or guidance document

can anticipate every possible situation.”36 Responsibility does not mean only the individual capacity to

minimize risk but also the capacity of individuals within organizational forms to respond to events.

Inventing Preparedness Equipment

In a series of recent papers, Stephen J. Collier and Andrew Lakoff trace the emergence of preparedness

as a norm of rationality in U.S. government planning.37 Beginning with civil defense plans developed

against the threat of nuclear attack in the 1950s, they argue that preparedness norms and techniques

spread to a number of disparate domains. Preparedness plans are today applied to a wide range of

emergencies, including natural disasters, disease outbreaks, and terrorist attacks. In fact, today

preparedness is being reorganized as an “all-hazards” function, that is, a generic toolkit oriented

towards emergency-scale events without reference to their specific cause. In the 2007 National

Preparedness Guideline, the U.S. Department of Homeland Security names preparedness as the

“coordinated capabilities to prevent, protect against, respond to, and recover from all hazards in a way

that balances risk with resources and need.”

This vision is far-reaching. It recognizes that preparedness requires a coordinated national effort

involving every level of government, as well as the private sector, nongovernmental organizations, and

individual citizens. It addresses capabilities-based preparedness for the full range of homeland security

missions, from prevention through recovery. States, communities, and the Federal Government have

worked together for decades to manage natural disasters and technological emergencies, particularly

with regard to response and recovery.”38

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As the DHS Preparedness Guideline makes clear, preparedness, while a “national effort”, involves

coordination and interface between a number of different organizations, individuals, and governmental

agencies. The figuration of biopreparedness equipment itself is a product of a range of pivotal fora,

including the White House Homeland Security Council, the National Science Advisory Board for

Biosecurity, and the Sloan Foundation. Moreover, within the broader biosecurity problem-space,

preparedness is only one set of equipment at stake. In the following sections, we specifically address the

interface of local public health departments and a biological laboratory with the emerging

biopreparedness field. In each case, we aim to locate the interface of biopolitical equipment with new

preparedness norms.

At the same time, we aim to contribute to a refiguration of the terms of preparedness itself. Parakseue

is a term familiar to the ancient Greeks. As a technical term, it refers to the capacity to respond to

events whose form, temporality and impact cannot be known or calculated in advance, yet which must

be exercised in relation to. The term etymologically means both to equip and to prepare. The term has

over time been used to denote military activity and spiritual exercise as well as the name for the day in

preparation for the Sabbath. As Rabinow writes “*w+hen Foucault undertook his famous detour into

ethics during the 1980s, the topics of care and form became central.”39 Foucault’s discussion of

paraskeue in the lectures at the College de France asks, “how can the subject act as he ought, not only

inasmuch as he knows the truth, but inasmuch as he says it, practices it, exercises it?”40 This exercise is

not practiced relative to the law but relative to the unforeseen events of life. These exercises that work

on the events of life are not renunciatory exercises such as those found in Christian asceticism, rather

they equip; these exercises provide paraskeue. What is equipment made of? It is not just a supply of

true propositions but in Foucault’s terms “statements with a material existence” – statements which

have a logos (are “justified by reason”) must be turned into ethos. “For these material elements of

discourse really to be able to constitute the preparation we need, they must not only be acquired but

endowed with a sort of permanent virtual and effective presence, which enables immediate recourse to

them when necessary.”41 Equipment is a certain set of practices which have appropriate logoi that

develops an ethos. This equipment must be an aid in the event, it must be “boethos.”

June Allison in a philological exegesis of the term paraskeue in her work “Power and preparedness in

Thucydides” deftly explains the ambiguity in the term; paraskeue can be translated into English as either

equipment or preparedness. What is most interesting is the fundamental ambiguity in its use as both

noun and verb. Paraskeue is both a process and a product. “Paraskeue: A word for process and

components – by definition embodies the process of moving from a time or a state when something did

not exist to a time in which it is available for use.”42 Paraskeue, first introduced (by Herodotus and

contemporaries) as a compound of skeuos - para meaning besides or near and skeuos meaning

instrument, is never left without a clear understanding of what its objects are. Thus paraskeue both is

and is not an instrumental rationality. It is both a means and an end. Cognate forms in other languages

15

generally mean to dart, shoot, burst or thrust forth. It is certainly in motion. It has no fixed referent but

always with an appropriate relation to its object.

The specific innovation we suggest is that while techniques and technologies are necessary—for

example, preparedness plans, new surveillance technologies and safety-by-design for biological

systems— they must be taken up within an equipment that works on the practice of preparedness.

IV. Figuring Syndromic Surveillance and Biopreparedness Venues

Dual-Use: A Technical Solution?

The technical design and implementation of sydromic surveillance was at first extremely successful.

While experimentation with syndromic techniques began during the 1990s, by 2004 over one hundred

syndromic surveillance systems were in operation at local, state, and federal health departments. The

rapid proliferation of the technology depended on figuring it in terms of what can be called dual-use

integration. According to this figuration, new technologies such as syndromic surveillance allow the

biopolitical equipment of public health to smoothly “integrate” with apparently distinct norms such as

preparedness. As Nicholas King clarifies, public health and biosecurity planners employ the term dual-

use to characterize the apparent utility of specific techniques for both normal public health and

exceptional biodefense.43 In this section, we chart efforts to design syndromic surveillance in such a way

that it could integrate these distinct normative objectives.

Historically, one could locate the effectiveness of the dual-use integration discourse within the

simultaneous destabilization of U.S. public health and national security during the 1990s. The end of the

Cold War security system, and the popularization of the emerging infections concept, left both modes of

government in situations of uncertainty. In particular, new biological threats—including both emerging

diseases and bioterrorism—challenged the effectiveness of these governmental regimes. One solution

proposed was to reconceive the relationships between public health and national security techniques

and institutions. On the one hand, public health experts began to call on the discipline to include

bioterrorism within the purview of their discipline. Most significantly, D.A. Henderson revealed to the

first International Conference on Emerging and Infectious Diseases that “We now know that there are

nations and dissident groups who have both the motivation and access to skills to selectively cultivate

some of the most dangerous pathogens and to deploy them in acts of terrorism or war.”44 On the other

hand, a series of presidential directives officially defined biological threats, including emerging diseases

of natural origin, as threats to national security. Following Presidential National Security Directive NSTC-

