A recent US National Research Council (NRC) report on research into environmental, health and safety (EHS) matters relating to nanomaterials provides a disturbing picture of nanomaterials flooding markets all over the world, but EHS work languishing years behind with insufficient funding and priority.
The notion that we can simply release new substances into complex environments without fully understanding the environmental and health impacts of doing so should have died with the cane toad and asbestos. But the power – and absurdity – of the capitalist ethic shouldn’t be underestimated. In the world of nanotechnology and the world of extreme free market ideology, a product doesn't need to be assessed for environmental impacts or human safety before being released.
In 2012 the NRC set out an EHS research strategy for beginning to deal with the gigantic gaps in knowledge surrounding the environmental and human health impacts of nanomaterials. That research strategy became part of the National Nanotechnology Initiative (NNI) in the US, in what was supposed to be an integrated, collaborative effort by many departments to ensure that the development of nanotechnology industries was done well.
These are not simply arcane research priorities but the basic research and knowledge that are needed both to understand, identify, assess, control and remediate potential impacts. It is the kind of knowledge that is necessary if we are going to have coherent regulation that ensures nanoproducts that aren't safe aren't released and that if unpredicted impacts occur, we have the tools to deal with it.
At a basic research level, the NRC report makes clear that we don't:
- have consistent reference materials that would allow consistency across different studies;
- know how to quantify the effects of engineered nanomaterials (ENMs);
- have instrumentation to measure key properties of ENMs;
- know what critical populations or systems are exposed to ENMs;
- have consistent testing standards so test results can be compared and duplicated;
- have the data needed to calibrate and validate models;
In trying to assess environmental impacts, we are equally ignorant. We don’t have:
- basic data relating to impacts on ecologically relevant species;
- data on ecosystem effects of chronic low-dose exposure to various nanoparticles;
- basic information regarding the life cycles of various ENMs;
- information on the complex, synergistic and cumulative interactions of nanoparticles in a variety of complex systems;
- information on exposure potential in different environments such as water, aquifers, soil, air and through wastewater and the food chain;
Our capacity to study impacts of nanomaterials on humans is also limited. For instance, we don’t:
- know toxicity mechanisms of different ENMs;
- know what level of exposure and which human populations are most exposed to ENMs;
- have system level approaches in order to understand the impacts of ENMs on human health.
And it gets worse. Many of the failings identified by the NRC depend on being able to determine what and where nanomaterials are! It would seem basic that regulators would track what products, what processes, what particles and materials are being used, but industry doesn't like the idea and so Australia has no labelling or disclosure requirements for the nanomaterials in use here.
There are already thousands of consumer products that contain nanomaterials. These include food ingredients, products for toddlers and babies, clothing, materials and appliances - to name just a few. A recent court case in the US found that nano-silver coating on clothing and materials – designated a pesticide in the US - was ‘ubiquitous’ and that there was no way for consumers to avoid exposure.
While the number of products containing nanomaterials continues to accelerate, there are an increasing number of independent peer reviewed studies indicating that certain nanomaterials may be harmful to both human health and the environment. The lack of basic research identified by the NRC means that studies such as these are more difficult to duplicate, may be given less weight than they deserve and are easier to challenge should they be used as the basis for precautionary regulation.
Despite at least 7 government agencies having responsibilities relating to nanomaterials, the majority of nanomaterials in Australia remain effectively unregulated. Some agencies keep a watching brief on new developments and new science, but that is very different to filling the gaps in our current research needs or taking a pro-active role in ensuring that the impacts of new nanomaterials are understood before products are released.
Food Standards Australia New Zealand (FSANZ) has captured the regulatory mindset well. They have indicated that if foods are produced using nanomaterials, they will be subject to regulations under the novel food provisions of the Food Standards Code, but FSANZ has apparently undertaken no testing in order to determine if foods made and imported into Australia contain nanomaterials – which they almost certainly do. They are apparently waiting for the food companies using nanomaterials in food or packaging to come to them.
Of course, when they do, FSANZ is unlikely to have the basic knowledge or tools to determine if the foods are safe.
So we come back to the NRC report. Sometimes ignorance is bliss and sometimes it’s just stupid. It is critical that governments urgently invest in filling the gaps in knowledge associated with the environmental and human health impacts of nanomaterials. Until that’s done there should be a moratorium on any further commercial releases of nanomaterials. In some places that’s known as the precautionary principle.
