Nanotechnology Lawyer & Attorney : Bergeson & Campbell Law Firm : Nanotechnology Law Blog

On May 20, 2008, the National Institute for Occupational Safety and Health (NIOSH) posted an entry on its science blog entitled “Nanotechnology: Should carbon nanotubes be handled in the workplace like asbestos?” The entry was prompted by the release of two recent reports contributing to the carbon nanotube/asbestos fiber comparison debate. The entry asks what the implications are to the risk assessment and risk management of carbon nanotubes in U.S. workplaces, and states:

However, questions have been raised about using these research findings for risk assessment analysis in the light of study limitations such as use of model animals, artificial administration methods, and sometimes extremely high doses, which are not representative of those exposures usually present in the workplace environment.  Such limitations are not unusual for pioneering scientific studies.  They simply mean that at this stage of the research, gaps remain that need to be closed by further study before quantitative risk assessment can be conducted.

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On May 16, 2008, EHP-in-Press posted an article entitled “Raw Single-Wall Carbon Nanotubes Induce Oxidative Stress and Activate MAPKs, AP-1, NF-κB, and Akt in Normal and Malignant Human Mesothelial Cells.” According to the article, the unique physicochemical and mechanical properties of single-wall carbon nanotubes have many potential new applications in medicine and industrial uses. The article states that exposure to single-wall carbon nanotubes induced generation of reactive oxygen species, increased cell death, enhanced DNA damage, H2AX phosphorylation, and activated poly(ADP-ribose) polymerase, activator protein-1, nuclear factor kappa B, protein p38, and protein serine-threonine kinase in a dose-dependent manner.  The article concludes that the cellular and molecular findings reported suggest that single-wall carbon nanotubes “can cause potentially adverse cellular responses in mesothelial cells through activation of molecular signaling associated with oxidative stress, which is of sufficient significance to warrant in vivo animal exposure studies.” EHP-in-Press articles have been peer reviewed and accepted for publication in Environmental Health Perspectives.

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On April 24, 2008, the U.S. Government Accountability Office (GAO) released a report entitled Nanotechnology: Accuracy of Data on Federally Funded Environmental, Health, and Safety Research Could Be Improved, which contains the testimony of Robert A. Robinson, Managing Director, Natural Resources and Environment, before the Senate Committee on Commerce, Science, and Transportation Subcommittee on Science, Technology, and Innovation. Robinson provided a summary of GAO’s findings as reported in its March 31, 2008, report entitled Nanotechnology: Better Guidance Is Needed to Ensure Accurate Reporting of Federal Research Focused on Environmental, Health, and Safety Risks. GAO was asked to focus on: (1) the extent to which selected agencies conducted environmental, health, and safety (EHS) research in fiscal year (FY) 2006; (2) the reasonableness of the agencies’ and the National Nanotechnology Initiative’s (NNI) processes to identify and prioritize EHS research; and (3) the effectiveness of the agencies’ and the NNI’s process to coordinate EHS research.

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On March 11, 2008, the German Chemical Industry Association (VCI) released a report entitled Responsible Production and Use of Nanomaterials, which is a series of documents intended to provide guidance on all aspects of a good product stewardship on nanomaterials. The documents include joint papers prepared by VCI and the German Federal Institute for Occupational Safety and Health (BAuA) and the German Society for Chemical Engineering and Biotechnology (DECHEMA). The report includes the following documents:

Principles Document:

• Implementing Responsible Care® for a Responsible Production and Use of Nanomaterials

Regulatory Documents:

• Requirements of the REACH Regulation on Substances Which Are Manufactured or Imported also as Nanomaterials
• Guidance for a Tiered Gathering of Hazard Information for the Risk Assessment of Nanomaterials
• Guidance for Handling and Use of Nanomaterials at the Workplace
• Guidance for the Passing on of Information along the Supply Chain in the Handling of Nanomaterials via Safety Data Sheets
• Strategy Paper of the German Chemical Industry on the Standardization of Nanomaterials