7 in 1998, the U.S. military developed a unit named the Global Emerging Infections System. GEIS was

charged with developing dual-use techniques for disease control and preparedness. As GEIS experts put

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it in their foundational document, Addressing Emerging Infectious Disease Threats, “Recently it has

become common to view diseases resulting from biowarfare/bioterrorism as different from the above

emerging infections only with respect to their unnatural origin.”45

In sites ranging from local health departments to military organizations, syndromic surveillance systems

were seen as a technical embodiment of dual-use. GEIS built one of the first syndromic surveillance

systems, called ESSENCE, in 1998. The system initially monitored only military populations, but

reconceived of the military population as a sentinel for the nation at large. That is, events detected in

the military population were believed to provide early warning of events occurring in the overall

national population. Later that year, the New York City health department, an early experimenter with

syndromic surveillance techniques, built a system designed for bioterrorism detection. The system

monitored 911 EMS calls for surges in specific symptoms, such as respiratory distress, that might

indicate the early stages of a severe epidemic.46

While the military, some university research centers, New York City DOH, and a few other health

departments were developing syndromic systems, the technology remained largely experimental and

was not yet widely implemented. The September 11th attacks, as well as subsequent anthrax mailings

later that fall, provided an impetus for an assessment of syndromic surveillance as a ‘dual use’

technology. Interestingly, this impetus did not come exclusively or even primarily from the government.

In a meeting on October 2, 2001, the Trustees of the Alfred P. Sloan Foundation approved a special

appropriation oriented to disaster recovery. In addition, they defined bioterrorism as a “select national

issue” requiring particular attention. One of the first grants dispensed was a grant for $704,000 to the

New York Academy of Medicine, the New York City Department of Health (DOH), and the University of

Connecticut to “develop and disseminate easy-to-use software that aims to provide early warnings of a

bioterrorist attack or disease outbreak.”47 The goal was to update and streamline the DOH syndromic

system (at the time described by Sloan as “cumbersome”), and then put the software on the Internet for

distribution free of charge. The updated system would, the Sloan Foundation hoped, become a standard

for health departments across the country.

Part of the grant called on the recipients to organize a conference “to discuss the software and identify

potential improvements.”48 Despite this specific goal, the conference—called the National Syndromic

Surveillance Conference—became an annual event and a key venue for figuring syndromic techniques

with various equipments. At the first conference, the mode of integration was a key organizing principle

for bringing together a diverse range of actors and organizations around an apparently common set of

techniques and problems. Over four hundred experts attended from university, government health, and

military organizations. The introduction to the conference featured a pair of talks given by Drs. Margaret

Hamburg and Michael Osterholm. Whilst the transcripts of the talks are unavavailble, the titles are

telling. Both are entitled “Putting Syndromic Surveillance in Context”, with Hamburg adding

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parenthetically ‘national preparedness’ and Osterholm adding ‘public health’. Since the conference was

organized around a specific set of syndromic techniques—in fact a specific software program known as

SatScan—the effort to position syndromics within multiple equipmental contexts is significant.

Of course, much of the effort to integrate these equipmental figures was pragmatic. During early

interviews with public health experts, Fearnley often heard astonishment at the amount of money

appropriated by the federal government for bioterrorism detection. According to a 2007 report from the

Trust for America’s Health, the federal government distributed $6 billion dollars to states and

municipalities for public health preparedness over the past six years. And according to a different

accounting, federal agencies have spent over $32 billion on electronic surveillance systems and IT

initiatives for biodefense during the same period (DHS-OIG 2007). While many public health experts at

the local level were skeptical about the reality of a bioterrorist threat—and even the possibility of

bioterrorism detection—they believed that expanded funding for syndromic surveillance would

ultimately improve both surveillance specifically and public health more generally.

Meanwhile, the Congress and Administration were initially interested exclusively in bioterrorism rather

than natural disease threats, Dr. Rajeev Venkayya of the White House Homeland Security Council told

the audience of the 2006 syndromic surveillance conference, because they were convinced that the

particular characteristics of this threat required integrating public health infrastructure into the national

defense infrastructure. This was because, as Barbara Bullock argued characteristically, a bioterrorist

attack would only be detected through the appearance of the sick in hospitals and emergency rooms. Or

as Senator Akaka of the International Security, Proliferation and Federal Services Subcommittee

acknowledged in a July 2001 hearing on biological preparedness, “problems and concerns within the

public health system directly affect our ability to plan and respond to acts of bioterrorism.”49

The Centers for Disease Control and Prevention (CDC) became the key nexus for integrating dual-use

biosecurity. As Bruce Baughman, Director of Planning and Readiness at FEMA, put it at a July 2001

congressional hearing on biological preparedness, “the CDC is a critical link between the health and

medical community and the larger Federal response.”50 Specifcally, CDC focused on a technical solution

through the design of a national syndromic surveillance system known as Biosense. As Fearnley has

discussed in previous papers, Biosense was funded as part of a Congressional push for security against

biological terrorism in 2004. 51 What we focus on here is how Biosense was designed to be an integral

technical node linking local public health departments with Federal preparedness planning and

infrastructure.

Biosense is a CDC designed software application that collects data from national sources, aggregates the

data by state, municipal area, and zip-code and finally runs analytic algorithms to detect possible

outbreaks. The software was distributed to states and municipalities for interpretation by local health

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departments, but was also designed to provide situational awareness for national decision-makers.

When Fearnley heard Biosense director Lynn Steele at the 2005 syndromic surveillance conference, she

argued forcefully that Biosense was designed to be a dual-use system. On the one hand, she revealed

that Biosense was part of a larger federal preparedness plan that included environmental detection

systems known as Biowatch. Not surprisingly, the plans for this multiple pronged biosurveillance

approach were guided by the bioterrorism scenario exercises known as TOPOFF. At the same time,

Steele also reiterated that CDC believed such a system could be useful for routine public health, not only

bioterrorism preparedness. But despite Steele’s enthusiasm, questions would soon emerge about the

effectiveness of Biosense as a dual-use technology. Perhaps more importantly, the focus on a technical

solution to the new biological problems disregarded how techniques could be incorporated with an

equipmental practice.

In large part as a response to the technical implementation of Biosense, the dual-use integration mode

of figuration came under attack from local health departments, outside observers and governmental

auditors. The second mode of figuration applied to syndromic surveillance we call differentiation.

