The “precautionary principle” has become the proverbial giant elephant in the nano-living room. Leading advocates for the “responsible development” of nanotechnology acknowledge that nanomaterials may present serious health and environmental risks which remain poorly understood. Yet almost no-one is prepared to raise the question of whether a precautionary approach to managing these risks is warranted, let alone to advocate that such an approach is necessary.
In recent reports from The United Nations Environment Program, the Australian Government’s Nanotechnology Taskforce (now Nanotechnology Unit), the United States Environmental Protection Agency, the influential US NGO Environmental Defense Fund and their nano-risk framework partner DuPont, neither the “precautionary principle”, or a “precautionary approach”, rates a single mention. The Australian “Options for a National Nanotechnology Strategy” report, in an appendix at the end of the document, does list public support for a “precautionary approach” among feedback received to its call for public submissions.
Some commentators have suggested that “Precaution is for Europeans”. But despite adopting a precaution-based framework for new chemicals assessment (REACH), on nanotechnology the EU is not much better. In last year’s report by the EU Scientific Committee on Emerging and Newly Identified Health Risks the possible application of a “precautionary approach” is mentioned just once, on page 54: “In the absence of suitable hazard data a precautionary approach may need to be adopted for nanoparticles which are likely to be highly biopersistent in humans and/or in environmental species”. Hardly a clarion call for the precautionary principle to underpin the development of a technology predicted to literally reshape the world.
In essence, the precautionary principle states that where there is a risk of serious or irreversible harm, a lack of scientific certainty should not be used as a reason to postpone measures to prevent harm from occurring. Or as the old adage puts it, given early warning signs of serious danger, “better to be safe than sorry”.
In the context of nanotechnology, a narrow interpretation of the precautionary principle could see nanomaterials treated as new substances, and ingredients in the form of nanomaterials required to undergo a full safety assessment by the relevant scientific advisory body before they are permitted for use in commercial products (As per recommendations 10 and 12 (i) from the United Kingdom’s Royal Society and Royal Academy of Engineering report “Nanoscience and nanotechnologies: opportunities and uncertainties”). Hardly the stuff of revolution, although no government has yet lent its support to this “no new nano safety data, no new nano market” approach.
A more comprehensive application of the precautionary principle would see nanotechnology’s broader socio-economic and political implications considered and assessed alongside its toxicity risks.
Nanotechnology’s proponents suggest that it will “revolutionise” every sector of industry. The APEC Center for Technology Foresight notes that this will necessarily involve large-scale social upheaval: “If nanotechnology is going to revolutionise manufacturing, health care, energy supply, communications and probably defence, then it will transform labour and the workplace, the medical system, the transportation and power infrastructures and the military. None of these latter will be changed without significant social disruption.”
It doesn’t seem like a bad idea to critically assess the implications of nanotechnology-driven large-scale change and disruption. In fact, you could argue that we would be foolhardy and irresponsible not to ask the hard questions about nanotechnology’s broader societal impacts: whether nanotechnology is likely to bring net social gains or losses; who will receive the benefits, who will bear the costs; what the implications will be for equity, international security, personal privacy and quality of life; and how we might prepare to manage the impacts of this transformative new technology.
Finally, and perhaps most controversially, truly precautionary management would see those impacted by decision making about nanotechnology – that is, the public – involved in the decision making process regarding its development and introduction.
So why has “precaution” become such a dirty word? Why are we not having a robust debate about what degree of precaution is warranted in nanotechnology’s management, given the early evidence of toxicity risks and the predictions of large-scale social upheaval? Why is the precautionary principle not even mentioned, let alone explored, in some of the leading reports on risk management?
I’d suggest that there are 3 main reasons that the concept of “precaution” has been black-banned from the emerging dialogue about managing nanotechnology’s risks and challenges:
Money: The hype around nanotechnology has created a “gold rush” mentality. Governments and industry world-wide are convinced that establishing a competitive lead in nanotechnology development is crucial to their future economic performance. No-one wants to see the growth of their nano-industries slowed by a commitment to precautionary management (which would require putting the breaks on product commercialisation while the health, environment, social and ethical consequences are investigated and assessed).
Ideology: The rise of neo-conservative governments over the past decade, particularly in the English speaking world, has been associated with a push for small government and a backlash against measures to protect the environment and to promote social justice. Especially from the United States, there has been a world-wide push for unfettered “free” trade, where the mantra is to “let the market decide”. There is therein an ideological opposition to the precautionary principle, which suggests that human and environmental values should inform our development of new technologies, rather than the other way around. In this political context, the “p” word has become unmentionable.
Fear: Genetic engineering of food products resulted in a world-wide backlash which is still reverberating around the world. But despite nanotechnology going even further in its atomic-level manipulation of our food, its blurring of the boundaries between living and non-living materials, the toxicity risks that it introduces to human health and the environment, and its potential application to every sector of industry, to date it has attracted scant public attention. Government and industry hope to win the public’s hearts and minds on nanotechnology and to avoid a repeat of the controversy that greeted GE foods. Perversely, it appears that they are unwilling to acknowledge any need for a precautionary approach to nanotechnology’s management for fear of legitimising – as yet latent – public concerns.
So if these are some of the reasons for government and industry unwillingness to consider the precautionary principle in relation to managing nanotechnology, what’s stopping bodies such as the United Nations Environment Program or key environmental NGOs such as Environmental Defense talking critically about the role for precaution in responding to nanotechnology’s risks?
The precautionary principle was formally enshrined in the 1992 Rio Declaration on Environment and Development signed at the United Nations Conference on Environment and Development. Why does the United Nations Environment Program report not discuss the relevance of the precautionary principle in responding to nanotechnology – an issue it identifies as presenting key environmental challenges?
My guess is that in the hostile political and economic climate described above, many environmental bodies have jettisoned their support for the precautionary principle. Rather than advocating for a precautionary approach, many groups have surrendered to the neo-conservative concept that “evidence-based” risk assessment is the only legitimate way of responding to nanotechnology’s risks and challenges.
But environment groups accepting, and perpetuating, the idea that “evidence-based” risk assessment is the only appropriate way to manage nanotechnology’s risks and challenges presents two very serious problems:
1) Evidence-based risk assessment reverses the burden of proof – rather than proponents being required to demonstrate evidence of safety, others are required to demonstrate evidence of harm. The emerging field of nanotoxicology is young and public interest research remains grossly under funded comparative to commercial research. While there are hundreds, if not thousands, of nanoproducts on supermarket shelves, and preliminary studies demonstrate the potential for some nanomaterials to present serious risks, we’re still many years away from having the “evidence” necessary to undertake evidence-based risk assessment. In the meantime, workers, the public, and the environment, remain exposed to risks that may result in serious harm. These are circumstances for which the precautionary principle was designed.
2) Evidence-based risk assessment invalidates non-science based concerns. The public has a right to be concerned about the broader social implications of nanotechnology. Critical questions about nanotechnology’s purpose, predictability, ownership and responsibility should be asked – and answered – alongside questions of basic safety.
In 2001, the European Environment Agency published an excellent report “Late lessons from early warnings: the precautionary principle 1896-2000”. The report documents a litany of public and environmental health disasters that could have been avoided if greater attention had been paid to early warning signs of danger, including asbestos, benzene, PCBs and BSE (mad cow disease).
It would be wonderful if we could see a little more willingness on the part of all stakeholders in the nanotechnology debate – government, industry, academia and civil society – to investigate what lessons nanotechnology could learn from previous experiences of “wonder materials” that came at a high human and financial cost, and what role there should be for the precautionary principle in management of nanotechnology’s risks and challenges.