First, autopoietic theory is explicitly epistemological and non-ontological. There has been a persistent push on the part of reviewers and critics to force Maturana and/or Varela to state their ontology, or else to posit one on their behalf. . . .

The best example of this concerns the application of autopoiesis to social systems. While a number of writers have attempted to dissect societies with respect to their "organization" and "structure", there is no indication that such an exercise follows from Maturana's and Varela's ideas. The most well-developed example is, of course, Niklas Luhmann, who has built up a vision of societal autopoiesis, but at the expense of adopting "communicative acts" as the fundamental units of analysis. This constitutes a shift of "domains of explanation" away from the biological roots of cognition and toward the network of interactions among observers. Such an analysis affords such "acts" an effective status as ontological primitives. What is problematical is that these new primitives are then treated in isolation from the phenomenology of the living actors who realize them.

Remember -- Maturana started all this as an enquiry into cognition. The theory begins from the viewpoint of how an observer, as a living system, "works". It then proceeds to describe the phenomenology of the living system in action, and (at least for Maturana) how that phenomenology extends to an explanation of interactivity (mutual orientation, structural coupling, etc.).

The entire point is that no explanation for "out there" is valid unless that explanation proceeds from the biological basis of the observer. As such, a strict (and literature-supported) interpretation for Maturana and Varela's work is that there is no ontology exclusive of the observer.

Does this make autopoietic theory problematical? You bet it does -- particularly if you have problems dealing with anything other than a linear theoretical progression from a fixed fundament. Such a "linear" progression has been the hallmark of Western philosophy and science -- just plant a (usually 'given') fulcrum somewhere, then obtain leverage by pushing against this fixed point. Whether you plant your fulcrum in the "objective" or the "subjective", it's all the same. One of the promising aspects of cybernetics was its recognition of cyclicity (cf. "feedback"). One of the main reasons cybernetics hasn't (yet) lived up to that promise was the parallel postulation of a new fundament ("information") upon which today's unfortunate objectivist / cognitivist biases were built. For all the holistic, systemic, and processual ideas encompassed by cybernetics, its practice has commonly fallen back into positivistic channels.

Second-order cybernetics was built upon the need to (re-)insert the observer into any system description. A system is what it is, how it is, and where it is (within some hierarchy, perhaps) from some observer's perspective