Documents on Safety Research:

• Roadmap for Safety Research on Nanomaterials
• Environmental Aspects of Nanoparticles

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On April 9, 2008, the Project on Emerging Nanotechnologies (PEN) released a report entitled Room at the Bottom? Potential State and Local Strategies for Managing the Risks and Benefits of Nanotechnology. According to the report, because of the slow pace of federal action to regulate development of nanotechnology, “there is ‘room at the bottom’ for state and local governments to move forward in pursuing regulatory and other oversight options.” Research for the report identified a number of states with laws promoting the nanotechnology industry or other initiatives encouraging research and development on nanotechnology applications. The report states that each of the 50 states is “home to at least one company, university, government laboratory, or other type of organization working with nanomaterials.”

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On March 26, 2008, EHP-in-Press posted an article entitled “Recirculating Air Filtration Significantly Reduces Exposure to Airborne Nanoparticles.” The authors investigated the effectiveness of recirculating air filtration to reduce exposure to incidental and intentionally produced airborne nanoparticles while driving in traffic, and while generating nanomaterials using gas-phase synthesis. The authors state that “use of inexpensive low-efficiency filters in recirculation systems is shown to reduce nanoparticle concentrations to below levels found in a typical office within three minutes while driving through heavy traffic, and within twenty minutes in a simulated nanomaterial production facility.”

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On March 25, 2008, the National Institute for Occupational Safety and Health (NIOSH) posted fact sheets regarding several initiatives for which it seeks participants. NIOSH states that the initiatives are fully funded by NIOSH, and there is no monetary cost to the participant.  The first two fact sheets concern NIOSH’s Nanotechnology Field Research Team, which is available to conduct site visits at facilities involved in the research, manufacture, or use of various types of nanomaterials. The third fact sheet describes NIOSH’s metal oxide particle exposure assessment study, for which NIOSH seeks manufacturers and end-users of fine and ultrafine metal oxides.

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DuPont and Environmental Defense (ED) will hold two interactive workshops on nano risk management. The workshops are intended to give participants the tools they need to:

• Understand (and explain to others) why nano-specific risk management is necessary;
• Assemble and leverage the internal and external resources to implement nano-specific risk management; and
• Begin implementing nano-specific risk management in an efficient and effective manner.

The workshops will include:

• Interactive discussions of how to implement nano-specific risk management;
• Case studies of nano-specific risk management in use by companies and governments; and
• Sources of additional help for companies adopting these approaches.

The first workshop will be held April 2, 2008, at the Sustainable Packaging Coalition in San Francisco, California. A second workshop will be held April 8, 2008, at the Toxics Use Reduction Institute in Boston, Massachusetts.

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Last week the National Institute for Occupational Safety and Health (NIOSH) requested comments on its Strategic Plan for NIOSH Nanotechnology Research and Guidance:  Filling the Knowledge Gaps (Strategic Plan).  NIOSH intends the Strategic Plan “to provide a tool for coordinating nanotechnology research across the Institute and to provide a guide for enhancing the development of new research efforts that will respond to the challenges of working with a new technology.” According to NIOSH, the Strategic Plan “represents a cohesive, multidimensional, and timely research agenda for addressing knowledge gaps concerning possible worker exposures to nanomaterials, the health risks from such exposure, and development of control technology and prevention measures.” Comments are due June 1, 2008.

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On February 29, 2008, the National Institute for Occupational Safety and Health (NIOSH) announced the availability of a brochure entitled “Safe Nanotechnology in the Workplace: An Introduction for Employers, Managers, and Safety and Health Professionals.” The brochure addresses the following questions: whether nanoparticles are hazardous to workers; how workers can be exposed; whether nanoparticles can be measured; and whether worker exposures can be controlled. The brochure states that little information is available about the hazards of nanoparticles in the workplace, and that NIOSH is conducting research to determine whether they pose a health threat to exposed workers. According to the brochure, workers may be exposed by three routes: inhalation (the most common); ingestion; and skin. Traditional industrial hygiene sampling methods can be used to measure airborne nanoparticles, and scientists are developing more sensitive and specific sampling techniques. The brochure states that worker exposures can be controlled with engineering controls, respirators, and training.

