It is hard to figure how the Office of Science and Technology Policy (OSTP) and the Council on Environmental Quality (CEQ) could have gotten it so wrong in publishing a memorandum on Principles for Nanotechnology Environmental, Health, and Safety Oversight, except of course to recognize that the first principle may be to serve the “free market” ideology.
The memorandum lists six areas that should serve as the principles for EHS oversight
(Purpose, Current Understanding, Information Development, Risk Assessment and Risk Management, International, and Regulatory Path Forward).
Bizarrely in the first area “Purpose”, the critical dimension of protecting human health and the environment gets relegated to second fiddle behind being “cognizant of the potential benefits of nanotechnology, including health, economic and environmental benefits”.
What are they thinking? Sure, it is important to recognize the benefits of nanotechnology, but only as they balance the threats that may or may not exist to human health and the environment.
Unfortunately, this can’t be chalked up to just poor writing, let’s give them more credit than that. No, instead this is the result of a strongly held belief that going forward in addressing EHS concerns from nanotechnology, the overriding principle is to not impede nanotechnology’s development.
The pity of this is that they have a point. It’s hard to argue to throw out the baby with bathwater when addressing health concerns about nanotechnology by just suspending all nanotechnology development.
But they have clearly misplaced their principles. Health and safety are first, preserving the so-called “nanotechnology industry” is further down the list, if on it at all.
