(Nanowerk Spotlight) For traditionalists it certainly is jolly good, absolutely spiffing, actually, to be able to open a report on leading edge 21st century nanotechnology and be confronted with a preamble that contains these phrases right out of the 19th century: "Twenty-seventh Report To the Queen's Most Excellent Majesty. May it please Your Majesty. Presented to Parliament by Command of Her Majesty. Humbly submitted to Your Majesty." But then it gets decidedly strange when this is followed by a quote from Alice's Adventures in Wonderland: "...for I was never so small as this before, never!" How cool, sorry, bloody marvellous – does this mean that MI6 has now added nanobots to James Bond's gadgetry?
Unfortunately it's not quite as exciting as that. Of course we are referring to the recently released report from the UK's Royal Commission on Environmental Pollution (RCEP) entitled "Novel Materials in the Environment: The case of nanotechnology" (pdf download, 4.6 MB). And just to include another time warp moment, the report's cover, underneath the title "Novel materials in the environment", shows a picture of the 2,400 year old Lycurgus cup (the Lycurgus cup, when illuminated from outside, appears green. However, when Illuminated from within, it glows red. The glass contains gold and silver nanoparticles which give it these unusual optical properties. The underlying physical phenomenon for this is called surface-plasmon excitation.)
The report was prompted by concerns about potential releases to the environment from industrial applications of metals and minerals that have not previously been widely used. As the majority of the evidence RCEP received was almost entirely focused on manufactured nanomaterials, the Commission decided to focus on this sector in its report. The document examines issues related to innovation in the materials sector and the challenges and benefits arising from the introduction of novel materials, specifically nanomaterials.
Although the Commission clearly states that it found no evidence of harm to health or the environment from nanomaterials, it believes that the pace at which such new nanomaterials are being developed and marketed is beyond the capacity of existing testing and regulatory arrangements to control the potential environmental impacts adequately.
Schematic representation of the gap between the emergence of products containing nanomaterials in comparison to the generation of environmental health and safety data (EHS) and their subsequent use by regulatory agencies. The diagram is purely qualitative. (Source: "Novel Materials in the Environment: The case of nanotechnology", p.30)
A major conclusion of the report is that nanomaterials are hugely variable in their nature. They are not a uniform class of materials, and attempts to regulate or legislate solely on the basis of their size (1-100 nm in one or more dimensions) or how they are made are misguided. It is the functionality of nanomaterials, i.e. what they do and how they behave, that matters and this should form the basis of governance and regulation:
"We have argued that the issue with all materials is their functionality. It is not the fact that they are created by any particular technology that is important, or even, in the case of nanomaterials, that they are of a particular size. What matters is what they do, and the implications of their properties and functionalities for environmental protection and human health. There is no logical reason why size of particle should in itself provide the basis for new regulatory controls."
Although they conclude that they have seen "no convincing evidence of the need for a special regulatory regime for nanomaterials", RCEP writes that they identified three areas of particular concern regarding governance and regulation of nanomaterials:
1) The first is profound ignorance and uncertainty about the behavior of some types of nanomaterial in the environment or the risks that they pose for human health.
2) The nanoform of an element or material may have significantly different properties to its bulk form.
3) In the longer term, the Commission is also concerned that more sophisticated third and fourth generation nanoproducts may represent a further step change in functionalities and properties, which would be even more difficult to capture in a regulatory system primarily focused on the bulk chemical properties of a material.
Approaching the topic from this perspective, the RCEP authors found that many aspects of nanomaterials are already covered by existing regulatory arrangements, notably those of the European Community Regulation on chemicals and their safe use (REACH) and that other dimensions could be covered by logical extensions of the existing framework.
For instance, one problem is that some nanomaterials may simply escape attention. "Under REACH, nanoscale versions of existing substances (e.g. titanium dioxide) are treated in the same way as the equivalent bulk material, even if they have very different properties. The most significant potential limitation of REACH in relation to nanomaterials is the one tonne threshold for registration. Because of the very large number of particles present even in tiny quantities of a nanomaterial, one tonne may be too high a threshold to capture potentially problematic effects."
The Commission expressed its deep concerns about the scale of the challenge involved and the timescales required to modify the existing regulatory framework and to gather the necessary data. The authors write that they "were repeatedly told by competent organizations and individuals that there is currently insufficient information to form a definitive judgment about the safety of many types of nanomaterials. In some cases, the methods and data needed to understand the toxicology and exposure routes of nanomaterials are insufficiently standardized or even absent. There appears to be no clear consensus among scientists about how to address this deficit."
The report makes a number of recommendations on how to deal with ignorance and uncertainty in the area of nanomaterials, which could also be applied to other areas of fast-paced technological development. It clearly states that simply to impose a moratorium that stops nanotechnology development is not a solution, but "while any kind of blanket moratorium does not seem appropriate, there may well be specific cases where it is necessary to slow or even hold up the development while concerns are investigated."
The Commission’s recommendations reflect the three main concerns mentioned above:
Functionality. "We need to focus on the properties and functionalities of specific nanomaterials as the key driver for understanding their behavior in organisms and the environment, rather than treating all materials in the size range as one single class."
Information. "A directed and substantial research program on the properties and functionalities of nanomaterials must be established as a matter of urgency, in order to inform risk assessment and risk management strategies. One essential part of such a directed program will be the development of techniques that allow the presence of particular nanomaterials to be detected in the environment."
Adaptive management. "Government urgently needs to recognize the degree of ignorance and uncertainty in this area, and the time it will take to address these. Government needs to develop flexible and resilient forms of management that allow appropriate control of emergent technologies in general, and for nanomaterials in particular."
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