This is a synthesis document. I have a lot of problems with it and will itemize those below.
Rejeski in the preface writes "...the potential for transformational benefits with this technology may reach further than technologies in the past." This overclaim needs to be teased out and I hope to do that one day. I am more and more convinced nano with do what plastics has done though there is also a chance it will do what virtual reality did.
On p. 10 you can find the Executive Summary.
The report admits there is no general life cycle analysis (LCA) of nanomaterials but adds the ISO-framework for LCA is full suitable. I wonder how both these statements can be accurate.
The ISO 14040:2006 can be purchased from http://www.iso.org/iso/en/CatalogueDetailPage.CatalogueDetail?CSNUMBER=37456&ICS1=13&ICS2=20&ICS3=60 for CHF 96,00 or from the ANSI webstore (http://webstore.ansi.org/ansidocstore/product.asp?sku=ISO+14040%3A2006) for $82.00.
I will refrain from commenting on the ISO-framework since I have no intention of paying $82 for it. I have read two for the five published LCA studies of nanoparticles to date (p. 18) and will read the other three soon.
The rationale for my reservations is enhanced with operational issues including "lack of data and understand in certain areas" is admitted a bullet later and a bullet later the report admits "limits...to the assessment of toxicity impacts and of large-scale impacts."
Next we get a series of recommendations (p. 11). Under the concept heading of high uncertainty issues we get pronouncements including -
- Do not wait for near-perfect data.
- ...[S]tate relevant uncertainty.... and
- Avoid overselling the benefits....
It calls on academia to "set up databases for LCA case studies" and to "[c]arry out research in LCA methods."
From industry is calls for "co-funding research on developing LCA methods..., on toxic effects..., and social science research..." including the "sharing [of] confidential information.
From NGOs and consumer associations, it calls for "...[c]ommunicating LCA study results..." and "educating themselves..."
SOUNDS REASONABLE, but we need to look deeper before we jump onto the LCA bandwagon.
1. p. 13. "...[I]ndividuals might accept risks if the benefits of nanotechnology are clear." Not necessarily true. Indeed, we Kahan study discussed earlier.
2. p. 14 LCA and LCI are sold because they purport "to quantify from cradle-to-grave the relevant inputs and outputs of the product system." However the uncertainties we have about nanoparticles are significant and substantial and severely handicap this methodology at this time. While LCA makes a lot of sense, it is being oversold as much as any nanoproduct to date. On the next page, the report admits "emerging technologies are not conducive to full-spectrum LCA due to sufficient knowledge." Nonetheless, the participants call for "...an earlier adoption of LCA..." to animate "proactive action of different stakeholders..." to "...add supplementary environmental information." The assumption here is that more information will lead to better decisions but really fails to articulate that types of information those making the decisions really want and need.
3. p. 16. "LCA results can be used to inform the public of the potential benefits of nanproducts as well as of their potential environmental harm." I have a lot of problems with using a methodology of any kind as a marketing tool in persuasion. There have been many occasions in business where a focus group responded positively to a product that failed when it was launched in the marketplace. Exotic methodologies with positively enhance valences, such as LCA, have the additional caveat of serving to enhance the findings thought the method itself might be flawed and the public defers to the claim of methodological reliability as a false standard of validity. Most disturbing is the language on p. 16. For example, "LCA results can provide a sound basis for marketing nanoproducts as environmentally friendly." While life cycle thinking (p. 28) might be useful, there is little evidence it is an effective marketing strategy or that it should be and there are so few LCA studies of nanotechnologies (see p. 18; there are 5) that overclaims of this sort should be subject to the strictest scrutiny.
What LCA is purported to do is "...to establish a linkage between a system and potential impacts..."(p. 17) which makes this tool intrinsically rhetorical. They add: "The models used within LCIA (impact analysis) are often derived and simplified versions of more sophisticated models with each of the various impact categories." While I would like to add more at this point, I will wait until I have a chance to read the Steinfeldt, Harsch & Schuckert, and EPA (flat panel) LCA studies.
A few pages later (p. 20), there is a quizzical remark. "...LCA will probably primarily be used as a management tool, not to support go/no go decisions." While this remark is couched toward medical applications, it does force an issue to the surface. How will LCA/LCIA be used? And are the simplified versions of more sophisticated models trustworthy as indicators?
Next, we seems to have the issues of data estimation for which we have no approach. For example, the report (p. 20) admits "...release rates are not always available, especially when these are condition-dependent...", "...[p]roduction processes for nanomaterials are evolving much more rapidly" and there are "confidentiality restraints" imposed as CBI.
And we still do not understand what parameters are most likely to influence toxicity of nanomaterials. They report claims that UNEP/SETAC framework for toxic impacts "can, in principle be used for specific impacts caused by nanoparticles and nanoproducts..."(p. 24) though I will need to read Udo de Haes before adding much here though Figure 3.2 on p. 24 does not seem particularly insightful.
Here are some of the overwhelming issues that are not addresses in sufficient detail in this report.
1. What level of precaution (p. 26) is called for given the lack of information needed to perform a LCIA for nanoparticles? The entire debate over precaution has not been resolved and the literature remain incredibly polarized.
2. When do we used worse case scenario (p. 25) in making LCA? Is there some threshold of probability associated with the scenario that makes it use fictive rather than factive?
3. We know LCA is a "time-consuming and costly exercise"(p. 26). How wise is this investment at this time given other needs both associated with nanomaterial health and safety and not so associated?
4. How does LCA/LCIA accommodate CBI? When so much in nanoproduction is associated with process rather than product, we need to resolve this debate if we make claims including: "It is likely that manufacturers have conducted additional assessments but retained the results for in-house used only" (p. 17).
5. While the report calls upon experts to "meet/convene and decide what is relevant for the LCA of specific nanoproducts, e.g., what are the hotspots, the main indicators to be used, allocation and cut-off rules, data-gap, uncertainty and sensitivity analyses" (p. 30), we must ask ourselves whether consensus is possible and who will pay the costs associated with this process (right now, ICON seems to be doing some of this). In addition, we are kicked back up to #3 above since we must ask ourselves whether this is a wise investment at this time.
While these proceedings are not the beginning and end of the debate over LCA, it is a start. I warn my readers to be highly critical of some of the claims made in this report and be very skeptical about the marketing attributed of this model.