Differentiation as a mode of figuration emerged as an explicit critique of the dual-use mode. At the 2007

syndromic surveillance conference, Howard Burkom of Johns Hopkins Applied Physics Labs argued that

the technology faced a situation of “trade-offs.” In this figuration, the specific technical capacities of

new surveillance systems require a normative “decision” about ends. The same technology is not

equivalently functional for the purposes of, for example, both daily public health practice and early

warning of bioterrorism. As Burkom put it, “the goals and capabilities of health monitoring institutions

need to shape the tools for surveillance.” Before designing a system, he continued, the designers must

clarify “what we are trying to detect and on what scale. Goals need to be put out front so the

evaluations can be planned ahead of time, systems designed, and tools selected appropriately.”

Interestingly, the syndromic surveillance conference—now an annual event—became the space where

the differentiation argument was first articulated. Many public health personnel credited Dr. Arthur

Reingold, of the UC Berkeley School of Public Health, with identifying the key technical limitations that

would ground the differentiation argument. This was the technical problem of false-positives. As Dr.

Reingold put it in a subsequent article, “increases in the sensitivity of epidemic detection will come at

the cost of decreases in specificity, and vice versa.”52

In other words, if one built a syndromic system sensitive enough to provide early warning of a

bioterrorist attack, the necessary result would be a loss of specificity. False-alarms—the detection

through surveillance of epidemics that do not in fact exist—would proliferate. These false-alarms would

cost money and human work-hours potentially unsustainable in public health practice. The conclusion

many at local health departments took from Reingold’s argument was that one could design a

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syndromic system to detect unexpected bioterrorist attacks, or a system for use in daily public health

practice. But the same system would not likely be useful for both.

Inventing Bio-Preparedness: Emerging Venues

The debate around syndromic surveillance played out as a question around how public health

departments could interface with new ontologies of biological threat and new norms of security. On the

one hand, some participants argued that syndromic systems should enable the dual-use integration of

public health norms and new norms of biological preparedness. Others criticized the dual-use model and

argued that these norms must be differentiated, such that techniques designed for preparedness could

not necessarily be applied to public health ends. They pointed to technical problems, such as “false-

alarms”, which posed problems for the daily practice of public health. This critique emphasized that the

design of techniques must take account of how techniques are taken up within a practice.

However, a third mode of figuration can be illuminated within the biosecurity problem-space.53 This

mode takes up the invention of biopreparedness equipment in addition to the design of techniques of

preparedness. That is to say, this mode aims to incorporate new techniques within new methods and

venues. Doing so reframes the question of interface for local public health departments. Rather than an

interface between biopolitical equipment and new norms, public health is framed as a technique to be

taken up within new equipmental figures. We argue that the emergence of this mode of figuration

offers important insights into how problems of health and security can be reconstructed in the near

future. However, the very incipience of biopreparedness equipment requires concerted inquiry,

reflection and intervention. Of particular concern remains the relationship between public health and

biopreparedness infrastructures, and whether the invention of new venues corresponds to the existence

of new forms of expertise.

One site that has taken up the invention of biopreparedness equipment is a highly influential advisory

group known as the White House Homeland Security Council. Formed in October 2001, the Council

resembles the National Security Council in structure and function. Rather than the cabinet-level and

administrative practices of the Department of Homeland Security, the Council serves to guide both

specific policy and broad objective principles of homeland security. While holding no actual

administrative or legislative power, the recommendations of such advisory councils have significant

sway over both the President and members of Congress.54

Publicly accessible products of the Council include the National Strategy for Pandemic Influenza (2005),

the Lessons Learned report following Hurricane Katrina (2005), and an accumulating number of

Homeland Security Presidential Directives. Throughout these documents, the Council has attempted to

refigure national biopreparedness as equipment through a transformation of existing organizations and

infrastructural architectures. As Collier and Lakoff have shown, preparedness planning has a lengthy

20

history dating back to at least the 1950s.55 While producing preparedness plans was one part of what

the Council calls a “shared vision” of preparedness, achieving this shared vision required more than a

plan.

“There is a difference between a plan (saying “this is what we need to do”) and a trained, resourced set

of defined missions (saying “this is what we are going to do, and this is how we are going to organize,

train, exercise, and equip to do it”). For any plan to work, it must first be broken down into its

component parts. Next, the plan’s requirements should be matched to the human and physical assets

of each responsible department, agency, or organization.”56

In the plans put forward by the Council, public health and national preparedness were both integrated

technically and differentiated equipmentally.

On the one hand, their plans (including HSPD-5, HSPD-8, the Avian Flu Pandemic Strategy, the Lessons

Learned report, and others) called for a single, integrated preparedness system. For example, HSPD-5,

written in 2003 and the earliest of these reports, called on the Federal government to develop both a

National Incident Management System (NIMS) and a National Response Plan (NRP). According to the

directive, the NIMS “will provide a consistent nationwide approach for Federal, State, and local

governments to work effectively and efficiently together to prepare for, respond to, and recover from

domestic incidents, regardless of cause, size, or complexity.”57 More significantly, the directive called for

a NRP that “shall integrate Federal Government domestic prevention, preparedness, response, and

recovery plans into one all-discipline, all-hazards plan.”58 As the Council acknowledged in Lessons

Learned, the model for this technical consolidation was the integration of intelligence and military

information into the unified command and control of defense operations.

Public health interfaces with these preparedness plans as a technique, one that produces certain kinds

of information (data on human populations) and certain kinds of interventions (actions oriented towards

improving health of human populations). However, it does not interface as an equipmental figure. That

is, while the mitigation of disease in human populations is an important goal—the numerous plans for

influenza pandemics demonstrates its continuing significance—the Council explicitly differentiates the

normative ends of public health and preparedness. In our terms, they figure them as different

equipments. In HSPD-21, they define the term “public health” as “the science and practice of protecting

and improving the overall health of the community.”59 HSPD-21 then contrasts “public health” with a

new term, “public health and medical preparedness,” defined as

the existence of plans, procedures, policies, training, and equipment necessary to maximize the ability

to prevent, respond to, and recover from major events, including efforts that result in the capability to

render an appropriate public health and medical response that will mitigate the effects of illness and

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injury, limit morbidity and mortality to the maximum extent possible, and sustain societal, economic,

and political infrastructure.”60

Public health preparedness does not rely on “the concept of ‘surging’” conventional public health

practices, but rather requires the government to “transform the national approach to health care in the

context of a catastrophic health event”. In the quote above, the ends of preparedness include limiting

morbidity and mortality, but also extend to the sustainability of “societal, economic, and political

infrastructure.”

