ON Greenwood - Thinking Big About Things Small - NOT RECOMMENDED

Mark Greenwood, Thinking Big About Things Small: Creating an Effective Oversight System for Nanotechnology, PEN 7 , March 2007, http://www.nanotechproject.org/110/31407-thinking-big-about-things-small - NOT RECOMMENDED.

This is the latest PEW report on nanotechnology and it adds very little to the discussion.

The only three points that surface in this report (not a study) and worthy of more discussion are:

(1) Will the efforts to secure nanosafety of products become prohibitively expensive leading to startups selling out to large corporations or shift the locus of nano-development to large transnationals with the wherewithal to produce the information needed for the marketing of nanoproducts? "...[I]nformation requirements and associated testing may ultimately determine what products will be viable and what businesses will succeed" (p. 5). I am interested the existences of "a tipping point at which it is no longer feasible for small companies to bear the costs of the oversight system" (p. 22) and this subject could be very important and deserves greater analysis.

(2) Will high risk applications become so problematic that there will be orphan applications that will need to be undertaken by government since the commercial world will find those applications simply unprofitable (p. 23)?

(3) Will labeling notify the public that a nanomaterial is in the product or is the "nano" label nothing more than an implied hazard warning?

I am particularly concerned about the following (here are my top 5):

(1) The footnotes 2 and 3 (p. 8) where a Device and Diagnostic Report (self-reported as a report; I won't pay $200 for it) and the PEW Directory of products are referred to as a study when at best they are loose inventories. There is a call for transparency aping a report over 15 years old (p. 29) after detailing a page earlier how confidential business information makes transparency highly problematic.

(2) Too many rhetorical flourishes appear in the report, such as "What is missing is a public discussion of these positions" (p. 9) with no recommendation. There are calls for faster toxicity testing and screening methods, calibration of information needs, etc. (p. 21), release into aquatic environments stripping existing regulatory designs (p. 26), reliable and credible monitoring protocols (p. 26), etc. with no recommendations as well.

(3) The utility of analogies (read as analogues) to "spur additional testing" (p. 22) seems risky. The GMO analogue and the TRI (Toxic Release Inventory) analogy (p. 27) have and will contribute very little to the debate since GMOs is a rhetorically powerful but ungrounded analogy and the TRI analogy deals with known toxic chemical risks and too much is unknown about nanoparticles.

(4) There are quite a few assumptions, such as small firms who do NOT have highly developed stewardship programs "are much more likely to step forward to participate in a discussion..." (p. 9) without any rationale whatsoever and there are quite a few grand statements, such as "...it will be important that stakeholders identify the kinds of decisions they will to be able to make" (p. 29).... for what end and too what end??? [I discussed this in greater detail in a chapter for a Wiley collection edited by A. Lin coming out later this year].

(5) References to "structure activity relationships" with a call "to develop a SAR approach for the more prevalent nanostructures of date" (p. 16) is exactly what the RNAD (Research Needs Assessment) effort by ICON is all about but there is no discussion of the Bethesda meeting in December or the upcoming one in Zurich in the summer.