Monday, April 30, 2007

Berube in Maui

I am taking a few weeks off to spend with family and to snorkel in Maui. As the governor of California would say in closing, "I'll be back."

RE: Proceedings from the Nanotechnology and Security Workshop - RECOMMENDED IN PART

Mark Morrison, Proceedings from the Nanotechnology and Security Workshop, http://www.nanoforum.org/nf06~modul~showmore~folder~99999~scid~452~.html?action=longview_publication&, February 23, 2007.

There is so little on this subject this report rose to the top. It deals with a workshop in Roma involving a unit of DG Research and APRE (Agenzia per la Promozione della Ricera Europea).

It focuses on sensor technologies calling for "better access to existing materials and improved networking and integration of expertise and knowledge amongst EU organization" and the involvement of "social scientists in the design of new project to assure that potential ethics issues are taken into consideration from the outset" (p. 4).

Two sessions occurred and were reported.

The first was on technology. Arvind from Edinburgh discussed speckling computing or smart dust. Chaniotakis from Crete discussed biosensors. Cowburn from Imperial College discussing laser surface authentication which could potentially give each material a signature, or fingerprint, that is stored in a database" (p. 8) to track goods.

The second section addressed societal implications. Altmann from Dortmund warned US military funding is "4 to 10 times the rest of the world" and was "one quarter to one third of the annual USNNI budget" (p. 9). He presumably covered much of the same material that is in his book from small sensors to new biochemical weapons. Morrison incorrectly identifies Altmann as the only person with a book in the field. I offer Daniel Ratner and Mark Ratner as another Nanotechnology and Homeland Security New Weapons for New Wars (Prentice Hall 2003). Next Bruce from the Church of Scotland argues technology shapes society. Again I direct the reader to Neil Postman's Technopoly: The Surrender of Culture to Technology (Vintage, 1993). The last presentation was van den Hoven from Delft who discussed RFID tagging. "RFID tags are now being implanted in people and could be used to monitor individuals' movements and transmit personal data" (p. 10). Issues range from ubiquity to issues of proportionality and public perceptions of risk and carries the warning "that the applications of technologies for a specific purpose could have entirely different outcomes" (p. 13).

This a recommendation associated with "the need to discriminate between measured security and perceived security" (p. 13) which probably deserved more ink.

The material from Cowburn and van den Hoven are worth a read and they are very brief.

Sunday, April 29, 2007

RE: Nanosciences and Nanotechnologies: A Review of Government's (UK) Progress on its Policy Commitments - RECOMMENDED

Council for Science and Technology(UK) , Nanosciences and Nanotechnologies: A Review of Government's Progress on its Policy Commitments, London: CST, http://www2.cst.gov.uk/cst/news/Files/nano_review.pdf, March 2007.

This is a relatively quick and interesting read and offers many comments, both the USA and EU should take seriously about some of their own efforts in the field.

This report is the two-year review to the government's response to the 2004 Royal Society report.

The report concludes the UK may be falling behind in engaging this field, most nanotechnologies pose no new health and safety risks, the Defra voluntary reporting scheme is promising but must secure high industry participation to be successful and an insufficient amount of funds has been committed to EHS concerns.

On a meta-level, the report complains the UK functions "primarily a responsive mode of funding to fill the knowledge gaps" (p. 7) when it should use a "strategic research spending" program (p. 7).

In terms of toxicity, it calls for "short-term toxicity protocols" (p. 8) for nanomaterials "currently on the market and being used by industry" (p. 8). It noted "the risk of exposure to researchers or workers to be extremely low" (p. 31).

While supporting Defra's voluntary scheme it noted alternatives, "including a compulsory reporting scheme" (p. 9) should be considered especially since Defra's first quarter report records only two organizations have submitted data" (p. 27).

Finally it called for "more in depth dialogue processes" (p. 9) with the public.