The Council’s vision of preparedness equipment subsequently took form in a particular biosurveillance

system. In January 2004, the Office of the President issued HSPD-9, Defense of United States Agriculture

and Food. The directive called for the Secretary of Homeland Security to create what a DHS audit calls “a

new biological threat awareness capacity.” To do so, it directs the Secretary of Homeland Security to

coordinate efforts by numerous federal agencies to “develop robust, comprehensive, and fully

coordinated surveillance and monitoring systems, including international information, for animal

disease, plant disease, wildlife disease, food, public health, and water quality that provides early

detection and awareness of disease, pest, or poisonous agents.”61

HSPD-10, Biodefense for the 21st Century, was issued later that year and more specifically identified DHS

as the central node in a future integrated biosurveillance network. As the DHS audit puts it, HSPD-10

calls for “an integrated and comprehensive attack warning system that will detect a biological attack at

the earliest possible moment and permit initiation of a robust response to prevent unnecessary loss of

life, economic impact, and social disruption.”62 While a number of specific surveillance systems were

already in operation—including the Biosense syndromic surveillance system, plant and food surveillance

systems, and the Biowatch environmental surveillance system—“the federal government has had no

single system for consolidating and examining bio-surveillance across federal, state, and local lines.”63

Later in 2004, DHS responded to the directives by initiating a program they called the National Bio-

Surveillance Integration System (NBIS). The idea was to integrate data not only from different agency

systems, but also from wholly distinct biological domains. As Acting Director of NBIS Kimony Smith put it

in comments before Congress in 2007,

“NBIS will integrate 20-40 disparate federal and commercial data sets containing human, animal, and

plant health data into a single national biosurveillance common operating picture and automatically

disseminate the information to appropriate agencies and organizations.”64

NBIS would “fuse” these distinct surveillance systems and distinct biological sectors to provide what DHS

called a “biological common operating picture (BCOP) for the world.”65 NBIS was designed as a new

venue for detecting significant biological events. By integrating data from disparate sources, DHS

22

technicians believed they could discover outbreaks that would be undetected in individual surveillance

systems. As the DHS audit put it, “By correlating ‘subthreshold’ data from across various sectors, NBIS

can help ensure earlier recognition of biologically significant information and events that otherwise

might not be reported beyond the originating agency.”66

The NBIS system refigures the relationship of disease and government. In the classic forms of modern

biopolitical government, disease was understood as a population phenomenon. Public health collected

information about and intervened in diseases effecting human populations, or epi-demics. Animal

health (e.g. the Environmental Protection Agency or the Department of Agriculture) collected

information about and intervened in outbreaks among animal populations, or epi-zootics. Under NBIS,

disease is refigured as a generic biological event impacting a common biological environment. HSPD-21

even defines biosurveillance as the “process of active data-gathering with appropriate analysis and

interpretation of biosphere data.”67 The novel forms of information integrated by NBIS demanded new

forms of interpretation. Interpretation of this data would not be social; it did not aim to normalize a

population. Instead, disease is understood at a molecular level, as a microbe that passes through many

domains (human bodies, animal bodies, air, water, food, laboratories) within a biosphere. NBIS aims not

to detect epidemics or to maximize population health, but to discover the emergence of significant

biological events in biological systems.

In terms of the diagnostic, NBIS required new specialists and new venues. “A venue in equipmental

composition characterizes the scene, site, or setting in which specialists work on design and synthesis.”68

Information collected by NBIS is “digitally fed into the system, integrated and illustrated by defined

ontologies, analyzed using specific analytical tools, and then disseminated via a web portal.”69

Ontologies, in computer science, are data models that represent concepts within a system domain and

relationships between these concepts. These computer-based ontologies and architectures differ

significantly from the “stable venues” Rabinow and Bennett call governmental. Rather than gathering,

sorting, and distributing, NBIS integrates, fuses and models. The result is a venue that is not

governmental. The sectors of populations or categories of objects divided among modern governmental

bureaucracies (e.g. public health, Food and Drug Administration, Department of Agriculture) are fused

into a common biological domain requiring new modes of veridiction and jurisdiction.

Yet as Fearnley has argued previously, discovering significant biological events in new digital ontologies

is not self-evident.70 The development of NBIS bears out this hypothesis. As NBIS went online in late

2005,71 a program manager established a “24-hour watch capability.” The watch-staff conducted

“nonstop research and analysis on biological events and their impacts worldwide” and issued daily or

weekly “situational reports.” Surprisingly, the watch staff was not initially made up of individuals with

medical training or public health expertise. Thus, the audit concludes, these reports “included

inconsistent interagency input, provided little or no medical oversight, and contained inaccuracies, as

23

reported by subject matter experts.”72 While the designers and planners of NBIS were clear that they

were producing new venues of expertise and security, it remained unclear how norms of preparedness

interfaced with existing governmental practices and biological ontologies.

While it is clear that new bio-preparedness venues are emerging in sites such as NBIS, they have yet to

become fully functional apparatuses. The question of how these venues will interface with public health

techniques and equipment remains viable and contested. While efforts are certainly under way to

invent biopreparedness equipment, the norms and forms of this equipment remain underdetermined.

As the NBIS system made clear, the production of new venues does not necessarily correspond with the

actual existence of new forms of expertise. In fact, the ontology of the “significant biological event”

remains undefined, crippling the efforts of NBIS monitors to interpret system data outputs. Along with

the design of techniques of preparedness, inquiry and reflection must attend to how these techniques

are taken up in a practice. Only the incorporation of techniques within a practice, shaped by

organizational forms and guided by ethical norms, can truly be called the invention of equipment.

