Scheme 1. Methodology of the pilot study for the benchmarking process of the responsible NanoCode
Figure 2. A section of the interviewee version of the Evaluation Framework Questionnaire
A useful mnemonic to reflect the Code’s key factors is noted below:-
NanoCode promotes best practise by the following 7 guiding principles;
Accountability of the Board for managing their nanotechnology.
Nanotechnology stakeholders are to be identified & their concerns met.
Occupational health & safety of all workers to be of a high standard throughout
the lifecycle of the product(s).
Carry out thorough risk assessments & minimise any potential public health, safety and environmental risks.
Organisation to consider & address the wider social, environmental, health & ethical issues of their nanotechnology.
Develop the open engagement of business partners with the NanoCode.
Ensure an organisation is transparent about its nanotechnologies and how it adopts the Responsible NanoCode.
EXAMPLES OF GOVERNMENTAL RESPONSES TO NANOTECHNOLOGY
The responses of governments to nanomaterials varies [7], for example, Canada has announced a mandatory safety reporting scheme for companies producing nanomaterials, becoming the first country in the world to do so. Companies and institutions that manufactured or imported more than 1kg of a nanomaterial in 2008 will be required to submit all of the information they have - physical and chemical properties, toxicological data, and methods of manufacture and use. In the USA, the Environmental Protection Agency (EPA) considers many nanomaterials as chemical substances and, as such, they are subject to the standard regulatory practices under environmental law. Two notable exceptions are fullerenes and carbon nanotubes.
In the UK, a Mini Innovation and Growth Team comprising representatives from several Knowledge Transfer Networks prepared a report called “Nanotechnology: a UK Industry View” [8], which collected issues and concerns from the UK nanotechnology industry and academia and produced a series of recommendations for the UK Government, focussing on where it was believed that Government could make a significant difference. The Responsible NanoCode was referenced in this report which was presented to the UK Government in January 2010.
The report has formed part of an evidence collecting process prior to the Government launching its UK Nanotechnologies Strategy: Small Technologies, Great Opportunities which was launched on 18th March 2010 [9]. This Strategy sets out how Government will take action to ensure that UK residents can safely benefit from the societal and economic opportunities that nanotechnologies offer, whilst addressing the challenges that they might present.
In a recent report on Nanotechnologies and Food [10], the House of Lords Science and Technology Committee recommended ‘that the Government, in collaboration with relevant stakeholders, support the development of voluntary codes of conduct for nanotechnologies in order to assist the continuing development of effective legislation for this rapidly emerging technology. The Government should work to ensure that voluntary codes are of a high standard, are subject to effective monitoring processes and are transparent.’ This comment from the House of Lords Committee has therefore endorsed the value of a voluntary code such as the Responsible NanoCode.
BENCHMARKING THE RESPONSIBLE NANOCODE
Cranfield University were appointed to progress this initiative by benchmarking the Responsible Nanocode (Scheme 1). This has involved interviewing companies and academics to gather information and to find demonstrable evidence of compliance covering their accountability, stakeholder relationship, worker health and safety, health, safety and environmental risks (non-worker), wider social, environmental, health and ethical issues, engaging with business partners, transparency and disclosure.
This benchmarking project has illuminated any knowledge gaps concerning for example health and safety, human or environmental exposure and ethical issues. Identifying such knowledge gaps greatly assists the development of robust methods for the ecotoxicity and environmental hazard assessment of manufactured nanoparticles under realistic scenarios.
The aim of this benchmarking project has been to interact closely with the developing nanotechnology industry to try and proactively address concerns and reinforce good practices and thereby help evolve the voluntary, principles-based Code of Conduct to a point where it will be adopted by businesses across the supply chain.
BENCHMARKING STUDIES
Benchmarking the Responsible NanoCode sought to ensure that the research and development as well as industrial application of nanotechnologies are performed in a transparent and responsible manner throughout organisations. These include:
• Research laboratories (including universities) • Small and medium enterprises • Large manufacturers
• Retailers and branded goods companies
The benchmarking activity provided an awareness of the risk maturity issues surrounding nanotechnology and provides an example of good practice for industry and research within the UK and EU.
