authored by Margaret Glass, ASTC
With all the media attention devoted to bailouts and the Senate replacement scandal, the stalled process of NNI reauthorization tends to fall under the radar. On Dec.11, however, the National Academies released an executive summary reviewing the federal strategy of risk-assessment and management related to the environmental, health, and safety implications of nanotechnology. Does the NNI have a robust strategy in place to minimize risk to society from nanotech development? Not according to the review. It's easy to get all these working groups, subcommittees, and reports that deal with nano mixed up (at least for me), so here a quick history behind this current review. The Nanotechnology Environmental Health Implications (NEHI) Working Group is where the various NNI agencies coordinate activities related to understanding potential risks of nano to public health and the environment. The NEHI coordination efforts have produced a series of documents that identify environmental, health, and safety (EHS) research needs related to nanomaterials. The latest of these, Strategy for Nanotechnology-Related Environmental, Health, and Safety Research, (2008), was supposed to identify priority research areas and present a decision-making strategy to inform responsible development of nanotechnology in the US. The National Nanotechnology Coordination Office, (NNCO) which oversees the day-to-day operations of the NNI, asked the National Research Council (NRC) for an independent review of this strategy. To do this, the NRC’s Board on Environmental Studies and Toxicology and National Materials Advisory Board appointed a Committee for Review of the Federal Strategy to Address Environmental, Health, and Safety Research Needs for Engineered Nanoscale Materials; this committee authored the current review. Members of the committee met in two workshops at the National Academies in March and May 2008. The participants and agendas of these meetings are available in Appendix C of the review. Biographical sketches of the individual committee members are in Appendix A. The committee was asked to conduct a scientific and technical review of the federal strategy. The results of this review are a set of harsh but carefully couched criticisms about science as a process at the federal agency level. I have been through this review summary a number of times and every time I have noted new phrases that make me uneasy. At the risk of taking things out of context, I'm going to quote some of these passages verbatim, followed by my paraphrase (in italics). But by no means should this be considered a substitute for reading the review yourself. “NNI does not have the essential elements of a research strategy—it does not present a vision, contain a clear set of goals, have a plan of action for how the goals are to be achieved, or describe mechanisms to review and evaluate funded research and assess whether progress has been achieved in the context of what we know about the potential EHS risks posed by nanotechnology.” There is no coherent strategy to identify goals and assess if they have been reached. “The committee concludes that how the FY 2006 data were used in the analysis is probably the greatest deficiency in the 2008 document, inasmuch as it is the foundation of the document’s evaluation of the strengths, weaknesses, and gaps in currently funded federal research. This is problematic because most of the listed FY 2006 research projects were focused on understanding fundamentals of nanoscience that are not explicitly associated with risk or the development of nanotechnology applications.” Research focused on fundamentals of nanoscience is of little help when assessing risks associated with emerging nanotechnology applications. “The NNI strategy does not identify resources necessary to address questions concerning EHS research needs for nanomaterials.” ... “For example, when developing their own research strategies, agencies tend to ask, What research can we do within our existing capabilities? rather than the more appropriate question, What research should we be doing?” The kind of fundamental research to bridge gaps in knowledge is not identified. “... the 2008 document substantially overestimates the general nanotechnology- related research activity in environmental, health, and safety research.” Existing EHS research can't be directly applied to nanotechnology. “...targeted, effective research that identifies and eliminates potential environmental and health hazards of engineered nanoscale materials should have high priority for the nation. An effective national EHS strategic research plan is essential to the successful development of and public acceptance of nanotechnology-enabled products.” NNI needs a plan to assess EHS risks of engineered nanoscale materials to ensure technological development and public acceptance. “... committee concludes that a truly national strategy cannot be developed within the limitations of the scope of research under the umbrella of the NNI.” Scope of NNI is too limited to create a national research strategy. The bottom line is that the committee states that the NNI is not more than the sum of its parts – the NNI is a coordination program among federal agencies, not a research program. In addition, because the NNI is supposed to ensure U.S. competitiveness through the rapid development of a research and development program in nanotechnology while ensuring its safe and responsible development, there the potential for a conflict of interest. Why is this important to us - the NISE Network? I don't know about you, but I have often worried that informal science education dealing with emerging technologies could be perceived of as advocating those technologies. We walk a fine line in informing our publics about current technologies and accepting money from sponsors and funders to advocate for these new applications. Are we sure we inform, rather than advocate? Is that an issue for anyone else?