Some specific items worth nothing include:
  • a call for more information on whether fixed nanomaterial may be free at some stage from wear and degrade during the life cycle (p. 11),
  • a concern for mislabeling products nano despite them not involving nanotechnologies (p. 12) and warned it could lead to a contagion effect across the industry though it admits the Magic Nano example "has had little effect of Germany's high investment, both public and private, into the development of nanotechnologies" (p. 12),
  • a call for some power to commission funding by the National Research Coordination Group (p. 15),
  • a call for instruments "to routinely monitor workplace exposure to free manufactured nanomaterials" (p. 15),
  • a call for "a minimum of a £5-6 million a year over the next 10 years to research the toxicology and health and environmental effects of nanomaterials" (p. 16) and that without adequate funding "our ability to engage in future international dialogue risks being compromised" (p. 17) and warned in "toxicology our understanding is little better than it was two years ago" (p. 23),
  • a call for the "[d]evelopment of methodologies for life cycle assessments" (p. 17) including a "government initiative to adapt LCA methodologies to products containing nanomaterials" (p. 20),
  • a conclusion that "the evidence that we have received does not suggest that there is serious reason to believe that nanotechnologies will cause global or irreversible effects that would justify the case for extreme actions such as a moratorium" (p. 18),
  • a call for government "to encourage industry to reduce or remove nanomaterials from waste streams" (p. 25) and applauds government for working "with industry to cause it to refrain any release for remediation until there is sufficient evidence that the benefits outweigh any adverse effects" (p. 25), and
  • a warning that public engagement "has been criticized for not having a major impact on policy" (p. 35) and recommended "industry to be significantly more involved in the public engagement process" (p. 35).

RE: (Australian) Options for a National Nanotechnology Strategy - RECOMMENDED

National Nanotechnology Strategy Taskforce (Australia), Options for a National Nanotechnology Strategy: Report to Minister Industry, Tourism and Resources, http://www.industry.gov.au/content/itrinternet/cmscontent.cfm?objectID=3E811562-B36F-F920-886795079F355734, June 2006.

While I do not think there is much new here, this report provides a glimpse into not only what Australia is confronting with nanotechnology (many of the same problems the EU and the USA are dealing with) but also offers a portrait of how other advanced nations are coming to terms with the supposedly nanotechnology revolution and its effects on national identity and economic competitiveness. I enjoyed reading this.

It begins with the assumption nano made "be as significant as the impact of electricity or the microchip" (p. 4). I am not so sure but I do like hyperbole. The report notes "Australian nanoscience talent... is relatively thinly spread" (p. 4). While observing "Australia is keen to participate in the nano-world" (p. 6), the report has a few recommendations:

  • the establishment of a dedicated office with a Federal Department (p. 6) and a general improvement in industrial awareness (p. 10) as part of a coordinated national strategy (p. 46),
  • new facilities complementing the characterization and fabrication facilities already identified by the NCRIS (National Collaborative Research Infrastructure) roadmap may be needed (p. 7) with greater consolidation of research capability maybe through one or more national centres of excellence (p. 8) modeled on the Australian Stem Cell Centre (p. 21),
  • specific funds should be made available to support Australian involvement in international HSE (health, safety and environment) studies (p. 7) as well as international co-operation in HSE (p. 7), esp. regarding chemical explosions, accidental spillages, and end-of-life-cycle issues (p. 26) and free radical formation (p. 27),
  • a national nanometrology program is recommended (p. 11) noting it as "a prerequisite for documenting standards and regulations" (p. 37) as well as a "cost-effective and robust ambient air monitoring systems for nanotubes, nanopowders, and quantum dots" (p. 27), and
  • a public awareness campaign like Biotechnology Australia's Public Awareness Program needs to be instituted (p. 7).
In addition, the report suggested "capture of rapid uptake technologies in areas of Australian scientific and/or industrial strength-- such as photonics, opto-electronics, biomedical, quantum -based technologies, as well as materials" (p. 20).

It also recommends "Green chemistry metrics need to be incorporated into nanotechnologies at the source" (p. 28).

It denies that a moratorium is needed (responding to FOE Australia's rhetoric) (pp. 29 & 32) though it suggests that industry "limit the use of engineered nanoparticles in environmental applications such as soil remediation" (p. 30) until cost-benefit research is done.

It notes "most Australians are interested in, feel positive towards, developments in science and technology" (p. 34) but "awareness of nanotechnology is low but increasing" and consumers are still forming their views" (p. 35).

The report added (p. 37) that "the Victorian Government is currently developing a communication program as part of its own state-based nanotechnology strategy" and I will follow-up on this.

The report also realized that "Australia will need 125,000 nanotechnology workers by 2015 in order a maintain a 1 percent share of the emerging industry" (p. 39) and recommended visa reform.

Finally, there is a nice inventory of facilities on pp. 42-46.

RE: NANOFRONTIERS: Visions for the Future of Nanotechnology - RECOMMENDED IN PART

Karen F. Schmidt, NANOFRONTIERS: Visions for the Future of Nanotechnology, PEN 6, Washington, DC: Project on Emerging Nanotechnologies, http://www.nanotechproject.org/114, March 2007.

Karen is a friend of mine and this is easily readable and she is reporting on an event so she was limited by what transpired. She is reporting on a NanoFrontiers workshop that transpired on February 9 and 10, 2006. The report and the workshop was crafted around the metaphor of a tool.

