Feedback from NIA

Nanotechnology Industries Association

Posted on: March 30, 2007

Introduction to the NIA

Formed in 2005, the Nanotechnology Industries Association (NIA) creates a clear single voice to represent the diverse industries’ views in the multi-stakeholder debate on nanotechnology, by providing an interface with government, acting as a source for consultation on regulation and standards, communicating the benefits of nanotechnologies and interacting with the media to ensure an ongoing advancement and commercialization of nanotechnologies.

The unique feature of the NIA is that it provides a purely industry-led perspective derived from the views of the collective membership, which is made up of many varied companies all at different stages of their life cycle and with a variety of interests in the huge range of technologies that derive their benefit from the nanoscale. This enables those seeking comment from industry to have a single point of entry to the industry and avoids the need to approach individual companies for statements on specific issues. In addition the breadth of the membership enables the NIA to put forward strong proposals to government and regulatory authorities to promote an environment that supports the application and utilisation of nanotechnologies. Initial aims of the association are:

• promoting the responsible use of nanotechnology and raising awareness of its many applications in an unbiased way among key audiences within the UK,
• generating position statements and papers in areas relevant to its members and providing responses to consultations exercises,
• technology foresight exercises examining current products, developments and future applications of nanotechnologies with an industry-based perspective on the risk-based classification of emerging technologies including nanotechnology, which is linked to a new hazard assessment methodology as the current project,
• working closely with regulators to represent the interests of the NIA to ensure the future of nanotechnology is secured and to realise its full potential,
• encouraging and stimulating industry participation and support for nanotechnology, and
• providing a forum for discussing topics of relevance to its members.

The NIA is currently working together with various regulatory bodies and governmental departments and committees; ongoing interactions include:

1. participation in the BIAC (Business and Industry Advisory Committee to the OECD) Nanotechnology Network,
2. participation in the OECD WPMN (Working Party on Manufactured Nanomaterials) Steering Groups 2 and 6, and the OECD CSTP (Committee for Scientific and Technological Policy),
3. active support of the UK Government’s Voluntary Reporting Scheme for Engineered Nanoscale Materials (conducted by DEFRA) by offering its members assistance with the completion of the required data sheet,
4. participation in selected meetings of the ISO/BSI nanotechnology standards working groups, The Nanotechnology Stakeholder group, the NRCG Task Forces, the NEG (Nanotechnology Engagement Group), and the UK Government’s CST (Council of Science and Technology) Nanotechnology Review, and
5. ongoing communication with equivalent organisations and governmental departments in other countries. For further information visit http://www.nanotechia.co.uk.

Comment

The NIA congratulates the Environmental Defense – DuPont Nano Partnership on the development of a Framework for ensuring the responsible development of nanoscale materials that can be widely used by companies and other organisations. The draft framework provides timely support in the identification of the prevailing issues in the debate of the potential risks of nanotechnologies, as well as indicating valuable strategies for the mitigation of these risks.

A particularly valuable aspect of the framework is its information-driven remit, which makes it a valuable tool for the continuing assessment of nanomaterials’ properties, while the suggested adoption of ‘reasonable worst-case assumptions’ in the absence of guiding information provides a responsible approach to further research, development and exploitation of novel engineered nanomaterials.

The NIA welcome’s the summary of ‘Familiar Elements’ (page 6) in the Draft Framework, because this put into context the Framework’s background paradigm and outlines its applicability to other data-gathering exercises. However, it would have been beneficial to specifically mention any overlap between Steps 1 and 2 of the Framework and any past, current or planned industrial voluntary reporting schemes (VRS) of engineered nanomaterials, such as those formerly conducted by NICNAS (Australian National Industrial Chemicals Notification and Assessment Scheme) and by the BfR (German Federal Institute for Occupational Safety and Health) and the VCI (German Chemical Industry Association), the one currently conducted by DEFRA (UK Government Department for Environment, Food and Rural Affairs), as well as those planned by the EPA and the OECD WPMN SG2.

The compilation of the necessary information and entry into the appropriate Framework Output Worksheet is a labour-intensive effort, which bears particular problems for small companies that don’t have dedicated safety officers to look after this matter and can sometimes cause the abstention of otherwise supportive companies.

Based on its experience in actively supporting DEFRA’s VRS, the NIA therefore strongly recommends to clarify if Sections 1 and 2 of the Framework Output Worksheet can be resubmitted to any existing or planned VRS without major changes, and, in case this overlap had not already been accounted for, to facilitate the transformation of the complied data into the targeted scheme. This provision would not only save time and effort, but also indicate strong interconnectivity between organisations and provide another incentive for nanotechnology companies to participate in both the Framework and the VRS.

The Environmental Defense – DuPont Nano Risk Framework represents a timely and well-structured initiative to secure the advancement of nanotechnology in a responsible way; in order to aid its implementation, however, significant support structures must be provided to ensure that all companies, large and small, will be able to afford the conduct of an appropriate suite of tests that will generate a consistent set of data to meet the expectations of the authorities or the NGOs, and to minimise potential burden on SMEs if the range of tests suggested were ever to become mandatory or even recommended by the regulatory authorities.

Dr Steffi Friedrichs
Director
Nanotechnology Industries Association