Last year I was invited to speak at the International Council on Nanotechnology’s conference in Tokyo. My presentation, ”The social, environmental and political impacts of nanotechnology” made three key points: 1) existing evidence of nanotoxicity requires us to take a precautionary approach to risk management – we should not expect workers, the public and the environment to continue facing unregulated exposure to nanomaterials; 2) we must look beyond the question of toxicity risk management to ask critical questions about nanotechnology’s purpose, predictability, ownership and responsibility (who bears the risks, who stands to gain?); and 3) given the scale of nanotechnology’s predicted impacts, we must involve the public in decision making about its introduction.
The International Council on Nanotechnology is a collaborative network between industry, government, academics and NGOs working on nanotoxicity issues. ICON’s mission is “to develop and communicate information regarding potential environmental and health risks of nanotechnology, thereby fostering risk reduction while maximizing societal benefit”. A key focus of the recent workshop in Tokyo was the need to improve safety for workers handling nanomaterials. My presentation argued for precautionary management of nanotechnology’s risks, for consideration of nanotechnology’s broader societal implications and for public involvement in nanotechnology decision making.
Report
The 2-day Asian Workshop on International Collaboration on Nanotechnology Environmental Health & Safety took place between 30.11 and 01.12.06. The conference was attended by around 80 invited participants, mainly from the USA and Japan, with a smaller number from other Asian countries, 3 from Europe and 3 from Australia. Participants mainly represented industry, government and academia. I was the only NGO speaker in the 2 day conference, and one of only 7 NGO participants amongst the 80 people in attendance. Although the key focus of the conference was on workplace exposure and safety issues, no labour representatives attended. There was much critical discussion about this, with the organisers committing to involve these key participants in ICON’s future work.
[Correction: The original copy of this report stated incorrectly that no occupational hygienists or workplace safety experts attended the conference. However at least one occupational hygienist was present. Additionally, many of the academics that attended and presented are focussed on researching the health impacts of nanomaterial exposure for workers. The point I was trying to make was that most people in attendance were from the research or business communities, or government, rather than people whose work brings them into close contact with workers who may face exposure to nanomaterials or other hazardous substances. These people may have a better understanding of the practical challenges of establishing safe workplace practice.]
The reception to my presentation was surprisingly warm (or at least lukewarm) – several of the participants asked interested questions or approached me afterwards to express their support for the ideas raised. They seemed genuinely interested in discussions about the broader social issues that nanotechnology raises, and cognisant of the trouble associated with a military-driven nanotechnology research budget. Some appeared challenged by the suggestion that we should look critically at the assumptions that underpin the mainstream nanotechnology debate (nanotechnology will necessarily bring net benefits, research into toxicity risks = “responsible nanotechnology”, management of nanotechnology should be restricted to science-based risk assessment).
The conference had two principal objectives. The first objective was to share information about nanotechnology research and environment, health and safety initiatives being undertaken by ICON and within the Asia-Pacific. This provided an interesting snapshot of research and policy work being undertaken in the region; copies of all speakers’ presentations are available at the ICON website. The second objective involved seeking the participants’ feedback to questions on how to improve the safety of workers exposed to nanomaterials.
The following two questions were asked: 1) what existing forums or mechanisms are in place to develop and improve best practices for safe nanomaterial handling [in the workplace]; and 2) what efforts should be undertaken to accelerate the development of globally adopted best practices [for safe nanomaterial handling in the workplace]? These questions were discussed in breakout groups by conference participants and then by the conference as a whole on the last day. A short list of recommendations will be considered by the ICON Steering Committee, who will then decide what action to take on them. The outcome will be published on the ICON website.
Key suggestions in response to the 2nd question included:
• Classifying nanomaterials as new chemicals (which would trigger new safety assessment requirements under existing regulation); and
• Seeking greater involvement of labour organisations and occupational hygienists (given that they represent or work most closely with people facing immediate occupational exposure to nanomaterials).
However, perhaps unsurprisingly, my suggestion that we support a moratorium on workplace handling of nanomaterials until such time as we either establish the safety of nanomaterials, or implement regulations to manage risks of occupational exposure, didn’t make it through to the short list for ICON’s consideration.
