Royal Society and Royal Academy of Engineering Working Group on Nanotechnology

Comments from GeneWatch UK
July 2003

GeneWatch UK is a not-for-profit public interest group. Our aims are to ensure that genetic technologies are developed and used in the public interest and in a way which promotes human health, protects the environment and respects human rights and the interests of animals. Ensuring public involvement in the decisions that are made about if or how genetic technologies are used is an important goal.

Our interest in nanotechnology is two fold. Firstly, we believe there are lessons to be learnt from the introduction of genetic technologies which could usefully inform the development of nanotechnology – particularly in the way in which the public have a role in shaping the research agenda. Secondly, we have concerns about how nanotechnology may intersect with biotechnology and the social, environmental, health and other consequences of this.

We are grateful for this opportunity to comment and hope these observations will helpful as the Group develops its study. The issues we consider the Working Group should address include:

1. Intellectual property rights and nanotechnology - currently this is not clearly a part of the Working Group’s agenda and yet experience in the field of genetics shows that it may cause considerable problems. Whilst it can be argued that inventors have a legitimate right not to have their inventions copied, if the scope of monopoly rights is too wide or discoveries, fundamental knowledge and basic techniques are patented, innovation will be stifled. This has quite clearly been the case in genetics (see Nuffield Council on Bioethics (2002) The Ethics of Patenting DNA: A Discussion Paper. July 2002) and it would be wise to ensure that such mistakes are not repeated with nanotechnology.

2. Nano- hype – there is considerable hype surrounding the potential for nanotechnology. This is partly to justify the increases in funding and partly to draw in investment from the private sector. This is the same scenario that was seen with biotechnology, both in the medical and GM crop arenas. It does nothing to generate a mature debate and will eventually fuel cynicism about unfulfilled promises. Equally, it is not possible to characterise fundamental questioning of nanotechnology as irrational when the claims for it are couched in revolutionary terms. When examining the claims for nanotechnology and its increasing political and economic support, GeneWatch also believes the Working Group should consider what the opportunity costs are for other areas of research and innovation which will not gain funding as a result.

3. The public and nanotech research – one of the major problems encountered with the use of GM in agriculture has been that official and scientific framings of the risks have been at odds with those of the public and NGOs in which they have more confidence (see e.g. Mayer S J, Hill J. Grove-White R & Wynne B (1996) 'Uncertainty, Precaution and Decision-Making: The Release of GMOs into the Environment' - a report on three seminars. ESRC Global Environmental Change Series Briefing; Grove-White, R., Macnaghten, P., Mayer, S. & Wynne, B. (1997) Uncertain World: genetically modified organisms, food and public attitudes in Britain. Centre for the Study of Environmental Change: Lancaster University). Narrow the definition of the risks to directly linked physical effects was not accepted as an adequate approach. Recent research also shows how experts and regulators have misunderstood the nature of public concerns (see Marris et al (2001) Public Attitudes to Biotechnology in Europe and highlights how this can lead to inappropriate policy responses. Therefore, understanding how public attitudes might evolve in relation to nanotechnology and what will shape them is a key piece of research that needs to be undertaken if the same mismatches are not to arise as have occurred with biotechnology. In addition, the findings of such research needs to be integrated into the Research Councils’ agendas – to ensure the appropriate research questions are asked in relation to safety and that the overall direction of research is likely to have public confidence. The Working Group could usefully examine how this might be done by calling on, for example, the experiences of NICE and the Alzheimer’s Society in drawing in lay people into complex discussions about research agendas and resource allocation.

4. Comparative assessments need to be undertaken – it will not be possible to assess with any degree of accuracy the social, environmental, health and safety implications of the various applications of nanotechnology. Rather than using conventional risk assessment and cost-benefit analyses, GeneWatch suggests that the Working Group examines the potential of other methodologies to compare across options and which have the flexibility to work with a wide range of different criteria including social and ethical as well as human and environmental safety. These include techniques such as multi-criteria mapping and evaluation (see e.g. Stirling, A & Mayer, S. (2001) Multi-criteria mapping the genetically modified crop debate: A pilot study of a genetically modified crop in the UK. Environment and Planning C: Environment and Planning C 19: 529-555). Such techniques can also indicate the dimensions of uncertainty where possible.

Genewatch UK