Tuesday, July 25, 2006

On NANO: RESEARCH STRATEGY FOR ADDRESSING RISK

Andrew Maynard, NANOTECHNOLOGY: A RESEARCH STRATEGY FOR ASSESSING RISK, DC: Woodrow Wilson PEN, July 2006 - RECOMMENDED WITH RESERVATIONS.

Mixed review - Andrew Maynard does some good work here but there seems to be overreach in some places.

"Research lacks strategic direction." This sentence from the foreword encapsulates the entire report.

This has been the case in all of science throughout the history of science. The problem has been to decide who should establish the directions for research.

Indeed, a very strong case has been made that researchers competing against one another for grants and honors often produces that crucible of learning where irrelevancies are burnt away and what is left has value.

In addition, while it might behoove us to focus on areas of research deemed most important first that usually depends on whether we have the researchers in the field willing to undertake the assignments.

Finally, we should not lull ourselves into complacency that medium- and long-term implications are less important.

(p. 3) - "...[P]ublic confidence in these emerging applications is in danger of being undermined." Let's not oversimplify this issue. It will take a lot more than toxicology and exposure studies to protect and sustain public confidence.

(p. 5) - "...risk research should be carried out...." It might also be important to keep in mind that industry is doing a lot of research and acquiring their findings should be a priority as well. We might be able to build into our current regulatory strategies ways to encourage sharing of information for some preferential treatment by government. Elsewhere, I have made the same argument but from the insurance industry's perspective.

(p. 6). - "...an independent study effort." This would seem to suggest strategic partnerships with the IRGC at this time.

(p. 8). - "...only one percent of the billions of follars the U.S. federal government has invested...." While I don't doubt that more investment is needed, I am uncomfortable with this percentage given that the author admits he did not have access to all the data.

(p. 13). - "Do we really want a situation where the de facto approach to health and safety of nanotechnology is "put the products on the market first and answer questions later?" - This is an oversimplification. First, some products will have low exposure values so sure. Second, this concept demands a grander decision on how much precaution should be built into our regulatory policies and that issue has not been sufficiently addressed.

(p. 16). - "The NNI lacks the authority to compel greater investments in risk-related research." True, but that does not mean it cannot influence the process. I am not sure an overlord over research is such a good idea since redundancy in research can be a strong corrective and for reasons mentioned above.

(p. 21 back to 19). - Figure 3 logic. Trying to link safety research to products on the market ignores the exposure variable and seems inconsitent with some earlier concerns over exposure research though I appreciate the interest in life cycle studies.

(p. 21). - ..."no projects are specifically addressing the potential effects of nanomaterials in the gastrointestinal tract..." This is a very interesting observation and we discovered the same when reviewing the ICON database, but there are additional variable at work here such as researcher interests, etc.

(p. 24). - "Althought identifying research priorites 10 years out in somewhat speculative, it is an exercise that helps focus on immediate needs." This is a noble task though it is often difficult to control the breadth of speculation. Counterfactuals in logic have demonstrated this repeatedly as has the entire field of abduction.

My concern is we need to bracket research. We need to spend the bulk of our research money on immediate and short-term goals but to quote a colleague of mind, to preclude being "upstream without a paddle" once again, we may need to address goals further down the development pipeline.

We know, as a rule and it should occur in nanoscience as well, that developments in many ways build on each other and accelerate, so we may have less of a window of opportunity on studying the implications of more advanced applications.

I want to comment of the Health Effects Institute as a model for the Nanotechnology Effects Institute, but I will need to do more research.

Now to the good stuff.

Yes, we need exposure research and we probably need some effort to research toxicity issues with emphasis on high exposure populations and those with highest sensitivity.

Yes, we need work in infomatics - concatenation of information of this sort will be time consuming and expensive.

Yes, we should link research to oversight.

Most importantly, yes, we need more research money in EHS research but more money does not necessarily generate better research nor does it guarantee public confidence per se.

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