Nanotechnology - Some Issues for the Royal Society/ Royal Academy of Engineering.

The ETC Group is grateful for the opportunity to summarize our perspective on the issues which should be addressed in the Royal Society and Royal Academy of Engineering preliminary review of nanotechnology. The ETC Group is an international not-for-profit civil society organization with offices in Oxford, Mexico, USA, and Canada. Since 1977, the ETC Group has undertaken research and advocacy on the socio-economic and environmental impact of new technologies affecting rural societies. In 1999, after a decade of informal monitoring, the ETC Group, with its partner organizations around the world, began targeted research and analysis of this set of new technologies. Since then, we have co-organized seminars on nanotechnology for civil society organizations and government officials on five continents as well as co-hosting an international seminar for global civil society. A list of our major publications in this field is attached.

We welcome the involvement of these learned societies in studying nanotechnology. Such an evaluation is long overdue. Although a few governments and scientific institutions have undertaken partial and superficial studies related to the socio-economic, environmental, or health implications of nanotechnology, each of these studies has suffered either from a narrow single issue orientation and/or from a highly-confined science-based focus that has excluded social perspectives and sidestepped public participation. The Royal Society and the Royal Academy of Engineering have an opportunity to correct these shortcomings and to create a model process that can engage the public, professionals and policy-makers in a constructive consideration of this major new technological revolution.

R&D and Revolution: The scope and intensity of the working group’s investigation should be commensurate with the predicted impact of nanotechnologies on society. There is broad agreement that nanotechnologies portend the greatest economic revolution the world has ever seen. Even conservative estimates for the use of nanoparticles suggest a major transformation that will affect economic development, employment, trade, the environment, and human health and well being. This being the case, the first and central task of the working group must be to describe an appropriate multi-year process for societal discourse and to recommend specific steps to ensure maximum participation in the evaluation of this set of technologies.

Process and Participation: Therefore, in the year allotted for its initial appraisal, the Royal Society and the Royal Academy of Engineering should see their own processes as an experimental model which the government can learn from when it undertakes a fuller, wider, and longer societal discussion that will be necessary before nanotechnology’s ultimate role can be determined. ETC Group does not believe however that review and evaluation process should forstall clear regulation and control, rather aid and improve it.

Without in any way constraining the breadth of the working group’s exploratory process, it is obvious that the full and informed participation of all sectors of society will be absolutely necessary. It is particularly important that those social groups who will be most impacted by the new technologies must be actively involved in the review and analysis. Among such groups, we include women, the poor, racial and ethnic minorities, the disabled rights movement, trade unions and workers, farmers and other basic producers. However, because nanotechnologies will have a major impact on production and trade, the evaluation must also include the views of developing countries and of countries-in-transition. Beyond the initial process of study and preliminary recommendations, it is essential for the working group to propose a mechanism for ongoing research and monitoring and to recommend continuing opportunities for public participation in the years ahead. It is clearly not enough to give a technology either a “red” or “green” light and then abandon it to its own devices. Such a powerful set of technologies will require ongoing research and monitoring by all

Science and Scope: As much as nanoparticles represent a vast technological revolution in themselves, it would be wrong to narrow the working group’s investigation to this limited field. The pace of research is such that developments now thought to be impossible could prove to be less than a generation away - and developments believed to be two or three decades distant could (via breakthroughs) be upon us within a few years. Thus, the implications of molecular self-assembly (the “gray goo” and “green goo” scenarios) must be considered. Further, the proposed investigation should review all developments at the
mesoscale (that uncertain zone between classical and quantum physics) as well as at the nanoscale including developments in biotechnology (nanobiotechnology), neurosciences, and biomemetics. We would encourage the working group to take heed of developments in micro-electronic microsystems (MEMS) since these are on the same minaturisation trend as
nanodevices and raise some of the same societal and ethical questions. The working group should also consider and take a view on the strategy being explored by the U.S. National Science Foundation on Converging Technologies (Nano, Bio, Info, Cogno) since this approach comes together at the nanoscale.

Safety and Environment: . ETC group recently commissioned a literature survey by toxicopathologist Dr Vyvyan Howard (University of Liverpool) on the human health impacts of nanoparticles and would direct the working group to our paper on this matter “Size matters” as a useful starting point. This also summarizes our views with regard to need for clear laboratory protocols and an interim moratorium on handling and use of nanoparticles. While these are the most often referred to areas of investigation, the ETC Group also wishes to emphasize the importance of evaluating such heretofore unexplored areas as the possible impact of exposure to nanoparticles for an unborn fetus and the short and long term implications of new nanotechnologies on agriculture and biological diversity. We particularly would ask the working group to evaluate the plans of the US Department of Agriculture with regard to applying nanotechnology to the food chain, assessing not only safety but also implications for food security, farmers rights and the direction of agriculture.

