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Nano Safety Research Plan Questioned

DEC 22, 2008

The National Research Council (NRC) recently released a generally negative assessment of the current research plan for assessing nanotechnology safety. The report , “Review of the Federal Strategy for Nanotechnology-Related Environmental, Health, and Safety Research,” characterized the current plan as insufficient.

Nanotechnology is a general field of research referring to the manipulation of structures smaller than 1,000 nanometers, at the molecular and even atomic level. The burgeoning prevalence of drugs and consumer products created through nanoresearch has raised serious questions about the evironmental and health risks of nanotechnology.

The National Nanotechnology Initiative (NNI ), a program consisting of 25 federal agencies with a stake in nanotechnology is tasked with assessing these concerns. The NNI is overseen by the Nanoscale Science Engineering and Technology (NSET) Subcommittee in the National Science and Technology Council (NSTC ).

In 2007 the National Nanotechnology Coordination Office (NNCO), which provides technical and administrative support to the NSET subcommittee, asked the NRC to review NNI’s “Strategy for Nanotechnology- Related Environmental, Health, and Safety Research” report . In evaluating the NNI strategy, an NRC committee chaired by David Eaton considered: “What are the elements of an effective nanotechnology risk-research strategy? Does the federal strategy have those elements? With respect to the federal strategy, have appropriate research needs been identified, are the gap analysis and the selection of priorities among research needs complete, and does the research identified support risk-assessment and risk-management needs?”

The NRC identified nine elements as essential to any effective risk-research strategy. Those nine elements are-- a statement of purpose, a set of goals, an evaluation of the state of the current science, a road map, ways to measure progress, review, an inventory of resources, mechanisms to achieve goals, and accountability.

The NRC’s report asserts: “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 [environmental, health, safety] risks posed by nanotechnology.”

Regarding the final set of questions on the quality of needs identified, the NRC’s assessment was mixed. Although the NRC committee noted that the five categories of research identified by the NNI report “address research that is important,” and “cover the necessary broad research topics,” the NRC faulted NNI for “valuable but incomplete” research needs in their categories. The five research categories are-- instrumentation, metrology, and analytical methods; nanomaterials and human health; nanomaterials and the environment; human and environmental exposure assessment; risk management methods.

The NRC committee also took issue with NNI’s gap analysis: “Uniformly, the committee agreed that many of the 246 research projects listed in Appendix A [of the NNI report] are of high scientific value, but the vast majority are of little or no direct value in reducing the uncertainty faced by stakeholders making decisions about nanotechnology and its risk-management practices.”

The NRC report also added this: “Although many of the NNI’s identified research needs support risk-assessment and risk-management needs, the committee concluded that failure to identify important research needs, the lack of rationale for and discussion of research priorities, and the flaws in the gap analysis undermine the ability to ensure that currently funded research adequately supports EHS risk-assessment and risk-management needs and provides critical data for the federal agencies.”

Ultimately, the NRC committee concluded that the NNI report “does not describe a strategy for nano-risk research,” but added later; “it does an excellent job of identifying numerous specific topics on which more research is needed...”

House Committee on Science and Technology Chairman Bart Gordon (D-TN) cited the report as an argument for passage of the “National Nanotechnology Initiative Amendments Act” (H.R. 5940) which he plans to reintroduce in the next Congress. This legislation would require NNI to develop an EHS research plan with near-term goals, and would assign responsibility for developing the EHS plan to an associate director of the Office of Science and Technology Policy (OSTP). Gordon said in a press statement that he is confident the Senate will pass H.R. 5940 as the House did this year.

A response to the NRC report from the NNCO is available here .

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