Ethical and Social Considerations for Increasing Use of DTC Neurotechnologies

摘要

In her article, Kreitmair (2019) identifies eight ethical dimensions to address with respect to direct-to-consumer (DTC) neurotechnologies to ensure they contribute to human flourishing. Here we expand on three important points for further reflection. USE OF DTC NEUROTECHNOLOGIES FOR SELF-TREATMENT: First, Kreitmair seems to suggest that DTC neurotechnologies are not classified as medical devices under Food and Drug Administration (FDA) law. The author supports this claim, in part, by stating, "DTC neurotechnologies are ones that consumers decide whether to buy, not ones that are prescribed to them or monitored by physicians" (155). However, assuming a DTC neurotechnology can achieve outcomes like decreasing stress or improving cognition, it would presumably do so by affecting brain function and, potentially, brain structure. Given that the FDA's definition (FDA 2018) of a medical device includes any device "intended to affect the structure or any function of the body of man or other animals and which does not achieve its ... purpose through chemical action," such a device would be considered "medical" even if not prescribed by a clinician.