V. Bio-Preparedness in the Laboratory

Equipment and Technologies: Towards Practice

Why focus on equipment and not technologies?73 One way of naming the difference between an

equipment and a technology is that the former is a practice, in the moral philosopher Alisdair

MacIntyre’s sense of the term. Synthetic biology is inventing new techniques and technologies, but is

fundamentally also changing how biology can be practiced. To treat it as a practice means that relative

to the political question of practical authority, the means by which it is regulated, this relation between

“science” and the “political” cannot be consider a purely bureaucratic and technical question. Currently,

for most of the scientists we have interacted with the question of security and regulation are considered

technical matters. To treat the political milieu relative to synthetic biology as a question of equipment is

to ask how the question of “responsible” or “good” science can be a question internal to the practice of

that science and structured by an organizational form.

MacIntyre offers an excellent overview of the term practice and what it might mean to consider science

as a practice. “By practice I am going to mean …activity through which goods internal to that form of

activity are realized in the course of trying to reach those standards of excellence which are appropriate

to and partially definitive of that form of activity with the result that human powers to achieve

excellence and human conceptions of the ends and goods involved are systematically extended.”74

24

This paragraph requires much unpacking even if the central point – that a practice is characterized by

the orientation to a good as a telos internal to that practice – is fairly clear. We might say that MacIntyre

points us towards a historicized anthropology of virtue. He gives us rich accounts of those qualities that

are virtues, which allow an individual to move toward the telos of a flourishing life. MacIntyre is quick to

make a distinction which does not appear in Aristotle. The virtues can be seen as a means to an end;

however they are not a technology or a technique. A technology is a particular relation of means to

ends, whereby means and ends can be adequately defined without reference to each other. A virtue by

contrast is a “means” of acting in which the end is internal to it. MacIntyre gives us two accounts of

virtues; in Homer, a virtue is a quality which enables an individual to discharge his or her social role. For

Aristotle, also read through Aquinas and the New Testament, a virtue is a quality which enables an

individual to move towards the achievement of a specifically human telos, whether natural or

supernatural. MacIntyre takes up this notion in which the cultivation of certain kinds of virtues is

contingent on the polis. The polis values those qualities of mind and character which would contribute

to the realization of the common good and identifies certain types of action as the doing or production

of harm of such an order that they destroy the bonds of community in such a way as to render the doing

or achieving of good impossible.

This diversion into Macitnyre is useful for a number of reasons, it shows on the one hand the reason

why focusing on equipment and not technologies is necessary if one is interested in the question of

flourishing as opposed to, for instance, fame, efficiency or maximization. Secondly, that these practices

have to be cultivated in a certain kind of venue, that goods internal to practice do not stem only from

that practice itself but also from the structures that the community of practitioners build and invent

within which to cultivate that practice. One might disagree with Macinytre that there is or can be a polis

in our time, however his point directs us to the national and international political structures that

govern and the laboratory space and organizational form of the science and how these interface. He

highlights that these interfaces are not extraneous but integral to a practice, in this case, of scientific

inquiry. The point here is that even if your laboratory is not working on re-engineering the 1918 flu virus

or small pox, actively building an organization and community of scientists that can respond to political

events is crucial for the practice of science in the contemporary world to flourish. Within the community

of synthetic biology Drew Endy and George Church, among a number of others, have been proactively

thinking about this.75

How can we understand virtues today and in relation to our object? “Virtues are dispositions not only to

act in particular ways, but also to feel in particular ways. To act virtuously is not, as Kant was later to

think, to act against inclination; it is to act form inclination formed by the cultivation of virtues. Moral

education is an education sentimetale.”76 And yet this is not enough to constitute the cultivation of

virtue, as in practice the distinction between the cultivation of virtue and the cultivation of discipline

through techniques may be indistinguishable.77 The point worth drawing out of MacIntyre is in

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historically locating anthropos and the good. It is worth then outlining the four elements of practical

reasoning that we are given in his reading of Aristotle; A person has certain desires, presupposed by but

not expressed in, her reasoning. Without desire “there would be no context for the reasoning and the

major and minor premises could not adequately determine what kind of thing the agent is to do.”78

Secondly, the major premise that doing something is good or needed is combined with a minor premise

where “the agent, relying only on a perceptual judgment, asserts that this is an instance or occasion of a

requisite kind” and then an action is taken.79 This can be restated as a way of thinking that ethics

conforms passions to a telos through reason and produces action (through correct judgment). This is not

so far from the characterization of equipment as the attempt to turn logos into ethos. “…inquiry

proceeds through mediated experience. It contributes to what used to be called Bildung, a process of

self-formation, that today might called an attitude or ethos.”80

Methods

What would this building of capacity consist of? Collier and Lakoff identify preparedness as the form of

rationality appropriate to working on vulnerable critical infrastructure. They outline techniques of

preparedness which include scenario planning, response and recovery exercises and kinds of

assessment. The authors argue that “while insurance seeks to calculate probability and distribute risk,

preparedness assumes that probability is not calculable and so enacts plausible scenarios in order to

reveal vulnerabilities.”81

As Carlo Caduff has written, “the dangerous events of the near future are distinctive in their virtual

quality”82, in contrast to the accident whose timing is unknown, the challenges for preparedness are

unknown in form. “The near future, accordingly, comes into view not as a realm of the possible, but as a

realm of the virtual.”83 According to this distinction then the possible is known form and unknown in

visitation, whereas the virtual is unknown in form. Cynthia Selin from ASU’s Centre for Nanotechnology

in Society in an recent article on scenarios titled “Trust and the illusive force of scenarios” suggests that

“by definition, scenarios are possible versions of the future so judging and evaluating scenarios is thus

not about revealing truthfulness, but rather demonstrating trust, reliability, credibility in the absence of

truth…”84 It is worth repeating a quotation from Foucault’s security lectures; “The specific space of

security refers then to a series of possible events; it refers to the temporal and the uncertain..” The

majority of people working within the policy realm refer to the “potential” of technology relative to a

bio-event, reflecting the political logic that Foucault suggests Machiavelli was the highpoint of, namely

the pairing of fortune/evil. The move to the modern security milieu made the population the object of

possible events, whose form is knowable but whose timing is uncertain (put within an apparatus to

control this uncertainty). I think it make a difference to argue that whilst scenarios can be used to

exercise possible versions of the future they may also be used to work on the future in a virtual mode.

One characteristic of scenarios as highlighted across the board by those who work on scenarios is that

26

they must be “plausible”. By this many things are implicitly referred to; for example, “realism” or

“verifiable.”

