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Nanotechnology controls: Voluntary or required?

In an Alternet article called The Evolution of Frankenfoods?, there’s a comment on voluntary controls on nanotech: “Jennifer Sass of the Natural Resources Defense Council worries that industry will get its way on voluntary, rather than enforceable, regulations. ‘Having these kinds of joint partnerships and collaborative efforts is a good thing,’ she says, ‘But without an overhanging enforceable regulation, I’m quite confident that the voluntary initiatives are inadequate regulations.’ ”

To me, voluntary initiatives seem like a positive first step (maybe even a necessary first step) in the evolution of the enforceable regulations that we’ll need to have. In a July 15 radio interview I did with Dr. Sass on KPFA, I think she agreed with this point. Hear the interview in MP3 format.

6 Responses to “Nanotechnology controls: Voluntary or required?”

  1. Jim Logajan Says:

    It makes no sense to me, at least, to indicate a need for control or regulation when no one is providing specifics on said regulations.

    If someone, such as Jennifer Sass, has specific proposals then she needs to put them forth so everyone who may be harmed by those regulations may critique them. Otherwise nothing is accomplished (except perhaps to spread innuendo).

  2. Christine Peterson Says:

    To see the NRDC proposals, follow these directions from Jennifer Sass:

    “Our comments are available at the EPA docket
    http://docket.epa.gov/edkpub/do/EDKStaffCollectionDetailView?objectId=0b0007d480453d0c

    “Once at the docket, our document is numbered: OPPT-2004-0122-0013

    “You can download the pdf there.”

  3. Novak Says:

    The recommendations boil down to, basically, an imposition of the European Union’s REACH chemical industry regulatory structure to the nacsent United States nanomaterial manufacturing industry. Which, in turn, boils down to “Guilty until scientifically proven completely innocent.”

    They come very close to saying exactly that, even unto naming REACH as a template and using a boatload of European case precedent, and stating that “no data” should be treated the same as “adverse data.”

    I would remind people that there is a reason the EU chemical industry is on the skids, and that REACH is a large part of it.

  4. Jim Logajan Says:

    Thank you for the link, Christine. I note that they “recommend that EPA conclude ab initio that because of their inherent properties, engineered nanomaterials “may present an unreasonable risk of injury to health or the environment,” until it is demonstrated by their manufacturers otherwise.”

    The underlying philosophy disturbing and unsound. Suppose the philosophy that underlies their recommendations were applied to parenting, to wit:

    “We recommend that EPA conclude ab initio that because newborn children can grow to become murderers or Republicans, they “may present an unreasonable risk of injury to health or the environment,” and should be kept under house arrest until it is demonstrated by their parents otherwise.”

    In their conclusion, they state “We urge the federal government, state regulators, and corporate
    leaders to develop this new technology with transparency, credibility, public oversight and
    participation.” The statement assumes that government, state regulators(!), and corporations will be the only ones developing nanotechnology. They fundamentally misunderstand the character of the technology, because they missed several important sources of future nanotech products: individual inventors, private academics, and small business partnerships, who have little in common with corporations. If their recommendations are followed, overcoming the “guilty until proven innocent” burden would, if successful, cost so much that only those with the largest collections of capital, such as corporations, would be players. If “inequalities within and between nations may be exacerbated if individuals and corporations gain monopoly control of nanotech,” then their recommendations would seem to increase, not decrease, the inequalities.

    Another assumption underlying their proposals is that the deus ex machina that would need to forcibly impose “guilty until proven innocent” in order to protect their current level of health and the environment is fundamentally more benevolent and more wise than those actually developing nanotechnology.

    The evidence I have from current world events tells me that the deus ex machina is neither more benevolent or more wise than those who are making the sacrifices and have the knowledge and experience necessary to bring the miracle forth. The current level of health of the average person (think third world) and the current or projected state of the environment (think industrial output needed to raise the living standard of the third world) is deeply saddening. To propose “guilty until proven innocent” regulations that would maintain that status quo is appalling.

    If acted on, the proposals will lead to inaction that will prolong suffering among the multitudes that the authors clearly overlooked and promotes the loss of individual freedoms that gives life itself any hope of meaning.

  5. Christine Peterson Says:

    Response to Jim Logajan: Thanks for your comments. Of the points you make, the one that I think is the most convincing, to both sides of this debate, is that the regulatory regime being proposed seems likely to drive development in the direction of large, wealthy corporations and away from smaller entities. –CP

  6. Novak Says:

    I disagree with Jim’s assessment only to the degree that I think it would not simply drive all development into the hands of the largest, most deep-pocketed players, but that it would also necessarily hinder the development of such products even by those players… quite likely, down to a trickle.

    Considering some of the signatory groups of the document (Greenpeace, the Sierra Club) I am cynical enough to believe that that is exactly the point.

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