“Whatever else they are, they aren’t brains. They aren’t organized like brains. They aren’t big enough,” said Hank Greely, a Stanford University professor and expert in law and biosciences who works with researchers in the field. “But more importantly, they don’t have the right architecture.” By that he means organoids are basic parts of a whole, similar to how a broom closet or stairwell would never be considered a skyscraper.

Greely, the Stanford professor, said many such scenarios are a long way off. Some, in fact, may never arise. He is heartened, though, that researchers are already taking these questions seriously, “whether they’re sensitive because they think it would be ethically terrible, or whether they’re sensitive because they think it would be terrible headlines and hurt their funding,” he said. “Or both.”

What happens if and when they become sentient? Or, in Greely’s words: “Is it unhappy? Is it in pain? Is it thinking? Is it Gregor Samsa in the body of a cockroach, thinking ‘Let me out of here?’”

Many experts, including Greely, agree that point hasn’t yet arrived. Muotri, the UCSD researcher, is among the few to believe that organoids may already be conscious in “their own way” — though different from human consciousness.

Greely said he isn’t worried yet. “But if you make an assembloid that has 20 carefully created and selected organoids connected to each other, you know, that could be about the size of a mouse brain. And we know that mice have behaviors. We’re pretty damn sure that mice feel pain,” said Greely. “Now we allow research that causes pain to mice, but we regulate it. One of the more technical issues with organoids is there’s nobody to regulate them.”

Stem cell-derived research, which includes organoids, is regulated in the U.S., as is animal research, which is relevant when human-derived organoids are transplanted into rodents and other creatures. But the broader focus of those regulations do not cover the unique and specific questions that arise from organoid research.

In November, Greely and Pasca co-organized a conference in California in part to discuss what such an entity might look like, who would be behind it, and who would pay for it. So far, they haven’t come up with a suggested path forward: “Most of the discussion, I thought, seemed to agree with the idea that it would be good to have something looking at this field,” Greely said. “I don’t think there was any obvious consensus on what that should be, or what ‘looking at’ meant,” though he added that he hopes a path forward will arise after they digest the discussions.

Today, some labs may collect donors’ cells directly — in which case they would explain their use for specific studies — but many researchers use stem cell lines derived from donors who provided a broad consent, meaning they may not be aware their genetic material could be used in organoid research. “With particularly controversial areas, you need something more than just a blanket consent,” said Greely.

Informed consent isn’t an issue unique to organoid research, but it may carry an added weight when considering the ick factor. A participant may not realize, for example, that their DNA could be used to develop an organoid that then gets implanted it into a rat.

“It’s not like there’s a great groundswell of people out there saying, ‘You’re misusing my cells. I never agreed to this,’” Greely added. “But I worry that at some point that would happen.”

Greely said it’s important to seriously consider such concerns. “Even if it’s not real, if people think it’s real, if people care about it, it is in some sense real,” he said.

As the field matures, experts are mindful of the effect that public opinion could have on its fate. If someone were to publicly come out saying they didn’t realize their cells would be used to develop organoids, and that they found such research disturbing, “that would be bad ethically,” Greely said. “It would also be bad politically for science. And I think both of those should be avoided.”

Scientists, he added, should do their best to keep the public looped in on the latest research so that there are no “disconcerting surprises.” Greely remembers the backlash that Dolly, the famous cloned sheep, received in the ’90s. “When Dolly’s birth was announced, we went from one lamb to ‘armies of cloned warrior slaves,’ kind of overnight,” he said. “Countries and states all over started passing laws about banning human cloning long before any human embryo had ever been cloned. And we still don’t have any cloned human babies.”

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