ALDES is an association of professional engineers and scientists in the Liberal Democrats. We exist to try to ensure that our party, where relevant, develops policy on a secure scientific basis. We try to provide accurate information and to balance the pros and cons of science based matters in as fair a way as possible. In so doing, we find ourselves from time to time seeking to counter ill informed criticism of science and technology. However, any influence we have depends on being consistently as well informed as possible.

We are therefore responding to your call in the Royal Academy of Engineering’s press release of 11th June to raise some concerns, to put forward some suggestions and to understand more fully what is being done in the emerging field of nanotechnology.

We start from a position that scientists have a clear duty to try to expand knowledge. At the same time we believe they have an ethical duty to concentrate on those areas of science that are most likely to bring benefits to mankind. Given, however, that any step into the unknown can carry risk we believe they also have a duty of care, and indeed ultimately a financial interest, in ensuring that potential benefits do not come at too great a price to, for example, health or the environment.

Taking this last condition further means that scientific research really needs to proceed on a ‘twin track’ basis. Any move forward needs to be balanced by a resolve to identify possible hazards at the same time. For example it is immediately clear that nano sized particles are likely to be colloidal in air and one would expect therefore that they could be taken deep into the lungs. This may or may not be a problem, or may be a problem with some particles but not others. A ‘twin track’ approach would require parallel research of this potential hazard with, inevitably, associated costs and perhaps delays.

Some potential risks will be relatively obvious but others not so. There is always likely to be an element of unpredictability: in the case of nanotechnology that very small sized particles might behave differently to larger ones. We understand this has already occurred with so-called ‘buckyballs’. The possibility of unpredictability is not a reason to stop research, but it does require that someone, somewhere is made responsible for exercising vigilance.

We are aware that research is already regulated and understand that laboratory research comes under the Health and Safety Executive’s remit. This sounds comforting at first but it is very difficult to see how HSE inspectors can be as ‘expert’ in all the new fields they are expected to cover as the leading edge researchers in those fields. Indeed, even setting up a specialist unit within the HSE may leave staff struggling to keep up. Moreover a ‘watching brief’ is never so exciting as being on the front line and may not be sufficiently attractive to people of the highest calibre. It seems to us that the onus has to be on the researchers themselves and built into the framework of their reporting structure. In other words researchers should be required to have considered and to report on potential hazards at each stage of their work, and the company, university, or grant giving body should have built into its funding a contingency for the expense of any ‘parallel’ research.

We do not expect this will remove all risk. That does not worry us. All we would wish is that as much is done as possible to minimise the risk.

Lastly we are grimly aware, from our experience in the muddy field of politics, that the fact that innovative research is already extensively regulated is actually of little value unless the public as a whole is aware that it is being done and have confidence in the regulation. It is difficult to see for example how the development of GM crops could have been more comprehensively regulated, yet wild assertions which led to, for example, the Frankenfood headlines have been left unchallenged. The GM regulators have gone about their work capably, conscientiously but, unhappily, silently and invisibly as far as the public is concerned. Whatever form of regulation you recommend in the field of nanotechnology we would urge that its brief include that of being an authoritative public commentator. The Foods Standards Authority has made an encouraging start in their field of regulation.

We hope these comments are useful. If we have raised matters that have already been dealt with we would be grateful to learn the outcome. If not, we would welcome a reply in due course. If you propose to publish a series of progress reports we would be very grateful to be included on your circulation list.

We would wish you every success for your study.

Yours sincerely

Richard Balmer
Hon Secretary ALDES