On p. 11, there is a call for probes to measure characteristics of nanoparticles that might be particularly problematic, such as surface reactivity. This is hardly a new call but it is unclear how well it has been heard by the funding agencies. Two pages lager, it is repeated when addressing EHS issues. On p. 14, the call for a "cadre of well-trained people to operate our tools" is mentioned though no solutions are forthcoming from this meeting.

The reports gets interesting on p. 15. There is a brief discussion of databases and nanoinformatics (nice word). The group recommends drawing "blueprints for the proverbial Nano Library." This included interconnecting databases and hopefully this would be international. On p. 18, there is a mention of Nano Library planning workshops and if anyone is listening, invite me.

There is a discussion beginning on p. 19 about three-dimensional nanostructures and a call to "move toward working in three dimensions" (p. 21). There is a brief mention of stochastic engineering which is defined as "designing nanosystems to function in spite of relatively high level of defects" (p. 22) which would seem necessary to produce these complex and adaptable 3-D structures.

Half of the way through the document, we get to CRITICAL APPLICATIONS. These are the same areas I spoke about in Zurich last year so I have to agree on the three selections though I would have chose a different ordering.

It starts with energy called a "gun to the head" issue referencing much of the same rhetoric used by Smalley and covers promises including "room-temperature supercondictivity" to "super-efficient wires"and even anticipates "artificial life forms that resembee simple bacteriaand then employ these creatures to produce fuel for human life" (p. 26) which sounds a bit like slavery to me. Of course, energy is a geo-political issue that does not follow demand-supply curves so I wouldn't bank on this, yet.

Next we get nanomedicine (a much better bet given necrophobia. There is nothing new here that cannot be gleaned from many of the nano-press services from Meridian Nano and Development News to Julia's service with the Woodrow Wilson Center. I was a bit how glibly the discussion on brain implants was presented without address the rich-poor gap and post-humanist concerns except for some left-handed referencing to a few paragraphs. I was also less than satisfied with the discussion on personalized medicine which while highly desirable would substantially reduce the pharmaceutical industry's profitability in the short-term at least since they would be less able to peddle cures that work on some people some of the time but are prescribed for almost everyone. The assumption that a doctor "might prescribe a cocktail" of say "10 percent of drug A, 50 percent of drug B, and 4o percent of drug C" (p. 34) seems to exaggerate a doctor's capacity.

Clean water seems a sure bet. From desalination to industrial and community based water purification to point of use technologies. Whether CNTs, iron, silver, magnesium oxide (p. 38), there is much promise here assuming we can get the technologies to the poor. I am less pleased with some of the assumptions behind pollution prevention and will have more to say about this in a later post. In terms of remediation, the field is flush with a lot of promises and no one has been able to resolve the end of the life cycle of nanomaterial byproducts.

Interesting group of interviewees and well written but a little weak on detail in some areas. On the other hand, it is slick and visually intriguing. I recommend the sections on the Nano-Library (pp. 15-18) and on Nanomedicine (pp. 29-36).

Monday, April 23, 2007

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.

RE: ETAG (European Technology Assessment Group), The Role of Nanotechnology in Chemical Substitution - RECOMMENDED

ETAG (European Technology Assessment Group), The Role of Nanotechnology in Chemical Substitution, STOA (Scientific Technological Options Assessment): ETAG, http://www.itas.fzk.de/eng/etag/project.htm, October 2006.

There are quite a few caveats to the report. For example, "[o]nly substances which are already known as toxic and dangerous to humans and the environment are considered" (p. v) and "...everything is considered as nanotechnology (NT) which is claimed by proponents to be nanotechnology" (p. v). Findings are placed in seven categories; coatings, flame retardants, flexibilizers, catalysts, and NT used to substitute or reduce solvents, NT used for remediation, and other examples. The report concluded "NT can not contribute in an exceptional manner to a large increase of substitution of hazardous substances (p. viii).

One of the primary problems with the concept of pollution prevention/chemical substitution is noted early in the report. "[A]pplications mostly exist only as ideas and concepts and have not even been proven in the laboratory" (p. 1). On p. 4, ETAG, like many others, argues a contagion effect. "[T]he outcome of the debate over NT can significantly influence the development of the technologies concerned" (p. 4) . In addition it relates the debate over NT "like the debate on nuclear energy, stem cell research or genetic engineering" (p. 4). Both of these assumptions are not necessarily true nor does the report spend any more time explicating them.