ICON has been a key advocate for more nanotoxicological research to be conducted as the nanotechnology industry grows. And certainly the organisation and its members wish to identify and promote emerging best practice in nanomaterials handling. But I couldn’t help feeling that the majority of this conference of industry, government and academic representatives were not very interested in a serious discussion about whether or not the precautionary principle should be taken into account in the management of nanotechnology. There appears to be little support for ensuring that best practice does in fact protect workers from unsafe nano-exposure prior to the commercialisation of further nanoproducts, or for insisting on government regulations to protect the health of workers, the public and the environment. This is very disappointing given the explicit calls for precautionary management of nanotechnology made by the world’s oldest scientific institution, the United Kingdom’s Royal Society, in its 2004 report:
• We recommend that ingredients in the form of nanoparticles undergo a full safety assessment by the relevant scientific advisory body before they are permitted for use in products. (Section 8.3.3: paragraph 24 & 23)
• We recommend that manufacturers publish details of the methodologies they have used in assessing the safety of their products containing nanoparticles that demonstrate how they have taken account that properties of nanoparticles may be different from larger forms. (Section 8.3.3: paragraph 25)
• Until more is known about environmental impacts of nanoparticles and nanotubes, we recommend that the release of manufactured nanoparticles and nanotubes into the environment be avoided as far as possible. (Section 5.7: paragraph 63). Specifically, in relation to two main sources of current and potential releases of free nanoparticles and nanotubes to the environment, we recommend:
a) that factories and research laboratories treat manufactured nanoparticles and nanotubes as if they were hazardous, and seek to reduce or remove them from waste streams. (Section 5.4: paragraph 41)
b) that the use of free (that is, not fixed in a matrix) manufactured nanoparticles in environmental applications such as remediation be prohibited until appropriate research has been undertaken and it can be demonstrated that the potential benefits outweigh the potential risks. (Section 5.4: paragraph 44)
The “International Council on Nanotechnology (ICON): a partnership for stewardship and sustainability” is an interesting organisation. It is an admirable attempt to form an international collaborative network between industry, government, academics and NGOs working on nanotoxicity issues. However my attendance at the Tokyo meeting made me think that ICON has over-reached, and suffers from some systemic internal conflicts.
Although it calls itself an “International Council”, ICON has no representative status. Despite efforts to conduct international outreach (for example by holding the Asian Workshop in Tokyo), its membership remains heavily dominated by the United States, where it is based at Rice University. Its name may lead you to think that it is concerned with “stewardship” of the industry as whole (for example in looking at broader societal implications, equity issues, research priorities etc). However, its mission statement: “to develop and communicate information regarding potential environmental and health risks of nanotechnology, thereby fostering risk reduction while maximizing societal benefit” restricts it to dealing with nanotoxicity issues, while arguably also promoting industry expansion.
And there-in lies one of the key limitations on ICON’s effectiveness as a body committed to fostering risk reduction – it is also inherently committed to furthering the industry’s expansion. Judging from the presentations at the Tokyo meeting, promoting the expansion of the nanotechnology industry is an over-arching priority of many of its members. The problem is that at this stage of the industry’s development, with enough nanotoxicological evidence to know that nanomaterials introduce new toxicity risks, but not enough information to manage these risks, promoting industry expansion is arguably antithetical to fostering risk reduction.
A key contributing factor in this central predicament of ICON’s is its membership. Industry is committed to promoting nanotechnology commercialisation (it’s their core business), governments are (largely) committed to nanotechnology commercialisation (they’re convinced they must promote early industry expansion or fall behind in the global race), academics are (largely) committed to nanotechnology commercialisation (they’re either excited by nanotechnology’s scientific potential, convinced by the “nanotechnology is progress” argument, or beholden to the nanotechnology industry for ever scarcer research funds and so unwilling to rock the boat). That leaves the NGOs to be the nay-saying critics – and as the partner with the least capacity to make a significant financial contribution to ICON’s operations; although their participation is critical to ICON’s legitimacy as a collaborative network, NGOs will inevitably have the least influence on its direction.
So, given its context and membership, can an organisation such as ICON take the steps necessary to fully and critically question what is necessary to “foster risk reduction and maximis[e] societal benefit” in relation to nanotechnology? What if the answer is to halt the commercialisation of nanoproducts and to use our scarce public funding for research in another area?
I come back to the three key points made in my presentation: 1) existing evidence of nanotoxicity requires us to take a precautionary approach to risk management – we should not expect workers, the public and the environment to continue facing unregulated exposure to nanomaterials; 2) we must look beyond the question of toxicity risk management to ask critical questions about nanotechnology’s purpose, predictability, ownership and responsibility (who bears the risks, who stands to gain?); and 3) given the scale of nanotechnology’s predicted impacts, we must involve the public in decision making about its introduction. Responding to these key issues is an urgent challenge that the scientific community as a whole must be prepared to face.
Acknowledgement: I am grateful to ICON for a travel disbursement that included my travel, registration and accommodation costs.
For further information contact Georgia Miller georgia.miller@foe.org.au
