On November 12th 2008, the 27th report of the British Royal Commission on Environmental Pollution (RCEP) focusing on ‘Novel Materials in the Environment: The case of nanotechnology’ was launched.
The Commission was established by a royal warrant back in February 1970, and its role has continued to be one to advise the British government and parliament on matters, both national and international, concerning the pollution of the environment, the adequacy of research in this field, and the future possibilities of danger to the environment. The commission defines itself as a ‘committee of experts’, composed of individuals educated in natural science, law, social science, industry, business, medicine and economy.
This 27th report is raising the highly topical matter of nanomaterial use versus human and environmental safety. It follows an earlier report published in 2004, by the Royal Society, the UK national academy of science and the Royal Academy of Engineering. Attendees from a wide spectrum including the UK Department for Environment, Food and Rural Affairs (DEFRA), the Royal Society, The Parliamentary Office of Science and Technology (POST) and others were present.
Professor Sir John Lawton, chairman of the RCEP, presented the report's findings and recommendations, stressing the fact that ‘it is not sensible to concentrate just on the size of nanomaterials. It is the functionality, what they do, how they behave that really matters’. Nanotechnology and the production of nanomaterials is an extremely fast growing field, in which a variety of scientific disciplines support the development of a number of technologies for the fabrication of nanomaterials, which then serve many different economic sectors, from electronics and textiles to the food industry and cosmetics. According to Sir Lawton, ‘the Woodrow Wilson center in the US has a database of over 600 products that are self identified by the manufacturers worldwide as containing nanomaterials’ and they are widely used. Nanomaterials are for instance present in the self cleaning glass used on the roof of Saint Pancras train station in London. Nanomaterials also have huge scope in being used as drug delivery systems, targeting with an exquisite presicion the region to treat.
While organisms have been exposed to a wide variety of naturally-occurring nanoparticles during evolutionary history (volcanic emissions, dust, viruses, pollen), most of them dealing very effectively with nanoparticles, there is a worry that manufactured nanomaterials with enhanced specific properties very different from the properties of the bulk material might exceed the ability of our defence systems.
Even if we do not find any evidence that nanomaterials cause harm to our health or the environment, Sir Lawton expressed, on behalf of the commission, a concern regarding the safe use of C60, nanosilver and carbon nanotubes. ‘The risk may never be perceived unless significant impacts are discovered and this could take a decade and probably more to be apparent.’
While it has clearly been expressed that there is no need for a blanket ban or a moratorium, Sir Lawton insisted on the fact that ‘we really do need as a matter of urgency a major increase in the research effort to prioritise and look at those nanomaterials’. We are currently lacking data on toxicology and ecotoxicology, and no consensus has been reached on how to address this issue. Moreover, there is virtually no information on the long term effects of exposure to nanomaterials and the environmental monitoring is currently impossible or extremely difficult to conduct.
Surprisingly, despite all these research gaps and uncertainties, no special regulation is needed. The European Union regulation concerning the Registration, Evaluation, Authorisation and restriction of CHemicals (REACH) can in practical terms deal with the regulation of nanomaterials, but in practice, a weight threshold of 1 T/manufacturer/year prevents nanomaterials from falling into these regulations. The commission therefore proposes a compulsory checklist as part of an early warning system for manufacturers and insists on the fact that DEFRA should make nanomaterials reporting compulsory, stressing the reason and benefits behind the use of nanomaterials. Monitoring should be the responsibility of the various envrionment agencies in England and Wales, Scotland and Northern Ireland. More training is also needed for ecotoxicologists, as to date, the efforts to characterise toxicology are disproportionately small compared to the investments in developing new nanomaterials. If we are already facing some regulation and ethical issues in the use of nanomaterials, despite over 600 of them being currently used in various sectors including the food industry and cosmetics, it is the more sophisticated, later generation of nanoproducts that may raise issues that we will not be able to capture by treating them as simple chemicals or mixtures of chemicals.
We have to move from a one-off public engagement project to a continual social intelligence gathering.