Competing nanotechnology control frameworks

Competing nanotechnology control frameworks

We’ve written here before about the Environmental Defense/DuPont effort to create a framework to deal with nanotechnology environmental, health, and safety (EHS) risks. Now NRDC has issued its own report and framework. An excerpt from the report:

The current approach to chemical regulation cannot be relied upon to prevent harm from nanomaterials; it is slow, costly, and fails to prevent exposures to known hazardous chemical pollutants.

True enough. But no approach could prevent all harm. The question is how to balance benefits and downsides. An excerpt about the NRDC framework:

In the face of government failure to take action, the new NRDC report proposes an immediate, three-part framework for regulating nanomaterials, based on already established precautionary approaches to managing toxic chemicals that are broadly agreed upon by environmental and worker protection groups:

• Prohibit the untested or unsafe use of nanomaterials. Because preliminary data demonstrates the potential for toxicity, unsafe or untested nanomaterials should not be used in a manner that may result in human exposures or environmental releases over the lifecycle of the material.
• Conduct full lifecycle environment, health, and safety impact assessments as a prerequisite to commercialization. Robust testing is urgently needed to identify potential risks early in development, across the lifecycle of the material. The results of testing should be made available to the public.
• Facilitate full and meaningful participation by the public and workers in nanotechnologies development and control; consider the social and ethical impacts of nanotechnologies. The potential of nanotechnologies to transform the global social, economic, and political landscape meanswe must move the decision-making out of corporate boardrooms and into the public realm.

It is useful to hear what the precautionary approach would recommend for nanoparticle safety, but for a framework to be implemented, it needs to build consensus beyond environmental and worker protection groups. Workers, for example, can take different views on issues when they are thinking about protecting their jobs.

We need a more inclusive approach. The Environmental Defense/DuPont effort asked for comments on a draft before issuing their framework; I don’t think NRDC did this. Can’t we work together? This is a hard problem and will require cooperation and probably compromise on both sides in order to get anything useful to happen. —Christine

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  1. jennifer sass May 17, 2007 at 7:30 pm - Reply

    NRDC did provide peer review of the EnvDef Dupont framework, and i am listed as a peer reviewer, with my NRDC affiliation, in the draft publicly released document.

  2. Christine Peterson May 21, 2007 at 2:21 pm - Reply

    Hi Jennifer — It’s good to hear that you commented on the draft ED/DuPont framework, but my question was about whether NRDC enabled others to comment on your draft framework. Thanks for engaging here, by the way! –Christine

  3. jen sass May 29, 2007 at 10:54 am - Reply

    Yes, the NRDC report was subjected to peer review prior to being released. In fact, the NRDC report had some of the same peer reviewers as the ED/DuPont framework, and many additional reviewers from the enviro and labor sectors.
    By the way, i don’t consider these to be competing frameworks. The ED/DuPont provided extremely detailed recommendations for data collection, and is specifically designed to identify workplace risks. Alternately, the NRDC report is a toxicology review and support for a precautionary regulatory framework for commercial materials.

  4. Christine Peterson May 29, 2007 at 5:37 pm - Reply

    Thanks, Jen, for that helpful clarification. —Christine

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