The second argument, that there are covenantal elements in the Creation narratives, is somewhat dependent upon the first for its advocacy. Nobody denies that there is a repetition of parts of the Creation mandate in Genesis 9. But such a repetition was necessary seeing that God had just wiped out every living thing from the map. That necessity doesn’t extend however, to requiring a covenant given to Adam in the Garden. And we are not justified in drawing an inference that the earlier use of the words were thereby covenantal simply because their repetition to Noah was in a covenantal setting. One wonders how the Lord was to warn our Adam about taking from the forbidden tree without including some of the language which would later be used in covenants. Covenants often included prohibitions and warnings. They were necessarily made by or with human parties. In that sense, all prohibitions are formulaic and “covenantal”(speaking anachronistically), but that does not turn them into covenants. Again we sense a lack of control in the understanding of the function of a Divine covenant.
However, this belief in a pre-Noahic covenant just might be supplemented by Hosea 6, even though it must be admitted that the all-important substance of that particular “covenant” remains anyone’s guess. Attempts to designate Genesis 2:16-18 as the oath are exegetically specious. All one can properly bring out of the text is what is there: a prohibition and a dire warning. That is it. So one is left with a vacuous covenant with no identifiable solemn oath. Not much to go on for the exegete, but rich pickings for a pious theologically charged imagination that wants to find light in between Scripture’s gaps!
As for the third argument put forth by defenders of a pre-Noahic covenant; the mention of “Adam” in Hosea 6:7, we are unmoved. Although studies by Warfield and others lend some superficial credence to the notion, there remain too many problems and unanswered questions that plague it. The immediate context favors a location (Tell ed-Damiyeh?). Concerning the identification of it with the person Adam, McKenzie comments:
modern scholars are nearly unanimous in rejecting this understanding. For one thing, there is no mention anywhere else in the Bible, including Genesis 2-3, of a covenant between God and Adam… Furthermore, the word “there” in the second line of the verse suggests that Adam may be a place name, and this possibility is strengthened by the places mentioned in subsequent verses – Gilead (v.8) and Shechem (v.9).
Duane Garrett thinks there is a deliberate wordplay between the man Adam and the place of transgression, the town of Adam in area of Gilead. But we must repeat the fact that even if the exegetical case for the person Adam were in the future universally accepted, we would still be none the wiser as to what the covenant actually entailed. We would certainly not be constrained to embrace a “covenant of works”, a “covenant of grace”, a “Creation covenant” etc., an Adamic covenant’, etc., on such flimsy internal evidence.. Plus, we would not be one step further to knowing what the putative covenant said. Better then, not to assert anything.
While not everyone will agree with my conclusions, and while respect is owed to those whose opinions differ, I believe the arguments for a covenant prior to the Noahic covenant fall short of being convincing and rely upon inferences brought to the text. More important is the glaring fact that there is just not enough scriptural data to provide content for these pretender covenants.
Personally, I could wish that I could confidently detect a true covenant in Genesis 1, or Genesis 1-2, or Genesis 2–3. I am, after all, attempting to show that the biblical covenants contain both the telos and the eschatos of the Creation Project as set out in the pages of Scripture. But I fear that any attempt to ground my scheme upon a covenant without a defining oath would be to make it, in fact, groundless. And so I am content to connect the covenants with Noah, Abraham, David, etc., with the already noted correspondence between God’s speech and His actions and to treat Divine covenants as intensifications of this motif.
I conclude, then, that for all the assertions of a pre-Noahic covenant notwithstanding, there is little or nothing to show for it but the personal judgments of good men who pour their own meanings into an empty vessel. The biblical record remains unchanged. The first covenant in the Bible of which we can speak meaningfully is the covenant God made with Noah after “the world that then was perished.”
 Ibid, 164-165. He cites Craig Bartholomew’s note about marriage being an example of a covenant before the Fall. I shall return to this, but will just say here that marriage is not a Divine-human relationship. Furthermore, both Proverbs 2:17 and Malachi 2:14 refer to the encroachments of sin within marriages. It might be argued that the covenantal aspects of marriage became necessary only after the entrance of sin. We have argued that the essence of a covenant is to insure obedience of one or both of the parties involved. This would be unnecessary prior to Genesis 3.
 Even Gentry, when rightly speaking of “the covenant with Noah [creating] a firm stage of history where God can work out his plan for rescuing his fallen world” (Ibid, 175), tacitly agrees that this is indeed the principle purpose of the covenant; namely, no more flood guarantees the uniformity of nature and a linear flow of history. It does not then appear to be necessary to for God to bind himself to Creation this way before the Flood.
 See J. Glen Taylor, ‘Hosea’, ZIBBC, Vol. 5, 28
 Steven L. McKenzie, Covenant, 22-23. Earlier he notes that, “The Assyrians probably had a covenant affirming Israel’s vassalhood, against which they rebelled.” – Ibid, 8. He gives Hosea 12:1; 10:4, and 6:7 as possible references.
 Duane A. Garrett, Hosea, Joel, NAC 19A, 162-163
 Walter C. Kaiser rightly refers to these as “hypothetical” covenants. See his The Promise-Plan of God, 26.