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Bergeson & Campbell, P.C. is pleased to announce that Lynn L. Bergeson and Ira Dassa published an article appearing in the Fall 2007 issue of Sustainable Development Law and Policy. The article discusses several issues in connection with the application of the Toxic Substances Control Act (TSCA) to engineered nanoscale materials.

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On 3 January 2008, Lloyd’s released a report entitled Nanotechnology: Recent Developments, Risks and Opportunities, which examines the potential risks and opportunities in the emerging field of nanotechnology. Lloyd’s states that nanotechnology “promises to improve many industries including medicine, food technology, textiles, materials, cosmetics, defence and more, but the risks are still not fully understood.”

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On January 2, 2008, the National Nanotechnology Initiative (NNI) released its Strategic Plan, which describes NNI’s investment strategy and the program component areas called for by the 21st Century Nanotechnology Research and Development Act of 2003. Under the Act, NNI must update its Strategic Plan every three years, and this plan updates and replaces the December 2004 plan. The Strategic Plan outlines the goals and priorities of NNI and describes approaches for achieving them. NNI states that the Plan supports “leading edge research, sustains the extensive infrastructure of facilities, seeks to facilitate technology transfer, and addresses environmental, health, and societal concerns.”

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The U.S. Environmental Protection Agency’s (EPA) December 10, 2007, Unified Agenda includes a notice regarding the Nanoscale Materials Stewardship Program (NMSP), which is a voluntary program that EPA established to assemble existing data and information from manufacturers and processors of certain nanoscale materials. The notice states that, under the Toxic Substances Control Act (TSCA), EPA has the authority to require the development of data necessary for risk assessment when statutory findings concerning (1) production volume and exposure/entry into the environment or (2) potential hazard can be made, and to prevent and eliminate unreasonable risk of injury to human health and the environment. On July 12, 2007, EPA announced the availability of an NMSP concept paper, a proposed information collection request (ICR), and a paper that describes determining the TSCA Inventory status of nanoscale materials. According to the Unified Agenda notice, EPA intends to publish in February 2008 a final NMSP notice, including final versions of any documents.

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On December 12, 2007, the National Institute for Occupational Safety and Health (NIOSH) announced the availability of the draft Current Intelligence Bulletin (CIB) entitled “Interim Guidance on Medical Screening of Workers Potentially Exposed to Engineered Nanoparticles.” NIOSH will hold a public meeting on the draft CIB on January 30, 2008. The meeting will include scientists and representatives from various government agencies, industry, labor, and other stakeholders, and is open to the public, limited only by the space available. Because the meeting room accommodates only 80 people, NIOSH must receive notification of intent to attend the meeting no later than January 18, 2008. Persons wanting to provide oral comments at the meeting are requested to notify NIOSH no later than January 11, 2008. NIOSH will give priority for attendance to those providing oral comments. NIOSH will then accommodate other requests to attend the meeting on a first-come basis. Comments on the draft CIB are due February 15, 2008.

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On December 4, 2007, the Organization for Economic Cooperation and Development (OECD) posted a notice entitled “Testing a Representative Set of Nanomaterials -- The Launch of a Sponsorship Programme.” OECD states that its Working Party on Manufactured Nanomaterials has launched a sponsorship program in which countries will share the testing of specific nanomaterials. According to OECD, valuable information on the safety of manufactured nanomaterials can be derived by testing a representative set for human health and environmental safety. In launching the sponsorship program, the Working Party agreed to a priority list of manufactured nanomaterials for testing, based on materials which are in or close to commerce, as well as a list of endpoints for which they should be tested. OECD intends to make regular updates on this program.

