NNI Does Nanotech EHS Regulation Right.
The NNI's Third Report is out. The environmental, health, and safety section calls for interagency coordination and identification of "plausible risks." This is good policy and good science. So why isn't EPA listening?
The NNI's approach to EHS emphasizes cooperation, coordination, and, most critically, risk assessment focused on plausible, not theoretical, concerns. It states:
Over the past two years, the NNI has released a cross-agency nanotechnology EHS research strategy, instigated multi-stakeholder workshops on nanotechnology EHS issues, and seen the Federal nanotechnology EHS research budget increase from $67.9 million in 2008 to a requested $116.9 million in 2011. Individual agencies have also played an active role in international efforts to develop nanotechnology responsibly....NNAP recommends that member agencies increase coordinated efforts...Specifically, the NSET Subcommittee’s interagency working group on Nanotechnology, Environmental, and Health Implications (NEHI) should develop clear principles to support the identification of plausible risks associated with the products of nanotechnology. The NSET Subcommittee’s NEHI working group should also further develop and implement a cross-agency strategic plan that links EHS research activities with knowledge gaps and decision-making needs within government and industry to make commercial and regulatory decisions that ensure safe use of nanotechnology products.
EPA, by contrast, seems to have determined to stretch its legal authorities, to act unilaterally, and to regulate highly theoretical risks. In this case, NNI, not EPA, has it right. NNI's approach will facilitate nanotechnology research and deployment. EPA's approach will not.