The pilot study focused on both the testing and refining of the evaluation frameworks developed by the working group, to ensure the code is appropriate for a range of organisations. This pilot study involved a series of face to face interviews with a range of organisations and this process naturally helped to improve the evaluation frameworks (Figure 2). In parallel, the collection and analysis of data gathered in the benchmarking interviews provides a picture of the practices among nanotechnology organisations in the UK.
A copy of a typical evaluation questionnaire is available at
http://www.cranfield.ac.uk/sas/risk/nanocode/
Although this pilot study was limited in scope, it was interesting to note that senior executives from the companies benchmarked valued participating in the process and one was quoted as saying ‘this has reinforced our efforts on addressing the key issues related to safe manufacture and use of nanomaterials and helped us focus on best practices.’
CONCLUSIONS
The Responsible NanoCode was developed by a working party comprising large and small companies, academics, NGOs and unions and provides a very simple model for the responsible management of a nanotechnology-based business. Its acceptance by the nanotechnology industry is both encouraging and demonstrative of its potential for large and small companies alike.
The benchmarking process at Cranfield (
www.cranfield.ac.uk/sas/risk/nanocode) provides endorsement for companies and aids the continuous improvement within these companies.
References [1] (a) The Nanotechnology Report, 4th Edition, 2006 (Lux Research); (b) P. J. A. Borm and D. Berube, A tale of opportunities, uncertainties, and risks, Nano Today, 2008, 3, 56 – 59.
[2] (a) S. Rocks, S. Pollard, R. Dorey, L. Levy, P. Harrison and R. Handy, Comparison of risk assessment approaches for manufactured nanomaterials, May 2008, Defra CB403 ; (b) A. Helland, M. Scheringer, M. Siegrist, H. Kastenholz, A. Wiek, and R.W. Scholz, Risk assessment of engineered nanomaterials: A survey of industrial approaches, Environmental science & technology, 2008, 42, 640. [3] (a)
S.T.Stern and
S.E.McNeil, Nanotechnology safety concerns revisited, Toxicological Sciences, 2008, 101, 4-21; (b) G Oberdörster, V Stone and K Donaldson, Nanotoxicology, 2007, 1, 2
[4] (a) M. Auffin, J. Rose, J.-Y. Bottero, G. V. Lowry, J.-P. Jolivet and M. R. Wiesner, Towards a definition of inorganic nanoparticles from an environmental, health and safety perspective, Nature Nanotech., 2009, 4, 634; (b) R. D. Handy, R. Owen and E. Valsami-Jones, The ecotoxicology of nanoparticles and nanomaterials: Current status, knowledge gaps, challenges, and future needs, Ecotoxicology, 2008, 17, 315 -325. [5] A. Grobe, O. Renn, A. Jaeger and D. Gmbh, Risk Governance of Nanotechnology Applications in Food and Cosmetics, Report for the International Risk Governance Council, Geneva, September 2008. [6] Nanoscience and nanotechnologies: Opportunities and Uncertainties, The Royal Society and The Royal Academy of Engineering, London, 2004. [7] A. Fairbrother and J. R. Fairbrother, Are environmental regulations keeping up with innovation? A case study of the nanotechnology industry, Ecotoxicology and Environmental Safety, 2009, 72, 1327–1330. [8] Nanotechnology: a UK Industry View, January 2010. A report from a Mini Innovation & Growth Team on Nanotechnology [9]
http://www.bis.gov.uk/assets/biscore/corporate/docs/n/10-825-nanotechnologies-strategy [10] See the List of Recommendations and Conclusions at
http://www.publications.parliament.uk/pa/ld200910/ldselect/ldsctech/22/2202.htm [11] M. Crane, R. D. Handy, J. Garrod and R. Owen, Ecotoxicity test methods and environmental hazard assessment for engineered nanoparticles, Ecotoxicology, 2008, 17, 421 – 437.
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