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On November 8, 2007, the Office of Science and Technology Policy (OSTP) and the Council on Environmental Quality (CEQ) issued a memorandum regarding “Principles for Nanotechnology Environmental, Health, and Safety Oversight.” According to the memorandum, OSTP and CEQ “led a multi-agency consensus-based process” to develop principles intended to guide the development and implementation of policies for nanotechnology environmental, health, and safety oversight at the agency level.  The memorandum says that federal agencies such as the U.S. Environmental Protection Agency (EPA), the Food and Drug Administration (FDA), the Occupational Safety and Health Administration (OSHA), and the National Institute for Occupational Safety and Health (NIOSH) “must implement sound policies to protect public health and the environment,” and “agencies that perform nanotechnology research and development or that use nanotechnology in accomplishing their mission must provide appropriate oversight.”

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On October 25-26, 2007, the European Commission (EC) held the First Annual Nanotechnology Safety for Success Dialogue. Presentations included:

• Food applications of nanoscience and nanotechnologies -- Ms. Sue O’Hagan, Confederation of the Food and Drink Industries of the European Union (CIAA);
• Consumer products applications of nanoscience and nanotechnologies -- Dr. Michael Holman, Lux Research;
• Health applications of nanoscience and nanotechnologies -- Dr. Carole Moquin-Pattey, European Science Foundation (ESF);
• Nanotechnology risk assessment: Knowns and unknowns -- Mr. Herman B.W.M. Koëter, Deputy Executive Director and Director of Science, European Food Safety Authority (EFSA);
• Nanoparticle toxicology: Scientific state-of-the-art -- Professor Ken Donaldson, University of Edinburgh;
• Nanomaterials. Risk assessment needs -- Professor Jim Bridges, Chair, Scientific Committee on Emerging and Newly Identified Health Risks (SCENIHR);
• The EU perspective on policy and regulatory aspects -- Mr. Kees Brekelmans; Enterprise and Industry Directorate General, “Consumer Goods” Directorate;
• Nanotechnology and the Food and Drug Administration:  Science and Policy -- Dr. Richard Canady, U.S. Food and Drug Administration (FDA); and
• The consumer perspective on applications of nanoscience and nanotechnologies -- Dr. Sue Davies, Chief Policy Advisor, Which?.

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The Federal Institute for Occupational Safety and Health (Bundesanstalt für Arbeitsschutz und Arbeitsmedizin/BAuA) (FIOSH) and the German Chemical Industry Association (Verband der Chemischen Industrie/VCI) (GCIA) have issued draft document entitled Guidance for Handling and Use of Nanomaterials at the Workplace. The Guidance is intended to provide an overview of occupational health and safety measures in the production and use of nanomaterials. The basis for the Guidance is a survey FIOSH and GCIA conducted in 2006 regarding occupational health and safety measures for handling and using nanomaterials. The Guidance provides recommendations for workers’ protection measures in the handling and use of nanomaterials, based on hazard assessments. The Guidance discusses the state of methods available for measuring nanoparticles and provides a flowchart that recommends specific hazard assessment activities based on the responses to flowchart questions. The Guidance will be developed further by mid-2008 to meet the advancing state of knowledge of nanoparticles.

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The Project on Emerging Nanotechnologies (PEN) at the Woodrow Wilson International Center for Scholars hosted on October 9, 2007, a seminar on the Responsible NanoCode, a voluntary, principles-based Code of Conduct for entities involved in the research, development, manufacture, and retail sale of products using nanotechnologies. The draft Code was developed by a working group organized in late 2006 by The Royal Society, the United Kingdom’s (UK) national academy of science, in conjunction with Insight Investment, the Nanotechnology Industries Association (NIA), and the UK government-sponsored Nanotechnology Knowledge Transfer Network.

