Nanotech Environmental, Health, and Safety Roadmap

In 2006, several United States-based nanotechnology organizations, industry and trade groups, and nongovernmental organizations requested that the U.S. Congress commission the National Academy of Sciences (NAS) to develop a road map for research on the environment, health, and safety (EHS) risks of nanotechnology. In response to this request, Congress allocated $1.8+ million to the Environmental Protection Agency (EPA) to contract with the NAS to develop a strategy.

This allocation was included in the 2008 Omnibus Appropriations Bill, passed in December 2007. The report released by the National Research Council (NRC) in December 2008 was critical of the National Nanotechnology Initiative's (NNI's) approach to EHS research. The committee enumerated several aspects of what might constitute a research strategy and found the NNI deficient in many areas including vision, goals, and a plan of action. The NNI challenged many of the NRC charges. In January 2009, House Resolution 554, the National Nanotechnology Initiative Amendments Act required the NNI to follow the NRC's recommendations and develop a long-term plan for EHS research and devise a road map to implement the new strategy.

The call for a more comprehensive and transparent approach to EHS research were a long time in development. [Page 539]Several developments raised the question of whether EHS risks were being effectively assessed by the United States' NNI. A report from the Government Accountability Office (GAO) published a statement in 2008 that indicated that the NNI had overestimated federal spending in the 2006 fiscal year by about 18 percent.

While the NNI reported that federal agencies had spent a total of $37 million research the potential risks of nanotechnology, the GAO determined that 22 of 119 projects identified by the NNI had little to do with EHS risks. In fact, the GAO found that these studies (20 funded by NSF, 2 at NIOSH) were primarily concerned with environmental hazards unrelated to nanotechnology at all; funding for these projects totaled $6.5 million.

The Woodrow Wilson Center's Project on Emerging Nanotechnology's then pressed for a new oversight body to do technology assessments, forecasting, and monitor health and safety issues. Their conclusion was that existing agencies could not deal with the current nano application's safety concerns, let alone the potential flood of new nano products under development. Then in December, the NRC released the report that concluded that the NNI's strategic plan for EHS was inadequate. Both the 2008 and 2009 reauthorizations of the NNI have included requirements for tighter oversight of EHS research. The controversy surrounding nano and EHS research stems from a variety of problems, not least of which are the questions of jurisdiction over both EHS regulatory processes and the vexing problem of what counts as EHS-oriented research.

The NRC report attends to these concerns and draws conclusions based on its assessment of the NNI's own strategic planning documents. The NRC report first defines the elements of what it considers the elements of an effective strategy for EHS risk research, and then measures the NNI's 2008 Strategy document against these standards.

The elements included: vision, goals, evaluation of the state of current science, road map or plan of action, a series of evaluative categories. The NRC assessment found the NNI to be successfully managing the coordination of several agencies work but that the NNI was not providing the necessary vision to steer this work in the directions that would be needed over the next decade. The NRC report also pushed to the NNI to appoint a single organization or person to be held accountable for determining whether its research strategy was delivering on its promises.

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