Review of the Federal Strategy for Nanotechnology-Related Environmental, Health, and Safety Research (2009) / Chapter Skim
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3 Evaluation of the Federal Strategy
3 Evaluation of the Federal Strategy
Pages 40-52
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From page 40... ...
However, the committee determined that the NNI document does not have the essential elements of a nano-risk research strategy, inasmuch as it does not evaluate the state of science, does not contain a clear set of goals, and does not have a plan of action for achieving the goals or mechanisms to review and evaluate funded research and assess whether progress has been achieved. There is no attempt to show how existing research will lead to answers to critical questions that the federal government, the research community, and other stakeholders are grappling with.
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From page 41... ...
Those statements in the strategy were echoed by Altaf Carim, 1 The 246 FY 2006 research projects listed include research on instrumentation and metrology and on medical applications that is not captured in the list of 130 environmental, health, and safety research projects included in the annual supplement to the president's budget (Teague, unpublished material, 2008)
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From page 42... ...
. BOX 3-1 Priority Environmental, Health, and Safety Research Needs for Engineered Nanoscale Materials, as Identified in the 2008 National Nanotechnology Initiative Research Strategy Instrumentation, Metrology, and Analytical Methods 1.
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From page 43... ...
Source: NEHI 2008. The committee's concerns about the limitations of the assessment of the state of science were reflected by Carolyn Cairns, program leader of product safety for Consumer's Union, at the May 5, 2008 workshop: "The document resembles a laundry list of ad hoc projects that some agencies have shoe-horned into relevance for environmental health and safety.
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From page 44... ...
The committee notes that in some cases the strategy document reads as though it has two stated objectives: continuing to support nanotechnology and understanding risks. As the strategy states, "this effort has entailed identifying and prioritizing EHS research for nanomaterials; analyzing the current research portfolio in detail; performing a gap analysis to determine areas requiring emphasis; and developing a strategy to address these areas and to sustain the diverse program aimed at advancing knowledge and supporting risk decision making" (NEHI 2008, p.1; emphasis added)
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From page 45... ...
. The current NNI strategy appears to essentially consist of a listing of agency projects cobbled together to look like a strategy" (Kojola 2008, p.
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From page 46... ...
and NNI (NEHI 2007) identify principles for identifying and setting priorities for EHS research, including value of information, leveraging research by other governments and the private sector, and adaptive management of nanomaterial EHS research; but it is not clear how these principles were used in selecting the research priorities.
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From page 47... ...
However, with respect to the overall funding level, the strategy document suggests that sufficient funding is already being dedicated to EHS research by the NNI and that funds should not be redirected to this research from other kinds of nanotechnology research. The strategy states, surprisingly, that "the current balance of research funding addresses such basic investigations and supports regulatory decision making.
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From page 48... ...
To have effective stakeholder engagement requires that the strategy be developed through a process of stakeholder input and consultation. There are many models of this, including tripartite input from government, industry, and civil society representatives, which would ensure that the strategy developed served the needs of regulators, industry, and citizens without being unduly biased by any particular group.
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From page 49... ...
That is reflected in remarks by William Gulledge, senior director of the Chemical Products and Technology Division of the American Chemistry Council, an industry trade association, who emphasized the need for a more broadly defined strategy, noting that the NNI plan "'represents a bottom-up approach where agencies identify their priorities.
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From page 50... ...
and simply relies on the budgets of its member agencies, it has no resources or influence to shape the overall federal EHS research activity. The NEHI must devise a research strategy that is responsive to individual agency budgetary priorities rather than developing a much-needed vision and strategy that include assurances that adequate resources go to the appropriate agencies to realize the vision.
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From page 51... ...
When both supporters and critics of nuclear energy raised strong concerns about both development and regulatory oversight being housed in the Atomic Energy Commission (AEC) , Congress responded in 1974 by creating the Nuclear Regulatory Commission (NRC)
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From page 52... ...
2008. Critics Slam Federal Nano Environmental, Health Research Strategy.
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