If the object of the scenario is the social, and specifically the securing of a population, then verification is

the right mode of veridiction. Making the object of scenarios the social puts it in the figure of biopower

such that the elements must be made object to a probabilistic reasoning. So taking up scenarios in terms

of non-probablistic reasoning, what can be taken seriously as a speech act and what is the object? What

kind of speech acts can be taken as serious? Peer review of technical knowledge may be step one. What

is serious enough to warrant continued discussion? According to Selin, at CNS “plausible” took on the

meaning of “negotiated in the context of a workshop”85. This is an interesting way of thinking about the

metric for assessing exercises, as it is akin to the veridictional mode suggested by Foucault of an “aid”.

Reflecting on scenarios and the relation to trust and efficacy Selin writes, “there is only anecdotal

evidence available to determine on what basis and for what reasons people may believe or trust in a

particular representation of the future described in a scenario and how their behavior or thinking

changed as a result.”86 If one thinks of scenarios as exercise to build capacity then it does not matter

whether one believes in or trusts a scenario. What matters is how you think in them. The question then

becomes what kind of thought is possible in what kind of scenario? Selin points out that “without action,

or the promises of action, the scenario exercise is moot and irrelevant”87. This may be the case

depending on the purpose of the exercise. The distinction Allison gives us from Thucydides is between

action and preparedness. The logos for action must be “heteimo”, or readily implementable, as Allison

suggests following Thucydides. The term “heteimo” Allison claims is used by Thucydides not just for

stylistic variation, but rather to distinguish between the particularity of a state of readiness and the

generality of a state of preparedness which takes particular objects of reference through the process of

equipping. As Rabinow suggests, in synthetic biology (as one among many emergent problem-spaces)

the “horizon of emergent challenges, which by definition can only be anticipated in general terms,

[should be] framed in terms of preparedness.”88 Allison points out that what is important is that just as

every action must have a suitable logos, so too the process of equipping. “Paraskeue can never exist

without a logos of some kind. This allows the reader to ask of any preparation whether the reasoning

behind it is sound or not. It can be seen in the History that, when one’s preparedness breaks down,

there is a corresponding deterioration in clear reasoning.”89

For preparedness, what counts is whether the exercise and the logos is an aid (boethos) rather than

immediately implementable (heteimo). Of course both require rumination as to the correct logos for the

object. We might wonder if the scenario can be used, instead of as a decision making tool for a

particular action, as an exercise for the building up of capacities to respond to the unknown and

unknowable.

27

We envisage the scenario tool as an aid for thinking in which those SynBERC researchers concerned

about the security milieu in which they operate are able to work on inventing adequate equipment to

prepare themselves by using kinds of thinking to engage their work in a way that means, for instance,

they could defend the pursuit of inquiry in the aftermath of an event in which their funding was

threatened. One SynBERC researcher at a Thrust 4 event at the laboratory on “Safety, Security,

Preparedness” was concerned that her work, the ultimate aim of which is to make higher yield of a

potentially lifesaving drug, could also be used to create new street drugs as they are part of the same

family. The laboratory (as a site of practice, as opposed to the building itself) may not be the correct

venue for building capabilities and exercising responses to events. The defense of research and the

ability to work on engaging with the political milieu within which work is being practiced will require

new venues.

Venues

“The venue is not a neutral scene … when composition is successful, the venue facilitates rather than

obstructs the design and synthesis of specific interfaces.”90

In the definition of venue in the Diagnostic, what comes out clearly is the notion of interaction. The

venue is the site of a certain kind of interaction. In an organizational context, where would those

interactions occur? This is not self-evident. Venues must be formed. The formation of subjects happens

within a structured space with norms, levels of commitment and interests. Selin in a piece for Time and

Society suggests that “temporal coding” is about “the way that time is built into stories”, borrowing a

term from Barbara Adam she calls them “timescapes”. “As a landscape architect designs spaces, a

timescape artist renders time visible and focuses on the design of temporality.”91 The point is that there

must be the creation of an organizational form within which kinds of temporality can unfold. For

example, the monastery is the form within which the temporal duration of the life and practice of a

monk is structured - the lab likewise for the scientist. Spaces have to be temporalized for particular

kinds of ends. It is clear that the lab is one space in which a kind of inquiry is practiced, in MacIntyre’s

sense, but it is possible that adjacent venues might be found to do other kinds of work. For instance, a

venue in which scenarios can be worked on might develop capacity and make terms like “responsible

science” connect to daily activities. Thrust 4 seeks to design and implement venues for pedagogy and

the building of capabilities adequate to face the problem of future contingents. Pedagogy is not the

same as technical training, it is about the forming of dispositions. Pedagogy requires exercises which

help to form a relationship between the subject doing the practice, the practice itself and the

community within which such a practice can take place. As Aristotle writes in the opening to the Politics,

“…every community is established with a view to some good; for mankind always acts to obtain that

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which they think good.”92Situating ourselves among contemporary blockages and opportunities, the

challenge is to reformulate them as problems to be worked on. In synthetic biology, as one among many

emergent problem spaces, the horizon of the emergent challenges can only be anticipated in general

terms and developed collaboratively.

VI. Conclusion

A sea-fight must either take place to-morrow or not, but it is not necessary that it should take place to-

morrow, neither is it necessary that it should not take place, yet it is necessary that it either should or

should not take place to-morrow93

The norm of preparedness—the demand to prepare for future events that cannot be secured through

the calculation of risk—is today recognized as an essential part of reconstructing a biosecurity

apparatus. In fact, the proliferation of this norm renders current biosecurity practices insufficient.

Syndromic surveillance has been designed as a technique of preparedness. It is a technology oriented

towards and taking seriously non-probablistic futures. The significance of syndromic surveillance for

laboratories is that it demonstrates the possibility of addressing the insuffiency of risk-based biosafety

and biosecurity. As a technology, it opens up a space for thinking about biological problems that cannot

be done within current biosecurity frameworks.

The insight from the laboratory case material is that biopreparedness must be taken up within practice.

The limitation of syndromic surveillance techniques is that they are yet to be taken up in these terms.

Practice can only happen in venues. That is, the goods of an activity will only be facilitated within a form

appropriate to that activity, with the attendant norms and temporality. For both the laboratory and

syndromics surveillance, the capacity to respond to events will depend on forming venues. Techniques

of preparedness must be built into generalized biopreparedness equipment.

