Falling in love with a new technology and wanting to apply it everywhere is not a good idea
Will nanotechnology become an object of harsh controversy like genetically modified organisms? Or will it take the path of the less controversial stem cell therapy? What lessons can be learned from past innovations, in order to avoid repeating old mistakes in future with nanoscience?
Recent history is full of new technologies whose risks were underestimated: from asbestos to chlorofluorocarbons, from non-ionising radiation to high frequency trading. But there are also examples of excessive precaution: the overreaction to swine flu or the missed opportunity of irradiated food, for example.
“We don’t seem to be able to apply lessons from the past to nanotechnology: we have been taught the same lessons over and over again, but it seems that regulators need to relearn them,” says Steffen Foss Hansen, associate professor at the department of environmental engineering of the Technical University of Denmark, and co-author of a chapter on nanotechnology in Late lessons from early warnings, a report published last January by the European Environmental Agency (EEA). It contains case studies of the delay between early evidence of harm and action to reduce risks in new technologies.
“In the early years of this century, there was a lot of dialogue on nanomaterials among industry, researchers, regulators, and NGOs. But as soon as evidence of real risks arose, the discussion became entrenched in the old commonplace about regulation hurting innovation, and people being overly alarmed. We have already seen this kind of rhetoric in the past,” says Foss Hansen.
What lessons does the EEA report have for nanotechnology? An obvious one is: heed the warnings. But it is not always applied. The first evidence, in 1979, on the link between lead use in petrol and reduced IQ in children was heavily attacked by industry and scientists.
“Initial studies raising concerns are often dismissed because they are necessarily sketchy, but instead they should be investigated thoroughly,” says Foss Hansen. The risk of overrating false positives is rarely an issue, he thinks. The authors of the EEA’s report found only four cases in which regulators took unnecessary precautionary actions.
Another lesson is that people not normally considered experts – such as the factory workers who deal with products every day – have knowledge that must be taken on board.
Polychlorinated biphenyls (PCBs) were assumed to be safely confined in the devices that used them, but instead they spilled into the environment. Maybe this could have been avoided by speaking with factory workers, who were handling the material every day. “Nanomaterials factories are not that different from the others,” says Foss Hansen.
Even accounting for wider social values may be useful. “The BSE [bovine spongiform encephalopathy] scandal would not have happened had the regulators considered the perception that feeding animals with dead versions of themselves is not very appealing to our society. People are likely to be happy with application of nano to medicine, but not to create supersoldiers, for example,” he says.
Past examples show that falling in love with a new technology and wanting to apply it everywhere is not a good idea. “We have seen many cases of new technologies looking for a problem, while much better and simpler solutions were available. Maybe it does not make much sense that the number of products with the word nano on their label doubles every 18 months,” he says.
Last July a European directive came into force that obliges cosmetics producers to clearly state the presence of nano components in their products, because such ingredients have proliferated in the past few years.
Institutional ignorance (when a decision is taken by people on one floor of an institution, ignoring the relevant information available to people on another floor) is another risk. Geologists knew that MTBE (methyl tert-butyl ether) – a substitute for lead in petrol – would go through the soil and pollute groundwater, when it was allowed as an ingredient in petrol. But several environmental agencies made the decision without taking this information into account.
Another lesson is that regulatory bodies responsible for overseeing technologies should be separated from organisations put in place to promote them. This separation is not always respected. For example, the US national nanotechnology initiative was designed with the dual purpose of developing nanotechnology applications and identifying their risks, a conflict of interests denounced in testimony (pdf) to Congress in 2007.
But what worries Foss Hansen more is what he calls “paralysis by analysis”. “Since 2008, there is increasing evidence that nanosilver is very toxic if it ends up in the aquatic environment. The early warning is there, yet agencies are still calling for more reviews: maybe they are just buying time to avoid implementing regulations,” he says.
Another concern is the lack of rules specific to nanotechnology within the EU chemicals regulation known as Reach (Registration, evaluation, authorisation, and restriction of chemicals). “If you change Reach to be more precise about nanomaterials, then you might open the door to extend it to other issues, like chemical mixtures or endocrine disruptors,” says Foss Hansen. “My feeling is that the commission is trying to hold a lid on it, and get Reach a chance to be fully implemented as it is, before you add extras to it.”. He finds the delay worrying.
The economic crisis and climate change may be making regulators wary of implementing more regulation, for fear of increasing the burden on industry. But the production volumes, and presumably the economic output, of nano materials has been going up every year since the middle of the past decade. “It’s tragic that we seem to be postponing action until we have evidence beyond reasonable doubts, just because we don’t want to [wage the] battles needed to add extra regulatory burden to industry,” Foss Hansen says.
Hilary Sutcliffe, director of Matter, a British NGO created in 2007 that co-ordinates the Nano&Me website, believes many stakeholders – including companies, regulators and scientists – are taking the wrong approach.
“Companies and scientists are talking about building trust in nano, that is, telling [people] how great it is and persuading the public to trust them. But the sector should focus instead on building trustworthiness: demonstrating that it deserves trust. Trustworthiness builds trust, trust builds confidence, and confidence builds markets,” she concludes.