The Nano Risk Framework

According to Environmental Defense – a national organization funded to conduct environmental research and aid in developing environmental policy – the possible hazards of nanotechnology are only magnified by the tiny amount of research that has been conducted to assess these hazards.

“The few data now available give cause for concern: Some nanomaterials appear to have the potential to damage skin, brain, and lung tissue, to be mobile or persistent in the environment, or to kill microorganisms (potentially including ones that constitute the base of the food web),” according to Environmental Defense.

The organization calls for the direct partnership between industry leaders in nanotechnology and public advocacy groups to aid in developing comprehensive strategies to maximize the benefits of nanotechnology while minimizing the risks.

In June of 2007, a major step forward was made in this aim with the partnership of Environmental Defense and DuPont. Building off of a co-authored article published in the Wall Street Journal in 2005, DuPont and Environmental Defense executives published a “Nano Risk Framework”: a “proposal for a comprehensive, practical, and flexible Nano Risk Framework – a systematic and disciplined process – to evaluate and address the potential risks of nanoscale materials.”

The proposal was not binding; nor did it establish any legislation regarding nanotechnology policy. Rather, it was a demonstration of what two organizations with seemingly opposing goals could agree upon and accomplish, according to Nigel Cameron, director of the Institute of Nanotechnology and Society at Chicago’s Kent College..

“Both organizations are still worried about what the federal government is going to think about it,” he said. “But, if it were me, if Environmental Defense and DuPont can agree on something, I’d just sign the check.”

The resulting proposal suggested a six-step process for bringing any nanomaterial to market: first, the material must be scientifically described and characterized; second, the material’s entire life-cycle must be analyzed and its reactivity with any other materials must be stated; third, the risks of these possible interactions must be evaluated; fourth, risk management procedures must be developed and assessed; fifth, a course of action must be decided upon and documented; and sixth, an evaluation procedure must be implemented for some point in the future.

According to the framework, its most effective application as a tool for policy would be in a setting in which its execution would be ensured – such as under federal law.

Yet, the 2003 Nano Act is the only federal legislation dealing directly with the matter of nanotechnology’s environmental, social and ethical impacts. And, according to the act, all that is required of any federally funded nanotechnology research and development project is that it includes “activities that address societal, ethical, and environmental concerns.”

The nature of these activities remains implicit, and it is not designed to be quantitatively assessed.