That means the form of the venue is significant. While there has been much talk about biologiclal

preparedness in the US government and elsewhere, there has been insufficient attention to the design

and construction of biopreparedness venues. In public health, venue construction might be as small-

scale as the remediation of existing offices or might be as transformative as rethinking the traditional

divisions between human, animal and environmental management. In laboratory practice it will involve

the collaborative engagement of scientists with ethicists, public policy and other stakeholders within

SynBERC. However, the form and site that collaboration will take remains under-determined.

Only through the correct diagnosis of the problem can the appropriate venues be formed. This paper is

not aiming to offer first order deliverables but rather has been an effort towards this diagnosis.

29

30

1 Paul Rabinow, Gaymon Bennett, and Anthony Stavrianakis, “Response to ‘Synthetic Genomics: Options for Governance’” ARC Concept Note 10, 2006. 2 Gilles Deleuze, Bergsonism (New York: Zone Books, 1991): 15. 3 Ibid. 4 Paul Rabinow and, Gaymon Bennett. “A Diagnostic of Equipmental Platforms,” ARC Working Paper, No. 9, 2007,

53. 5 Ibid., 44.

6 Michel Foucault, History of Sexuality. Volume 1, An Introduction (New York: Vintage Books, 1990): 173.

7 Paul Rabinow, French Modern: Norms and Forms of the Social Environment (Chicago: University of Chicago Press,

1995): 12. 8 Michel Foucault, “Society Must Be Defended”: Lectures at the College de France, 1975-76 (New York: Picador, 2003): 246. 9 Michel Foucault, “Security, Territory, Population: Lectures at the College de France 1977-1978” (New York: Picador, 2007). 10 Ibid. 11 Ibid. 12 Rabinow, French Modern. 13 Rabinow and Bennett, “A Diagnostic of Equipmental Platforms.” 14 Cf. Yael Allweil, Lyle Fearnley, Kevin Karpiak, Timo Rodriguez, Anthony Stavrianakis, and Jerome Whitington, “Re-workings of the Biopolitical” Labinar Collaborative Paper, 2007. 15 Elizabeth Fee, “Public Health and the State: the United States” in Dorothy Porter, ed., Public Health and the State (Editions Rodopi, 1994). 16 Barbara Gutmann Rosenkrantz, “Cart before Horse: Theory, Practice, and Professional Image in American Public Health, 1870-1920” Journal of the History of Medicine (January 1974): 55-73. 17 Cf. Rabinow, French Modern; William Coleman, Death is a Social Disease: Public Health and Political Economy in Early Industrial France (Madison: University of Wisconsin Press, 1982). 18 Simon Szreter, “The Population Health Approach in Historical Perspective” AJPH vol. 93, no. 3 (March 2003): 421-31. 19 DA Savitz, C Poole, WC Miller, “Reassessing the role of epidemiology in public health” AJPH vol. 89: 1158-1161. 20 Coleman, Death is a Social Disease. 21 Rabinow and Bennett, “A Diagnostic of Equipmental Platforms”: 46. 22 Institute of Medicine, Emerging Infections: Microbial Threats to Health in the United States (Washington, D.C.: National Academy Press, 1992); Stephen S Morse, “Factors in the Emergence of Infectious Diseases” Emerging Infectious Diseases vol. 1, no. 1 (1995): Paul Ewald, The Evolution of Infectious Disease (New York: Oxford University Press, 1994). 23 Morse, “Factors in Emergence.” 24 Robert Carlson, “Future Brief: SB 1.0” online at http://www.futurebrief.com/robertcarlsonbio001.asp 25 Ibid. 26 Michel Foucault, “Security, Territory, Population: Lectures at the College de France 1977-1978.” 27

Cf. Nowotny, et. al., Re-thinking Science: knowledge and the public in an age of uncertainty (Cambridge, UK: Polity, 2001); Charis Thompson, Making Parents: the ontological choreography of reproductive technologies (Cambridge, MA: MIT Press, 2005).

31

28 National Science Advisory Board for Biosecurity, “Proposed Framework for the Oversight of Dual Use Life

Sciences Research” (2007): 3. Online at

http://www.biosecurityboard.gov/Framework%20for%20transmittal%200807_Sept07.pdf 29 Quoted in Alexander Kelle, “Synthetic Biology & Biosecurity Awareness In Europe”, SynBIOSAFE, (2007), 10. Online at www.synbiosafe.eu/uploads///pdf/Synbiosafe-Biosecurity_awareness_in_Europe_Kelle.pdf 30

Thanks to Dr Roger Brent 31 National Science Advisory Board for Biosecurity, “Proposed Framework for the Oversight of Dual Use Life

Sciences Research” (2007): 3. Online at

http://www.biosecurityboard.gov/Framework%20for%20transmittal%200807_Sept07.pdf 32 Cf. Stephen Collier and Andrew Lakoff, “Distributed Preparedness: the spatial logic of domestic security in the United States” Environment and Planning D vol. 26, no. 1 (2008): 7-28; Collier and Lakoff, “The Vulnerability of Vital Systems: How “Critical Infrastructure Became a Security Problem”, forthcoming in Myriam Dunn and Kristian Soby Kristensen (eds.), The Politics of Securing the Homeland: Critical Infrastructure, Risk and Securitisation, (Routledge, 2008) 33 National Science Advisory Board for Biosecurity, “Proposed Framework for the Oversight of Dual Use Life

Sciences Research” (2007): 3. Online at

http://www.biosecurityboard.gov/Framework%20for%20transmittal%200807_Sept07.pdf

35

Ibid 36 Ibid 37 Stephen J. Collier and Andrew Lakoff, “Distributed Preparedness: the spatial logic of domestic security in the United States” Environment and Planning D vol. 26, no. 1 (2008): 7-28. 38 Department of Homland Security, National Preparedness Guideline (2007). 39 Paul Rabinow, Anthropos Today, (Princeton: Princeton University Press, 2003): 3. 40 Michel Foucault, “The Hermeneutics of the subject: Lectures at the College de France 1981-1982”, 318. 41 Ibid 42June Allison “Power and preparedness in Thucydides”, (Johns Hopkins, 1989); 37. 43 Nicholas B. King, “The Ethics of Biodefense” Bioethics 19(4): 432-446. 44 Quoted in Laurie Garrett, Betrayal of Trust: The Collapse of Global Public Health (Hyperion, 2000): 488-89. 45 GEIS, Addressing Emerging Infectious Disease Threats. Online at: http://www.geis.fhp.osd.mil/GEIS/aboutGEIS/history.asp 46 Heffernan R, Mostashari F, Das D, Bescuildes M, Rodriguez C, Greenko J, Steiner-Sichel L, Balter S, Karpat A, Thomas P, Phillips M, Ackelsberg J, Lee E, Leng J, Hartman J, Metzger K, Rosselli R, Weiss D, “System Descriptions: New York City Syndromic Surveillance Systems”, Morbidity and Mortality Weekly 53(Suppl.) (2004): 23-27. 47 Alfred P. Sloan Foundation, 2002 Annual Report. 48