Some of the best evidence of substitution entails bifouling (nanostructuring of surfaces), alternatives to brominated flame retardants, alternatives to lead batteries, reducing the use of solvents, and reducing the used of insecticides by improving performance through the use of sensors. On p. 10, there is a hit list of substances from heavy metals to toxic organic pollutants which should be considered as worthy of substitutability research.

On pp. 15-16, there is a well worth reading review of self-cleaning surface technologies with specific examples. The review of silver particle-based coatings was rather superficials (p. 17) though the review of paints, sealants, and corrosion protection coatings (pp. 17-18) though brief is notable. The case on flame retardants (p. 20) is also notable.

The issue here is the environmental footprint of nanotechnology, read as nanoparticles at this time. While there may be a lot of promise, there isn't a lot of real experience. Once the remediation literature is set aside, there is very little to work from which makes risk studies on nanotechnology so problematic.

Thursday, April 5, 2007

RE: Environmental Defense - DuPont Nano Risk Framework - RECOMMENDED

Environmental Defense - DuPont Nano Risk Framework, February 26, 2007 - Draft - http://www.oecd.org/dataoecd/19/26/38173388.pdf

First, this project is in its draft stage, so I am sure it will improve. Terry and Scott are friends of mine and this was a lot of work. Generally, I applaud the effort though at times I found some of the material self-evident. Nonetheless, it was a major work on organizing and refiling concepts in a more user-friendly way.

Second, I have organized my recommendations and criticisms into two major categories.

Category 1 - Risk Communication. On p. 4, there is a claim that the Framework (F1.0) "can ... facilitate public acceptance." There is no reason to believe this is true at all. The assumption the public will react favorably to better packaged data and more data is simply not validated by experience or by social science research. On the other hand, if F1.0 is marketed as a public relations tool, then there is better likelihood of success though I doubt that was the intention of the authors. I sense public stakeholders would prefer not to be convinced nanoEHS has been addressed by industry and regulatory stakeholders on the basis of a term with assumed positive valence, such as "Nano Risk Framework." I am NOT suggesting the public does not want information, they just a not necessarily swayed by risk assessments based on a supply of scientific data, much of which is inconclusive and some of which is contradictory.

As I said recently at a DC briefing: "Leave risk communication to the specialists" because every time scientists and lawyers get involved they are convinced that communication of this nature is a secondary skill set which came with their advanced degrees. And they are WRONG. That's why we have crisis communication experts!

Category 2 - Mine fields.

There are a few, they include the following four: "worst case assumptions", CBI, consumer use and misuse, and waste management.

(A) worse case assumptions:

(1) Are we talking about "worst" or "worse"? "Worst" is relatively easy. "Worse" is not. The comparative concept is a judgment call and since participants in that decision making will come
of the process with their own motives (some of which are self-preserving). They include: actual or perceived self-interest, role definitions, role conflicts, actual or perceived threats to self-esteem, conflicts in value hierarchies, jurisdictional concerns, and perversity. These are the reasons we live in a world with evil and they will surface during the process of deciding why "worse" should not be "worst". There is a rich literature in scenario building the authors may need to examine for guidance here.

(2) "Worse" does not mean the data sets we build will address the issues at hand. Often exaggerated scenarios address phenomena that are not associated with the case instant. We could find ourselves learning a lot about nanoparticles which turn out to be irrelevant and since we live in a zero-sum EHS world (meaning there are limited researchers and resources), this becomes especially problematic.

(B) confidential business information (CBI) p. 65:

(1) This is a conundrum for risk management regulation and public risk communication. Much of the value in applied nanoscience has less to do with what is made and more to do with how it is made. The processes are patented and serve as the basis for much of the intellectual property of a company. As such, CBI will always be a feature of nanotechnology risk management and is the bugaboo of the process.

(2) The public assumes that industrial/business researchers are less trustworthy. In addition, they believe industry/business has research which is confidential. In many (if not most) occasions, they assume this research is negative in nature and being held confidentially to prevent regulation and public boycott. Finally, partial transparency may simply be more of a problem than outright opacity.

(C) consumer use and misuse: This concept surfaces when I was writing my book and I included a passage on off-terrain vehicles and how no one know they would end up on city streets so designers ignored the associated implications. Put simply, there is very little constraints when it comes of consumer misuse. Children huff cleaning products. Automobiles in demolition derbies. Toilet page rolls when no bong is available. You get it!

(D) waste management: This issue arose in the ICON "Best Practices" report in which some respondents referred their waste the third parties. What is this industry? Who are they? What are they doing? I can see an entire industry dedicated to dealing with the waste stream of the nanoworld that treat the waste like bulk waste when more care might be justified. F1.0 cannot allow the producers to assign responsibility for the end-state to a third party.

