NNI Seeks Public Comment On Nano EHS Research Priorities

Posted on August 21, 2007 by Patrick T. Lewis

Small Times is reporting that the National Nanotechnology Coordination Office at NNI is requesting public comment, until September 17, 2007, on its proposed  "Prioritization of Environmental, Health and Safety Research Needs for Engineered Nanoscale Materials:  An Interim Document For Public Comment." 

According to the Small Times article,

"The comment period is an opportunity for public input into the prioritization of research and information needs related to environmental, health, and safety aspects of nanomaterials," groups note, adding that the research priorities will be an important part of the NNI EHS research strategy, which will be used by the Federal agencies to support research within their mission areas.

The NNCO established 25 research priorities.  However, to make the list more manageable, it broke the 25 priorities into five broad categories.  Overall, I like the approach the government is taking on these research priorities.  They are asking the right questions about (1) how engineered nanomaterials interact with biological systems and the environment, (2) how to measure exposure to nanomaterials -- both in workers and to the general public, and (3) what impact nanomaterial exposure has on health.  The report also calls for risk management to be a research priority.

 These are NNCO's five proposed categories:

Instrumentation, Metrology, and Analytical Methods

The priority research needs for this category provide an integrated approach essential to understanding, predicting, and quantifying the chemical and physical properties and behavior of nanomaterials.  The priorities under this research category underpin, and are fundamental to, all five categories of EHS research and information needs.

Nanomaterials and Human Health

Research on human health often involves complex, interrelated scientific concepts that are investigated most efficiently by a parallel, rather than serial, research paradigm. This parallel structure permits the investigation of single or integrated research questions and the leveraging of progress in related areas. Evaluation of the human health research needs against this paradigm and the value-of-information principle led to identification of an overarching research priority. The task force identified five broad research needs that are critical to addressing this overarching priority and to establishing the fundamental principles for nanomaterial interactions with living systems. Overarching Research Priority: Understand generalizable characteristics of nanomaterials in relation to toxicity in biological systems.

Nanomaterials and the Environment

The priority research needs for this category represent those that were presented in the EHS Research Needs document, with revisions to ensure complete coverage of environmental issues.

Health and Environmental Exposure Assessment

Research in this category is aimed at assessing exposure to, rather than hazards of, nanomaterials * * *.  The priority research needs for this category identify work to enable the collection of exposure information. Data collection should group individuals into exposure categories and relate groups potentially exposed to nanomaterials, including workers, patients, consumers, and neighbors of production or utilization plants. * * * Information on the process, task, and location variables should be evaluated to understand how nanomaterials behave in workplace environments and what factors determine the exposures to nanomaterials in such environments.

Risk Management Methods

The many research needs for this category, as identified in the EHS Research Needs document, were grouped by the risk management methods task force into five broad research needs, which were then prioritized. The broad research needs are listed below, ranked from highest to lowest priority. The task force recognized one of the research needs identified in the EHS Research needs document as encompassing the overarching research priority for this category. Overarching Research Priority: Evaluate the appropriateness and effectiveness of current and emerging risk management approaches for identifying those nanomaterials with the greatest potential risks.
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Reminder: Comments Sought by US EPA on Nanoscale Materials Stewardship Program

Posted on August 9, 2007 by Michael E. Heintz

Just a reminder to those interested in commenting on US EPA's draft documents concerning the Nanoscale Materials Stewardship Program (NMSP): comments are due to the Agency on or before September 10, 2007. 

US EPA is seeking comments on three draft publications: the "Concept Paper for the Nanoscale Materials Stewardship Program under TSCA, " the "TSCA Inventory Status of Nanoscale Substances - General Approach," and the Information Collection Request (ICR) in Support of EPA’s Stewardship Program for Nanoscale Materials.

The full text of all three can be found here.

Specifically, EPA is seeking comments on the following:

    1. Whether the data elements that have been identified in the NMSP are appropriate for nanoscale materials;
    1. Timing and phasing of submissions under the NMSP basic and in-depth programs and whether approaches for tiering data submissions are appropriate;
    1. Who would participate in the NMSP and how to encourage participation, especially from small and medium sized enterprises;
    1. What criteria to use for NMSP program evaluation and views on the timing and nature of any reports the Agency may issue; 
    1. How to engage industry and other stakeholders in the NMSP in-depth program and approaches for generating test data;
    1. The processes and roles for EPA, participants, and other stakeholders during development and evaluation of data for the in-depth program;
    1. Possible approaches for identification and use of alternative sources of data, in order to minimize the burden of information collection associated with the NMSP;
    1. Uses for the data submitted to EPA under the NMSP program; 
    1. Issues relevant to scope, definitions and descriptions;
    1. The suitability of the approach for determining the TSCA Inventory status of nanoscale materials discussed in the Inventory paper; and,
    1. Whether, in combination, the TSCA Inventory paper and the NMSP concept paper are sufficiently clear in how EPA plans at this time to address nanoscale materials that are new or existing chemicals under TSCA and the NMSP.
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