priorities reviewed and evaluated in the previous NNI reports, Environmental, Health, and Safety Research Needs for Engineered Nanoscale Materials (NEHI 2006) and Prioritization of Environmental, Health, and Safety Research Needs for Engineered Nanoscale Materials: An Interim Document for Public Comment (NEHI 2007), both of which received public comment. The first of those reports developed five research categories with a total of 75 research priorities. The priorities were reduced to 25 in the second report. The new strategy (NEHI 2008) attempts to develop timelines and sequence the research needs and uses an accounting of research projects of FY 2006 to determine the strengths, limitations, and data gaps of the research portfolio.

There is no evaluation of the existing state of science or of federally funded research in each of the five categories identified in the strategy—instrumentation, metrology, and analytic methods; nanomaterials and human health; nanomaterials and the environment; human and environmental exposure assessment; and risk-management methods. Rather, the research categories and identified research needs (see Box 3-1) are analyzed solely in the context of FY 2006 research projects. The committee questions the NNI’s use of FY 2006 data to assess the extent to which federally funded environmental, health, and safety (EHS) research for nanomaterials is supporting the selected research needs. The majority of the research projects listed for FY 2006 focused on fundamentals of nanoscience that are not explicitly associated with risk, or on developing nanotechnology applications.¹ There also is no clear connection between the research projects and how they will inform an understanding of risk. Without a clear articulation of how the research projects will inform that understanding, the report’s assessment is highly misleading and inappropriately used to identify whether research needs are being addressed.

NNI (NEHI 2008) contains conflicting statements about the use of FY 2006 research projects to evaluate research needs. The document states that “this analysis of strengths, weaknesses, and gaps will inform agency decisions about the magnitude and balance of future EHS research investments” (NEHI 2008, p. 9). But the document continues, “data gathered for FY 2006 represent a one-time-only ‘snapshot’ of the NNI agencies’ EHS research portfolios in one year. However, these are likely to be indicative of the overall trends in agency investments in more recent years” (NEHI 2008, p. 9). The strategy goes on to acknowledge limits of the gap analysis, including statements that the data represent only projects funded in FY 2006; that the data represent planned research, not research results; and that only federally funded research is accounted for—there is no mention of research funded by industry, nonprofit organizations, or other countries. Those statements in the strategy were echoed by Altaf Carim,