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