We are responding to the Royal Society’s request for initial views on the study on nanotechnology that the Royal Society and the Royal Academy of Engineering will be conducting. We welcome the announcement of the study and wish to register our interest and draw attention to issues of relevance to consumers.

The NCC campaigns on behalf of consumers and has a particular remit to represent the views of disadvantaged consumers. One of our five main areas in which we are working is ‘science and technology that can service consumer needs and aspirations’. We have been developing and promoting a more consumer-focussed model of risk governance. We have also conducted a major piece of consumer research that has examined consumers’ views on risk (Running Risks, NCC, 2002). Our model of risk governance highlights the need for openness and consumer consultation, particularly where there is scientific uncertainty or controversy and to ensure that consumers’ concerns and values are understood and valued and that their interests are taken into account from an early stage in the development and decision-making relating to science and technological developments.

Therefore we wish to highlight the need for consumer representation on the working group on nanotechnology. OST guidelines recognise the value of such expertise on scientific advisory committees.

We also suggest that consideration be given to ways of working that are both open and consultative. We welcome this call for initial views but suggest that there would also be considerable value in issuing a draft report for consultation prior to publishing a final report. Not only would this allow wider peer review but could also enhance public debate. We strongly advocate public debate and dialogue about new technological developments and would welcome the use of consultation methodologies that seek such engagement. We consider that such an approach would enhance public trust and confidence and would be willing to offer our expertise.

We welcome the scope of the review that includes consideration of not just health, safety and environmental impacts, but also ethical and social issues surrounding the development of this technology. We would also like to highlight the need to consider the impact on consumers – both in terms of potential risks and benefits – and the impact of any developments on consumer choice, access or issues of equity. Consumers are not a homogeneous group and developments should not disadvantage particular groups of consumers.

In assessing potential benefits for consumers we believe it is important to include a ‘reality check’ to assess whether claimed benefits are likely to be realisable. We can perhaps learn from the debate about new genetic technologies where developments in GM crop technology have to date failed to deliver benefits for consumers or those benefits are some way off and/or uncertain.

We suggest that it may be over ambitious at this stage of knowledge and in the timeframe envisaged for this study to be able to fully assess the potential health, safety and environmental impacts of the applications of nanotechnology – particularly where there are uncertainties. Rather, we consider it may be more useful to identify criteria and mechanisms for making such assessments and ways and means of addressing gaps in knowledge.

I hope these comments are useful and we would be willing to discuss these further with you if this would be helpful.

Yours sincerely

Sue Dibb
Senior Policy Officer
National Consumer Council
UK
www.ncc.org.uk