voluntary management of nano risks likely to fail
Posted December 6, 2007 in Health and the Environment
“With great power must also come great responsibility”, warned Spiderman’s uncle (Stan Lee, 1962). Nanotechnologies offer a great power, and obligates a great responsibility. It promises to revolutionize every sector of our economy, from things as important as cancer therapies, as exciting as elevators to space, and as mundane as stain-free neckties. Nanotechnologies are not new, but our ability to manipulate materials at the nano-scale so precisely is new, and ushers in a new wave of nano-enabled scientific advancements.
So, what is our government doing about this? Voluntary government programs are being implemented to encourage companies to submit health and safety information on their products, hopefully prior to commercialization. Nanowerk recently reported on a new article in the journal Nanotoxicology,where two scientists, Hansen and Tickner, analyzed a sample of the over 200 voluntary programs and identified the key elements in successful programs. The key lessons learned are: 1) Clear incentives to participate for various stakeholders (reduced costs, high publicity, agency guidance and technical assistance); 2) Signed commitments and periodical reporting; 3) Quality of information; 4) Transparency in design, reporting and evaluation (e.g. a clear baseline to measure development against; stakeholder involvement; public access to information to enhance their overall legitimacy); 5) Regulatory threat (threatening a harsher outcome, such as legislation, if a voluntary agreement is not reached).
Overall, the two scientists conclude that the three current voluntary programs on manufactured nanomaterials that they looked at have serious limitations and that the key lessons from past experiences have not been incorporated. This included the DuPont/Environmental Defense framework, the US EPA nano-scale materials stewardship program, and the proposal of the UK Department for Environment and Rural Affairs (Defra).
To paraphrase Donald Rumsfeld, the Secretary of Defense under President GW Bush, when questioned on the Iraq War: There are things we know we know, there are the things we know we do not know, and, there are the things we don't know we don't know. While the quote falls flat in the context it was used, to defend the US presence in Iraq based on mis-information about the existence of weapons of mass destruction, it applies very well to nanotechnologies. That is, we know that there is some evidence of hazard; we know that there are a lot of gaps in our knowledge about the characterization and safety-testing of these materials; but, the engineering manipulations that impart unique desirable physical properties at the nano-scale are also likely to impart unique and highly hazardous properties that we cannot predict at this time. So, the warning to Spiderman is a very relevant message to our scientists, our corporate leaders, and our federal regulators – take care, act responsibly, and limit or prevent human exposures and environmental releases of nanomaterials until we know that it can be done safely.
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Comments
Rory O'Neill — Dec 7 2007 01:31 AM
There are other reasons to be wary.
The obvious drawback is that even if voluntary agreements are well drafted, they only work for those that of their own volition adopt the standards, self-police and maintain interest overtime. Some, of course, maybe the majority, will opt out entirely...
The second, and for me more worrying consideration, is that voluntary agreements are really anything-but-regulation-and-enforcement agreements. Once you have them, the chances of getting proper regulation (and that means any prospect of meaningful enforcement by regulatory agencies) is greatly reduced.
And finally, a pick-and-mix proliferation of voluntary agreements means we get the betamax effect, the triumph of the worst option. This happened with the environmental standards produced by ISO, EMAS and BS. The latter two had much better monitoring, worker participation and reporting requirements, but ISO was preferred because employers (particularly US employers) saw ISO as the soft option.
This is why many of us are resisting voluntary agreements, even good ones. The good employers who would adopt and enforce good practice anyway, don't need volunteerism. The ones that see it as a soft alternative to regulation and enforcement, probably could do with a dose of both.
Yours, Rory
Rory O'Neill
Hazards www.hazards.org
Health, safety and environment officer, International Federation of Journalists
Professor, Occupational and Environmental Health Research Group, University of Stirling