RE: An Open Letter to the International Nanotechnology Community at Large - RECOMMENDED WITH MISGIVINGS

An Open Letter to the International Nanotechnology Community at Large, Civil Society-Labor Coalition Rejects Fundamental Flawed DuPont-ED Proposed Framework, http://groups.google.com/group/emergingtechnologies/msg/f3e58aa23071e9b1, April 12, 2007.

I recommend this letter because it is an important voice in the debate though I disagree with much of it. Also note, I am speaking for myself and as a critic and not for any group, organization, or entity.

First I begin with a disclaimer. Medley and Walsh are friends and in my interaction with them I have no reason to believe they are shills or barkers for the "dark side". In addition, anyone who knows me knows that I seldom play the friend card. I say what's on my mind (one of the luxuries of being a full professor with life tenure). It was the absence of civility from this "civil" society coalition which bothered me. This framework, for me, brought together a process that is worth testing and I am willing to discuss this given the dearth of much else at this time.

Second, I read the entire "framework" from cover to cover twice and I am wondering whether anyone from the AFL-CIO through the United Steelworkers of America can make the same claim. I wish each of the signatories had actually included the name of the person who is willing to stand behind the claims being made.

I found the lack of any specific indictment beyond the assumption that it will substitute for hard fisted regulation unsettling and began to question the perceived self-interest at work here especially when this blog has spent time and effort vetting works from a handful of the submitted members in this coalition and in many cases their works have been second class.

Third, (see earlier blog) I have some problems with the "proposed framework" but I can still appreciate the intent here. To claim it "is, at best, a public relations campaign" is simply unfair especially when the same case can be made of the civil society-labor coalition who needs the public and its contributing members to see them as an alternative to other groups. One of the fundamental characteristics of a movement is it definitional opposition to a power structure of some sort.

Here are the two issues I have with the open letter.

1. This "framework" was not a substitute for regulation. It was never claimed to be a substitute for regulation and this coalition might find more profitable efforts directed toward regulators both in the USA and abroad who seem to have already committed themselves to a voluntary approach. In their defense, the current voluntary approach advocated by regulators is couched in rhetoric that does not exclude more heavily fisted regulation either at the same time or later down the road.

While an argument can be made the voluntariness might preclude stringent regulation that argument is not being made in the open letter beyond rhetorical flourishes. I would enjoy if we could elevate this debate by finding a voluntary government regulation which delayed or forestalled more formalized regulations which in turn resulted in some impact.

Please understand that how this debate is resolved in no way detracts from the "proposed framework" simply because it is not mutually exclusive from the more formalized regulatory approach.

2. Deciding not to play is not working. The letter includes a statement of dissociation lest their participation "would be used the legitimize the framework as a starting point or ending point for discussing nanotechnology policy."

While it makes sense not to suggest the proposed framework is an "ending point", it makes much less sense to be concerned about it as a "starting point" especially when it would not preclude more points along the line.

I have studied movements and organization for some time now and it might behoove this coalition to offer an alternative into the debate especially under these circumstances when the framework was released in a bona fide gesture of transparency.

If you are a legitimate civil society, you need to act civilly and civic-ly and engage this debate offering criticisms of specifics and offering rationales and counsel. I am not suggesting that you abdicate your principles or moral codes. I am only suggesting that if the public sphere is to be served, then a civil society functions best with tactics beyond spurn.

We can do better and nanoparticles are entering the market so we have precious little time to produce a productive discourse on health and safety. Considering some of the research to date on environmental remediation, water purification, human cancer treatments, etc., we may not have the ethical luxury to opt for rejection as a strategy. We serve to respect "worker safety, people's health and environmental protection" best by advancing an approach that warrants respect, civil and civic engagement.