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The American Conference of Governmental Industrial Hygienists (ACGIH) will hold a webinar entitled “Nanotechnology Health and Safety: Case Studies in the Occupational Setting” on December 4, 2007. The webinar will discuss the uncertainties associated with the hazards and potential risks of working with engineered nanoparticles; describe ways to help manage exposure to engineered nanoparticles; and illustrate how occupational health and safety controls, both engineering and administrative, can be implemented to manage better worker health and safety.  Additionally, the webinar will present case studies that will highlight how select organizations that use engineered nanoparticles in production facilities (metal oxide and metal alloy), as well as research laboratories, are addressing the safety and health issues behind this new technology.

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On August 16, 2007, the National Nanotechnology Coordination Office (NNCO), on behalf of the Nanoscale Science, Engineering, and Technology (NSET) Subcommittee of the Committee on Technology, National Science and Technology Council (NSTC), published a notice in the Federal Register announcing the availability of a document entitled The Prioritization of Environmental, Health, and Safety Research Needs for Engineered Nanoscale Materials: An Interim Document for Public Comment, which assigns priority to research needs and areas identified in the NSET Subcommittee document Environmental, Health, and Safety Research Needs for Engineered Nanoscale Materials, which was published on September 21, 2006.  Comments are due September 17, 2007.

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The National Institute for Occupational Safety and Health (NIOSH) has posted several material safety data sheets (MSDS) for nanomaterials in its Nanoparticle Information Library (NIL). The goal of the NIL is to help occupational health professionals, industrial users, worker groups, and researchers organize and share information on nanomaterials, including their health and safety-associated properties.  To view the MSDSs, enter msds in the search field.

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On July 31, 2007, an international coalition of consumer, public health, environmental, and labor organizations issued the Principles for the Oversight of Nanotechnologies and Nanomaterials and called for strong, comprehensive oversight of the new technology and its products. According to the coalition, the manufacture of products using technology has “exploded in recent years,” while “evidence indicates that current nanomaterials may pose significant health, safety, and environmental hazards.”

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The proceedings of the June 19-21, 2007, EuroNanoForum 2007 are available. According to the European Commission (EC), they “provide an overview of the state-of-the-art in nanotechnology for industrial applications, presented by selected international top speakers to open up new perspectives in Europe for coming years.”

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The Council of State and Territorial Epidemiologists (CSTE) recently issued a position statement on nanotechnology risks. The CSTE statement observes that the “health, safety and environmental effects of nanomaterials are poorly understood,” and that “our limited knowledge of [nanotechnology’s] potential harm is cause for concern.” Among other things, CSTE calls: for increased funding for research on the environmental, health, and safety impacts of nanotechnology; for the Food and Drug Administration (FDA) to require content-labeling on products containing nanoparticles that are aerosolized or applied to the skin; and for the U.S. Environmental Protection Agency (EPA) and Occupational Safety and Health Administration (OSHA) to issue standards for the protection of workers, the public, and the environment against known or suspected harmful effects of nanoparticles.

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On June 22, 2007, the U.S. Environmental Protection Agency (EPA) announced the award of two research grants totaling almost $600,000 to scientists at Oregon State University, who will evaluate whether some engineered nanomaterials adversely affect human health. Under the first research grant, scientists will review a variety of commonly manufactured nanomaterials to determine their potential interactions with biological processes; if the researchers find nanomaterials that produce adverse human health effects, they will seek to identify the potential cellular and genetic targets of those nanomaterials and group the nanomaterials by composition and effects. The second research grant will focus on how engineered nanomaterials can damage or kill cells, and is expected to lead to the development of occupational and environmental exposure guidelines.

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On June 21, 2007, Environmental Defense (ED) and DuPont, who commenced a partnership on nanotechnology in September 2005, released the final Nano Risk Framework, which establishes “a systematic and disciplined process for identifying, managing, and reducing potential environmental, health, and safety risks of engineered nanomaterials across all stages of a product’s ‘lifecycle.’” The Framework is aimed primarily at organizations, both private and public, that are actively working with nanomaterials and developing associated products and applications. ED and DuPont believe that “adoption of the Frameworkcan promote responsible development of nanotechnology products, facilitate public acceptance, and support the formulation of a practical model for reasonable government policy on nanotechnology safety.”

