fined and incomplete in others, specifically risk management and exposure assessment. The committee also believes that some research needs that fall between categories could be overlooked.
The research needs in the NNI strategy document are not presented as concrete, measurable objectives, and the implementation plan fails to provide any sense of how success toward specific goals will be measured or what resources might be needed to achieve them.
The committee carefully considered the “gap analysis” in the NNI document, which was based on identifying FY 2006 funded projects as relevant to one or more of the five broad research categories. The committee concluded that the gap analysis is flawed and is neither accurate nor complete in laying a foundation for a research strategy. The approach used does not provide an accurate picture of current resource allocations even among the five broad categories. The committee concluded that the use of the FY 2006 data to conduct the gap analysis is perhaps the greatest flaw identified in the document. It is particularly problematic in the discussions of human health and metrology, in which it resulted in the inclusion of research projects that are not directly relevant to understanding the EHS needs related to nanomaterials. The issues arising from the gap analysis led to important deficiencies in all the research categories described in Section II of the 2008 NNI document. Because of the flaws in the gap analysis, it is difficult to understand the priorities of selected research needs and the logic for the priorities.
The NNI document states (p. 46) that “the EHS research strategy fundamentally depends on sustaining the broad spectrum of basic research…. The current balance of research funding addresses such basic investigations and supports regulatory decision making.” However, although the committee has no reason to doubt the value of the compelling nanotechnology research described, it notes that probably less than half the grants and resources counted in the inventory will provide any useful data to support regulatory decision-making. The analysis suffers universally from a lack of coherent and consistent criteria for determining the value of information provided by various research activities. Such criteria would ideally be founded on an understanding of the uncertainties in each of the various research fields and the interrelationships among them.
The federal funding specifically addressing nanotechnology-related EHS issues is far less than portrayed in the NNI document and may be inadequate. The committee concludes that if no new resources are provided and the current agency funding continues, the implementation plan described in the NNI document will not ensure that engineered nanomaterials are adequately evaluated for potential health and environmental effects. Such an evaluation is critical to ensure that the future of nanotechnology is not burdened by uncertainties and innuendo about potential adverse health and environmental effects of engineered nanoscale materials. Those concerns have been voiced recently by both the nanotechnology industry and a variety of environmental and public-health interest groups.