Increasing the number and scope of nanotechnology applications requires developing methods and tools that will facilitate assessing and communicating risk associated with nanomaterial applications. The Environmental Defense – DuPont’s Framework – is clearly an important document that provides a set of procedures that will be useful to government agencies as well as to industry. However, the framework relies on qualitative methods and tools for information, aggregation, and evaluation. It is basically a descriptive discussion of individual facts and features associated with nanomaterials. Thus the proposed approach may not comply with the requirements of a quantitative risk assessment, or a transparent and reproducible decision analysis associated with risk management, which is required under the current federal guidance and desired by stakeholders. Moreover, one must not overlook the wide array of factors involved in managing nanomaterial development, which ranges from the technical specifications of the material, to the possible adverse effects in humans.
To meet the challenge of conducting risk assessment and risk communication in situations with a limited knowledge-base, and a high uncertainty, we and others (Linkov et al., 2006a) advocate the use of multi-criteria decision analysis (MCDA). MCDA is a robust discipline with a developed set of tools that are quite useful for the issues discussed in the framework. Specifically, MCDA tools are useful in illustrating and justifying decisions at the analytical depth and appropriateness of advanced risk assessment tools (such as probabilistic risk assessment) required for implementing individual projects. Multiple publications are available on the use of MCDA tools (e.g., Figueira et al., 2005), and have been applied to various topics (Linkov et al., 2006a, 2006b).
Our paper on “Multi-Criteria Decision Analysis and Environmental Risk Assessment for Nanomaterials” (Linkov et al., 2007) combines state-of-the-art research in MCDA methods applicable to nanotechnology, with a hypothetical case study for nanomaterial management. The case study shows how the application of MCDA can balance societal benefits against unintended side effects and risks It also details how MCDA can bring together multiple lines of evidence to estimate the likely toxicity and risk of nanomaterials with limited information on physical and chemical properties. The essential contribution of MCDA is to link this performance information with decision criteria and weightings elicited from scientists and managers, allowing visualization and quantification of the trade-offs involved in the decision-making process. I believe consideration of these approaches could be of value for the committee.
In summary, The Environmental Defense – DuPont’s Framework – could be strengthened if it were supplemented with a transparent and justifiable decision-making framework. The disciplines of multi-criteria decision analysis, value of information analysis, and adaptive management could be complementary to the risk assessment and communication procedures discussed in the document.
Igor Linkov
Managing Scientist
Intertox Inc
Figueira J, Greco S, Ehrgott M, editors. (2005). Multiple criteria decision analysis: State of the art surveys. New York (NY): Springer.
Linkov, I., Satterstrom, K., Kiker, Batchelor, C., G., Bridges, T. (2006a). From Comparative Risk Assessment to Multi-Criteria Decision Analysis and Adaptive Management: Recent Developments and Applications. Environment International 32: 1072-1093.
Linkov, I., Satterstrom, K., Seager, T.P., Kiker, G., Bridges, T., D. Belluck, A. Meyer (2006b). "Multi-Criteria Decision Analysis: Comprehensive Decision Analysis Tool for Risk Management of Contaminated Sediments". Risk Analysis 26:61-78.
Linkov, I., Satterstrom, K., Steevens, J., Ferguson, E., Pleus, R. 2007, in press. Multi-criteria Decision Analysis and Nanotechnology Journal of Nanoparticle Research. http://www.springerlink.com/content/6m445835280r0520/?p=e721e14db82e477d93abcccffe203b12&pi=0