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The July 2007 issue of Consumer Reports includes an article entitled “NANOtechnology: Untold Promise, Untold Risk.” According to Consumer Reports, while nanotechnology “promises to be the most important innovation since electricity and the internal combustion engine,” “some applications might pose substantial risks to human health and the environment.” The article states that nanomaterials are already being used in consumer products such as car wax, computer chips, and sunscreen, and that approximately $2.6 trillion worth of goods worldwide are expected to use nanotechnology by 2014, up from $50 billion in 2006. Consumers Union (CU), the nonprofit publisher of Consumer Reports, concludes that the responsibility for protecting consumers rests mainly with government and industry.  In particular, CU believes that the government should provide more funds for risk research and regulation, and that the Food and Drug Administration (FDA) should assess safety information on nanoingredients in cosmetics, food additives, and other products before they are sold, and should require manufacturers to report health problems linked with those ingredients. The full article is available in the July 2007 issue of Consumer Reports.

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On May 11, 2007, the United Kingdom (UK) Health & Safety Executive (HSE) published its first bulletin on nanotechnology research. The bulletin is intended to provide an overview of published studies that have examined the exposure and potential health effects of nanomaterials, particularly in the occupational setting. According to HSE, inevitably there will be some overlap between studies of exposure of other groups (i.e. consumers).  HSE screened the literature search results to ensure that the studies listed are relevant to HSE and its responsibility to manage health and safety in the workplace. The first bulletin reviews literature published in 2000-2006. According to HSE, subsequent bulletins will summarize publications from the previous four-month period. The bulletins will summarize the range of studies that have been published in two areas of interest: measurement, characterization, and control of exposure to nanoparticles; and potential for toxic effects of nanoparticles in humans.

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On May 10, 2007, EHP-in-Press posted an article entitled “Reviewing the Environmental and Human Health Knowledge Base of Carbon Nanotubes.” The authors reviewed the currently available literature about the human health and environmental risk potential of carbon nanotubes (CNT). The authors also investigated the life cycle of the CNT, as release into different environmental compartments may occur at the production stages as well as the product’s usage and disposal stages, which may indirectly or directly cause human exposure. Because, according to the authors, the published literature revealed many open questions, they also systematically interviewed seven leading scientists worldwide and integrated their contemporary knowledge in the review. The authors interviewed scientists who were key authors or project leaders, having investigated and reported the potential impacts of CNT on human health or environment. Through this combined approach, the authors present an updated and contemporary knowledge base for scientific discussion.

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Environmental Defense (ED) will hold a webcast regarding its recent report, Not That Innocent: A Comparative Analysis of Canadian, European Union and United States Policies on Industrial Chemicals, on May 24, 2007, from 3:00 p.m. to 4:30 p.m. (EDT). The webcast will include a 45-minute presentation and a question and answer period. Dr. Richard Denison, Senior Scientist at ED, will present the findings and discuss his report, which compares the European Union’s new Registration, Evaluation, and Authorization of Chemicals (REACH) regulation, the Toxic Substances Control Act (TSCA), and the Canadian Environmental Protection Act (CEPA).

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On April 11, 2007, the European Commission (EC) announced that the report prepared by the Scientific Committee on Emerging and Newly Identified Health Risks (SCENIHR) regarding the appropriateness of the risk assessment methodology for assessing the risks of nanomaterials is available for comment. Comments are due May 23, 2007. EC states that the report “provides the Commission with a sound scientific approach on how to modify the Technical Guidance Documents of the EU chemicals legislation in regard to nanomaterials. The report provides proposals for general and specific modifications of risk assessment of human health and the environment, describes a staged strategy for the risk assessment of nanomaterials and identifies areas of further research.”