Concentration and Control: The history of past industrial revolutions makes it clear that such transformations create not only new corporate entities but new commercial and technological platforms and convergences that can radically transform society, employment, and trade. New technologies usually encourage broad-spectrum intellectual property claims and develop new monopoly mechanisms that can have a major dampening effect on the pace and type of innovations being developed by the scientific community. Ethical and equity issues ? in the market place and in society ? must also be evaluated. So too must questions of liability ? both for economic, health and environmental damage that may arise in the future.Defense and Democracy: As is evident from the number of national patent claims and funding trends, nanotechnology’s potential in warfare and defense is enormous. We also note that the UK Home Secretary intends to apply nanotechnology to crime reduction and indeed there is an upcoming conference on this matter in London in October. Many of the near-term applications relate to sensors and monitoring devices that have the potential both to make society safer and to stifle social dissent and disable democracy. These implications demand the widest and most careful societal discussion.

Health and Humanity: Even some of the near-term implications of new nanotechnologies for human health and humanity are quite remarkable. Many of the initiatives blur the distinction between “nano”, “bio” and “cogno” and propose forms of human performance enhancement that raise profound ethical questions for humanity and, in particular, for the disabled movement. ETC group can refer the working group to those who have expertise in this regard. Indeed, these technologies raise fundamental questions about the nature and definition of humanity. It is vital that the so-called “targets” of these technologies have a clear and informed voice in this discussion and that their right to say “no” ? without negative social repercussions ? be recognized as a human right. Can a society that is unclear about what it means to be a human being make responsible decisions about technologies that purport to enhance our human potential?

The Role of the ETC Group: The ETC Group is prepared to work with the Royal Society and the Royal Academy of Engineering in each of these areas of investigation and stands ready to provide additional research information and to participate in any appropriate way to encourage the widest possible participatory process during this initial review year.

Yours respectfully,

Jim Thomas
European Programme Manager,
ETC Group

ETC Group’s Publications in this Field.
These are all available from our website

The Big Down: Atomtech - Technologies Converging at the Nano-scale
(80 page document), Date: January 30, 2003

Nanotech Un-gooed! Is the Grey/Green Goo Brouhaha the Industry's Second
Date: May 16, 2003

Nanotech and the Precautionary Prince
Date: May 2, 2003

Size Matters! And The Case for a Global Moratorium
Date: April 14, 2003

The Little BANG Theory
Date: February 6, 2003

Green Goo: Nanotechnology Comes Alive!
Date: January 23, 2003

No Small Matter! Nanotech Particles Penetrate Living Cells and
Accumulate in Animal Organs


I appreciate that you are still in the process of selecting the working group and so would very much want to emphasise the obvious point that the composition of the board will be seen by civil society groups and the public as something of a barometer as to how independent and broad-thinking the working group's report is likely to be. As you are no doubt well aware the role of the Royal Society in the GMO debate has attracted civil society concerns about impartiality that are likely to persist unless there is a clear indication that things are being done differently this time. Recognising that the issues raised by nanotechnology are not simply science issues and drawing in working group members from outside natural sciences and industrial engineering would be a welcome first step.

In particular given the claims nanotech industry is making for society - that it will cure disability, increase military and industrial power, and advance sustainable development - I would think it was particularly essential to have working group members able to robustly examine these claims:

The first four of of which would naturally fall outside of the natural sciences
reperesented by your two societies.

I also mentioned to you on the phone that it would be very helpful for transparency sake if any industrial interests of members of the working group were openly declared from the beginning and am glad to hear you were considering this already. I notice for example that Professor Dowling is closely allied with the aerospace industry who heavily invest in nanotechnology but that this wasn't mentioned in the initial announcement. Industrial capture of science is of course a very sensitive subject and one that will probably emerge quite strongly amongst civil society concerns. I trust therefore that the Royal Society and the Royal Academy of Engineering will be careful to maintain distance and independence in the composition of this important working group.

Jim Thomas
Programme Manager
Action Group on Erosion, Technology and Concentration (ETC Group)