The Royal Society and Royal Academy of Engineering study on nanotechnology
Comments from Friends of the Earth
Technological innovations at the nano scale raise environmental, health and safety,
ethical, economic, social, strategic and scientific questions. All of these need
to be carefully examined in order to craft public policy and regulatory frameworks
that will minimise or eliminate risk. We advocate a precautionary approach based
on clearly identified needs (not an open ended application of insufficiently tested
technology on the basis of assumed ultimate benefits).
More specifically, we urge the study to address the following points:
Environmental:
The manipulation of molecules to manufacture genetic material, including novel
self-replicating substances with no equivalent in nature, poses many risks. What
are these risks, how real are they now (given that one company has already built
a fifth nucleotide base unknown in nature) and who is regulating them? What other
environmental risks are posed through nanotech applications, either now or in
the foreseeable future?
Safety:
Ultra small particles appear to have inherent toxic properties. What is the state
of knowledge in this area, especially in relation to products (such as sunscreens)
that already contain nano-particles? In the case of carbon nanotubes there is
a mixed body of evidence on their safety with the suggestion that under some circumstances
they can cause similar effects to asbestos fibres. How can the real effects be
best assessed before product development? There are no common procedures concerning
lab or other safety measures in nanotech research. This is clearly unwise, what
should be done? Also, what are the potential liabilities arising from the use
of these technologies and who would be liable in the event of harm to people or
the environment? What level of scrutiny would be required to demonstrate the safety
or otherwise of the use of technological applications at the nano scale?
Ethics:
Patents are now being granted on a wide range of nano matter innovations. A range
of ethical questions are raised by this trend. In some respects these issues are
even more fundamental than those linked to patents on life (these are patents
on nature). What will be an adequate political process to deal with these issues?
What are the real priorities: Should official research resources go into these
novel technological areas in the theoretical expectation that they will combat
poverty and protect the environment, or should there be more focus on existing
(and grossly underfunded) programmes that promote social justice and environmental
sustainability?
Control and public oversight:
The present research agenda in the nanotech fields is dominated by military and
industrial interests. What public oversight is there of public funding decisions
in support of these interests? Whatever the research focus, what regulatory bodies
or other bodies in the UK are equipped with adequate expertise and staff capacity
to regulate this emerging area? Related to this question, what changes in national,
EU and global regulations would be required to ensure effective risk management
of nano technologies and products? What changes in national, EU and global regulations
would be required to ensure the UK could adopt a precautionary approach toward
the research and development of nanotechnologies and their use in products in
this country?
Who will benefit:
Nanotech is already presented as a source of wealth, development and prosperity
and another means to fight poverty. How will this be the case given that the technology
is (and will be) under the control of developed country companies located in high-tech
clusters, protected by patents, backed with venture capital, supported with government
research funding and aided by various infrastructure advantages? What will be
done to prevent yet another technological divide between the rich and poor worlds?
As novel nanotech applications displace more traditional industries (including
in the developing countries), what will be the social impacts of displacement
in terms of unemployment and so on?
Monopolistic enterprise:
The convergence of IT, biotech, atomic manipulation and artificial intelligence
disciplines is seen as offering exciting synergies. Will the convergence of companies
from these different industrial sectors create yet larger corporations with even
greater economic and political influence? If so, how can their impacts be effectively
regulated. Linked to this is the potential to enhance the power of already massive
military complexes (the USA in particular see below). Personal freedom: There
is clear potential for nano applications to enable the widespread and cheap surveillance
of individuals. There is also the potential for far faster genetic profiling and
other applications that will invade privacy. There is the potential to enhance
commercial strategies through the nano-tracking of products. What are the implications
of these potential applications of nanotech and how can they be effectively regulated?
Military:
Control of nanotech applications for military purposes will confer huge advantages
on those countries who possess them. The implications of this for world security
will be considerable. The military uses of nano scale technology could create
awesome weapons of mass destruction. Is it desirable or necessary to develop such
weapons given the already overwhelming might held by the USA in particular? What
are the prospects for the effective monitoring of nano weapons?
All of these questions must be answered in advance of policy development. Our
experience suggests that the failure to grasp these issues at an early stage of
public scrutiny will create considerable challenges and difficulties for policy
makers later on. Friends of the Earth will closely monitor developments in technology
at the nano scale and looks forward to reviewing your conclusions in due course.
Tony Juniper, Executive Director, Friends of the Earth England, Wales and Northern
Ireland and Vice Chair Friends of the Earth International
June 19th 2003