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Japan is unusual among industrialized countries in its reluctance to use brain criteria to determine death and harvest transplant organs. This results from public distrust of the medical profession due to an earlier incident, and from concern that technological interventions will threaten religious and cultural traditions surrounding death and dying. Public acceptance is growing, however, as medical professional groups and universities develop brain criteria, and as pressure from patients who could benefit from a transplant, as well as from foreign countries, increases.

Comparison of transplantation medicine in Sweden, Denmark, Germany, Spain and Portugal reveals many and important differences with respect to frequency of transplantations, frequency of life donations, legal regulations and influence of the family on organ donation. The differences observed are at least partly related to cultural and value differences between the various countries, but many questions need to be studied systematically and in more detail before useful conclusions can be drawn. One study would have to address the problem of how differences in the family influence on organ donation can be explained. Another question needing further clarification concerns the exact meaning of "medical decision" and "medical criteria" because these terms, on which access to-and selection from the waiting list largely depends, are equivocally defined and seem to differ according to different traditions. Open questions also arise with respect to the influence of "closeness or distance" on medical decision making. The findings indicate that it would be premature to propose common guidelines to be observed within Europe as long as the above mentioned and some further questions have not been systematically studied and thoroughly analyzed.

No abstract

This paper reports on recent developments in the rise of bioethics in Japan. Much of the recent interest in bioethics in Japan is seen as a response to various civic movements. The women's liberation movement, access to equal opportunity, and the recognition of patients' rights and the importance of informed consent are among some of the movements influencing the development of bioethics in Japan. The author argues that this movement is to be encouraged and fostered by health care professionals, public policy makers, as well as lay persons in Japan.