Policing Regulation

Normally anything that leads with a paragraph about nanotechnology being the next industrial revolution goes straight in the bin, firstly as it clearly is not and secondly because it is a phrase that has been over used for the past decade with little justification ( although if you bought Drexler’s original vision of nanotechnology then it may have rung true until you started to look at the practical scientific and engineering issues).

We let it through this time as it was a component of a more interesting report, in which the Woodrow Wilson project was calling for the Environmental Protection Agency in the United States to create “an adequate oversight system is necessary to identify and minimize any adverse effects of nano and products on health or the environment.”

The key recommendations looked a little more like a shopping list, viz,

* EPA should launch its proposed voluntary program to collect nanotechnology risk information and should begin immediately to revise the Toxic Substances Control Act (TSCA) to better deal with nanotechnology.

* EPA and industry should create a joint research institute to conduct scientific research on nanotechnology effects.

* EPA should set up and lead an interagency regulatory coordinating group for nanotechnology oversight.

* Congress should establish a temporary committee in each house to consider options for a nanotechnology oversight mechanism.

* Congress should provide an additional $50 million each year for research on the health and environmental effects of nanotechnology products and processes.

While it is always reassuring to see agencies setting up yet more committees and task forces to look at the effects of nanomaterials, it is no good setting standards if they cannot be enforced, and at present, we just don’t have the instrumentation to do this.

A typical example is the detection of nanoparticles in the environment. While they may exist for milliseconds or even minutes, by the time they have agglomerated into clumps tens of microns in size, how can you detect whether they were free nanoparticles with any ability to cause harm? Unless someone happened to be waving a TEM grid around at the exact moment of their release, you would never know.

A further problem is globalisation making it easier to push production of high value materials to countries where there just isn’t the public and legislative pressure to ensure that minimum safety standards are met. In some of those countries, making a fast buck will take precedence over quality of life for the workers, so that is why we end up with ships being broken up by hand in Bangladesh, children stitching footballs in Pakistan and all kinds of horrific sweatshops across SE Asia. As the health and safety issues cannot be policed in some countries as it can in the west, combined with endemic corruption in some areas, then the possibility of accidents and contamination there is proportionately higher.

The final problem is that we do not really have much information to indicate whether nanomaterials are harmful or not, and we probably won’t until governments stop forming task forces, drawing up guidelines, and start funding some proper toxicology studies. While UK Science Minister Malcolm Wicks was reported to be incandescent with rage about the UK Council for Science and Technology report accusing the government of inaction on the issue, his time would be better spent finding a budget for the requires studies than looking for scapegoats (in this case it was the entire UK scientific community).

While nanotoxicology is a worthy bandwagon to try to clamber aboard, some decent methodologies for assessing toxicity and some decent instrumentation for detecting nanoparticles should be a starting point, and only then can we look at more regulations.

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