We mentioned earlier a request for comment on a proposed Nano Risk Framework for approaching nanotechnology materials safety organized by Environmental Defense and DuPont. Now a different group of organizations has come out against that framework. Their statement is titled “Civil Society-Labor Coalition Rejects Fundamentally Flawed DuPont-ED Proposed Framework“. An excerpt:

We reject outright the proposed voluntary framework as fundamentally flawed. We strongly object to any process in which broad public participation in government oversight of nanotech policy is usurped by industry and its allies. We made the decision not to engage in this process out of well-grounded concerns that our participation – even our skeptical participation – would be used to legitimize the proposed framework as a starting point or ending point for discussing nanotechnology policy, oversight and risk analysis. The history of other voluntary regulation proposals is bleak; voluntary regulations have often been used to delay or weaken rigorous regulation and should be seen as a tactic to delay needed regulation and forestall public involvement.

It may be true that “voluntary regulations have often been used to delay or weaken rigorous regulation,” but I would want to see more data on that. It seems to me that voluntary regulations may also often be the first step toward enforced safety standards. I’d want to see a study of this question before dismissing the ED-DuPont effort. It’s easy to put out a press release ridiculing other people’s work, but it would be more helpful for the ETC Group to present a substantive proposal of their own. —Christine