Feedback from Michele Mekel and Nigel Cameron

Center on Nanotechnology and Society

Posted on: March 28, 2007

Dear Scott and Terry,

On behalf of Nigel Cameron and myself at the Center on Nanotechnology and Society, please accept our congratulations on the Environmental Defense-DuPont Nano Risk Framework, a very important initiative.

As to our comments, it is clearly a valuable general boilerplate/template document for nano risk management. As a first effort in the area, it does a commendable job of pointing out the ways in which nano is different, and how the template will require tweaking, updating, and tailoring. It also offers an appealing step-by-step approach, complete with useful diagrams and worksheets.

The only caveats we have to add are the following:

• Endorsement by the standards organizations, insurers (such as Swiss Re), the International Risk Governance Council, the NanoBusiness Alliance, ICON, and other industry leaders with key constituents seems necessary for broad uptake and adoption.
• Many nano companies are small startups, and the framework seems too time-, personnel- and resource-intensive for them to adopt, at least meaningfully and effectively.
• While the framework explicitly acknowledges that it does not address the ethical, legal and social implications (ELSI) of nanotechnology, the framework seems to lack an acknowledgement of how closely tied real and perceived and EHS and ELSI risks are for an emerging technology, such as nanotechnology.
• Finally, as spoken by a lawyer, the framework seems to bring legal review and legal considerations in a bit late.

Again, congratulations on a tremendous effort. If we can be of any assistance in the future, please don't hesitate to contact us.

Michele Mekel, J.D., MHA, MBA
Executive Director & Fellow
Institute on Biotechnology and the Human Future
(http://www.thehumanfuture.org/)
Associate Director
Center on Nanotechnology and Society
(http://www.nano-and-society.org/)
Illinois Institute of Technology/Chicago-Kent College of Law