Down in an earlier blog, I complained about the entire concept of life cycle assessment and refer you to the post from April 2. (I am working on a much longer piece about this subject).

Tuesday, April 3, 2007

RE: Overview and Comparison of Conventional Treatment Technologies: Nano-Based Treatment Technologies - HIGHLY RECOMMENDED

Background Paper for the International Workshop on Nanotechnology, Water, and Development, Overview and Comparison of Conventional Treatment Technologies: Nano-Based Treatment Technologies, 10-12 October 2006, Chennai, India, Meridian Institute, http://www.merid.org/nano/watertechpaper, 2006.

People who have heard me speak know I am very interested in applications of nanotechnology to bring potable water to the developing world. Indeed, recent interest from the Bill and Melinda Gates Foundation indicates this may be a contemporary applications worth notice given the millions of children who suffer and die from water-borne parasitic and viral diseases. Their web site reports: In the developing world, severe diarrhea is a killer, taking the lives of between 2 million and 3 million children every year. Persistent cases of diarrhea cause malnutrition, retard growth, and delay mental development."

According to their web site (http://www.gatesfoundation.org/GlobalHealth/Pri_Diseases/ADI/default.htm):

"The foundation focuses support on efforts to:

  • Prevent acute diarrheal illnesses through the development of vaccines against their major causes
  • Develop drugs to stop life-threatening dehydration in children with infectious diarrhea
  • Increase knowledge of the causes of acute diarrheal illnesses to improve diagnostic tools and treatment
  • Discover new tools and strategies to treat severe diarrhea."
This publication is a brief and highly useful report and worth perusing. I recommend the comparative charts on pp. 33-35.

The report discussed applications for water treatment, esp. those associated with point of use (POU) in the three general classes: filters, membranes, and catalysts. In addition, the report covers nanoparticles for groundwater remediation. While much of this information is self-reported (from corporate public relations and marketing professionals), it still can be a useful guide to water treatment nanotechnologies.

It is particularly interesting to read this report with the understanding that when we are discussing water treatment, we seldom are comparing one method to another. Instead, there is a layering of technologies which can be used. For example, POU ceramic filters might be enhanced with colloidal silver supplementing a community based remediation technology.

Chapter 2 deals with Nanotechnology-Based Water Treatment Technologies. It begins with a review of carbon nanotube-based (CNT) membranes and Seldon Labs' nanomesh. In the category of nanofiltration, we get coverages of Saehan Industries' nanofiltration membranes, Argoinide's NanoCeram alumina nanofilters, and KX Industries' World Filters. In the category of nanoporous ceramics, clays, etc., we read about Porous Ceramic Shapes and MetaMateria's Cell-Pore, Nanovation AG's Nanopore (ceramic nanopowders on a support material), Pacific Northwest Lab's SAMMS (ceramic nanoscale pores with a monolayer on mesoporous supports), SolmetexX Inc.'s ArxenX (hydrous iron oxide nanoparticles on a polymer substrate), Cyclodextrin's polymer for POU and in situ groundwater treatment, and Pacific Northwest Lab's CNT nanocomposites (a thin film of an absorbent powder on a matrix of CNTs). The chapter also covers zeolites like AgION Technologies Inc.'s zeolite-silver compounds. In the category of nanocatalysts, we get a review (though superficial) of nanoscale zero valent iron, titanium dioxide photocatalysts, Adsorbia GTO's titanium oxide nanoparticle adsorbent, and Adedge Technologies, Inc.'s AD33 (nanostructured iron oxide metal for arsenic removal, and NanoMagentics, Ltd.'s MagnetoFerritin.

A short report well worth your time.

Monday, April 2, 2007

ON Proceedings of the Workshop on Nanotech and Life Cycle Assessment - RECOMMENDED

Proceedings of the Workshop on Nanotechnology and Life Cycle Assessment, Washington, DC 2-3 October 2006, http://cordis.europa.eu/nanotechnology, EC DG Research and WWIC, 20 March 2007.

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....
Actions from stakeholders included calls for government to set up "research frameworks and programs for the methodology development of LCA...", using results "to design adapted economic instruments" and "green purchasing." It calls (p. 12) for "an international LCI (life cycle impact) database" and "improved data coordination."

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.

ASSUMPTIONS

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.

The UNEP/SETAC Life-Cycle Initiative
Helias A. Udo de Haes
Journal of Industrial Ecology, Winter 2002, Vol. 6, No. 1, Pages 11-13.

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.