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On April 3, 2007, the United Kingdom’s (UK) Department of Environment, Food, and Rural Affairs (DEFRA) released its second quarterly update on the Voluntary Reporting Scheme (VRS) for engineered nanoscale materials. According to the update, DEFRA has received a total of six submissions since VRS’s launch in September 2006, four of which were from industry and two from academia. DEFRA has liaised with groups representing the UK nanotechnologies industry and has made direct contact with companies involved in the sector. From these contacts, DEFRA believes that “a number of VRS submissions are being prepared and will be delivered” in the near future. During discussions with industry, DEFRA sought feedback on VRS, and industry raised the following issues: uncertainty regarding the scope of VRS; resources; and confidentiality issues. The next update will be published in June 2007.

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The International Council on Nanotechnology (ICON) and Rice University’s Center for Biological and Environmental Nanotechnology (CBEN) announced on March 22, 2007, they have launched a monthly online journal that contains citations and links to articles on the environment and health impacts of nanotechnology. The ICON and CBEN coalition launched the first online database of nanomaterial scientific findings in August 2005, but the new journal -- The Virtual Journal of Nanotechnology Environment, Health & Safety (VJ-Nano EHS) -- “has taken the concept one step further,” the coalition said. The virtual journal organizes the information contained in the existing database into a reader-friendly monthly journal format. New features include a rotating guest editorship and a series of papers on topics of interest taken from the database. Contents of the journal are searchable. In the future, the coalition said, the journal will include a section on the most cited nanotechnology environment, health, and safety papers.

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On January 22, 2007, ISO published a report entitled Workplace Atmospheres -- Ultrafine, Nanoparticle and Nano-Structured Aerosols -- Inhalation Exposure Characterization and Assessment, which includes information on the potential health effects of nanoaerosols, sources of occupational nanoaerosols, exposure assessment strategies, particle ensemble characterization methods, size-resolved characterization, online chemical analysis, single particle analysis, and electron microscopy sample collection and preparation. The report states that its aim is “to provide generally accepted definitions and terms, as well as guidelines on measuring occupational nanoaerosol exposure against a range of metrics.” ISO intends the report to address an immediate need and establish an essential step for developing future exposure assessment standards for nanoaerosols.

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On March 20, 2007, the Woodrow Wilson International Center for Scholars Project on Emerging Nanotechnologies (PEN) released a report entitled Nanotechnology and Life Cycle Assessment: A Systems Approach to Nanotechnology and the Environment, which summarizes the results of the October 2-3, 2006, workshop organized by PEN and the European Commission on life cycle assessment (LCA). LCA is a cradle-to-grave analysis of how a material affects ecosystems and human health. According to the report, the purpose of the October 2-3, 2006, workshop was to determine whether existing LCA tools and methods are adequate to use on a new technology. The report provides an overview of LCA and nanotechnology, discusses the current state of the art, identifies current knowledge gaps that may prevent the proper application of LCA in this field, and offers recommendations on the application of LCA for assessing the potential environmental impacts of nanotechnology, nanomaterials, and nanoproducts.

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In a March 15, 2007, letter, the Senate Committee on Commerce, Science, and Transportation and the Congressional Nanotechnology Caucus requested that the Government Accountability Office (GAO) review the National Nanotechnology Initiative (NNI), which was created to accelerate the discovery, development, and deployment of nanoscale science and technology. For fiscal year 2006, NNI received $1.2 billion in research and development funding, and 22 federal agencies, including the U.S. Environmental Protection Agency (EPA), the Food and Drug Administration (FDA), the Consumer Product Safety Commission (CPSC), and the Occupational Safety and Health Administration (OSHA), participate in NNI. According to the letter, one key expectation for NNI was “to ensure that adequate attention and research funding was made available to gain a better understanding of the potential environmental, health, and safety (EHS) risks associated with nanomaterials.” The letter states that the Committee and Caucus “are extremely concerned that this has not happened and that there is a lack of transparency with regard to how much federal attention and funding this important aspect of the initiative is receiving.”

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