Ibid., 65. 49 U.S. Senate, “FEMA’S Role In Managing Bioterrorist Attacks And The Impact Of Public Health Concerns On Bioterrorism Preparedness” 107th Congress (July 21 2001). 50

Ibid. 51 Lyle Fearnley, “Information Breakdown: Redesigning Syndromic Surveillance for Biosecurity” in Collier and Lakoff, eds., Biosecurity Interventions (New York: SSRC, forthcoming); Fearnley, “Signals Come and Go: Syndromic Surveillance and Styles of Biosecurity” Environment and Planning A (forthcoming 2008). 52 Arthur Reingold, “If Syndromic Surveillance is the Answer, Then What is the Question?” Biosecurity and Bioterrorism: Biodefense Strategy, Practice and Science 1(2) 77-81. Reingold (2003: 77-81) 53 We thank Dr. Roger Brent of the Molecular Sciences Institute for this insight.

32

54 Ibid 55

Stephen Collier and Andrew Lakoff, “Distributed Preparedness: the spatial logic of domestic security in the United States”. 56 White House Homeland Security Council, The Federal Response to Hurricane Katrina: Lessons Learned (February 2006): 69. 57

Homeland Security Presidential Directive-5 (2003), online at http://www.whitehouse.gov/news/releases/2003/02/20030228-9.html 58 Ibid. 59 Homeland Security Presidential Directive-21 (2007), online at http://www.whitehouse.gov/news/releases/2007/10/20071018-10.html 60

Ibid. 61

Homeland Security Presidential Directive-9 (2004), online at http://www.whitehouse.gov/news/releases/2004/02/20040203-2.html 62 Department of Homeland Security, Office of Inspector General, “Better Management Needed for the National Bio-Surveillance Integration System Program” (2007), online at http://www.dhs.gov/xoig/assets/mgmtrpts/OIG_07-61_Jul07.pdf 63 Ibid. 64 Senate Homeland Security and Governmental Affairs Committee, Subcommittee on Oversight of Governmental Management, the Federal Workforce, and the District of Columbia, “Testimony of Dr. Kimothy Smith, Acting Director of the National Biosurveillance Integration Center” October 4, 2007. 65 Department of Homeland Security, Office of Inspector General, “Better Management Needed for the National Bio-Surveillance Integration System Program” (2007): 4. 66 Ibid., 3. 67 Homeland Security Presidential Directive-21 (2007), online at http://www.whitehouse.gov/news/releases/2007/10/20071018-10.html 68 Paul Rabinow and, Gaymon Bennett. “A Diagnostic of Equipmental Platforms,”44. 69 Department of Homeland Security, Office of Inspector General, “Better Management Needed for the National Bio-Surveillance Integration System Program” (2007): 3. 70 Lyle Fearnley, “Information Breakdown: Redesigning Syndromic Surveillance for Biosecurity” 71 Apparently in response to a November speech by President Bush. The timing—in concurrence with the avian flu pandemic documents and the Katrina Lessons Learned report issued by Homeland Security Council—is probably not coincidental. Carlo Caduff has pointed out the relationship between Hurricane Katrina and influenza pandemic planning in recent work. 72 Department of Homeland Security, Office of Inspector General, 2007, “Better Management Needed for the National Bio-Surveillance Integration System Program”: 9-10. 73 A technique is a specific practice which can be taken up in either an equipmental or a technological mode. 74

Alisdair MacIntyre, “After Virtue: A study in moral theory”, (University of Notre Dame 1984); 187 75 Bugl et al “DNA Synthesis and biological security”, Nature Biotechnology 25, (2007) 627-629.

Brent, Roger “In the Valley of the Shadow of Death”, http://dspace.mit,edu/handle/1721.1/34914 76 Alisdair MacIntyre, “After Virtue: A study in moral theory”, (University of Notre Dame 1984);149 77 MacIntyre uses the examples of a courageous solider or a child learning chess 78 Alisdair MacIntyre, “After Virtue: A study in moral theory”, (University of Notre Dame 1984);149. 79 Ibid. 80 Paul Rabinow, Anthropos Today, (Princeton: Princeton University Press, 2003):3 81 Stephen J. Collier and Andrew Lakoff “Vital Systems Security.”, ARC Working Paper, No.2, 2006 , 4 82 Caduff, Carlo “The Futures of Risk”, unpublished field statement, UC Berkeley 2005

33

83 Ibid 84

Cynthia Selin “Trust and the illusive force of scenarios”, Futures Volume 38, Issue 1, (February 2006), 1-14; 3. 85

Personal communication 86Cynthia Selin “Trust and the illusive force of scenarios”, Futures Volume 38, Issue 1, (February 2006), 1-14; 3. 87Cynthia Selin “Time Matters: Temporal harmony and dissonance in nanotechnology networks” Time & Society,

Vol. 15, No. 1, , (2006), 121-139 ;126. 88 Paul Rabinow, presentation, Thrust 4 Security event, LBNL, October 2007 89

June Allison “Power and preparedness in Thucydides”, (Johns Hopkins, 1989); 136. 90

Rabinow, Paul and Bennett, Gaymon. “A Diagnostic of Equipmental Platforms,” 91 Cynthia Selin “Time Matters: Temporal harmony and dissonance in nanotechnology networks” Time & Society, Vol. 15, No. 1, , (2006), 121-139 ;126. 92 Aristotle, Politics, book 1part 1, Online at http://classics.mit.edu/Aristotle/politics.1.one.html 93

Aristotle, On Interpretation, 9, 19, a 30, Online at http://etext.library.adelaide.edu.au/a/aristotle/interpretation/