The Royal Commission on Environmental Pollution report on Novel Materials
Imagine for one naïve moment that we have a pretty good handle on managing the environmental impact of existing manufactured “stuff”. Then someone comes along and invents some “new stuff” that behaves very differently from the “old stuff.”
How can we be sure that the frameworks and mechanisms in place for preventing harm to the environment will work for the new stuff? And where they are strained to breaking point, how do we go about fixing the system?
These are two questions addressed in a new report from the Royal Commission on Environmental Pollution—an independent British standing body established in 1970 to advise the Queen, government, Parliament and the public on environmental issues… Of course, because this is for the Her Majesty The Queen, phrases like “old stuff” and “new stuff” are conspicuous by their absence in the report—which instead addressed the rather more sophisticated-sounding issue of “Novel Materials in the Environment.”
This is, in effect, a report on the challenges of avoiding adverse environmental impacts of engineered nanomaterials. Coming four years after the seminal report from the Royal Society and Royal Academy of Engineering on nanoscience and nanotechnologies, it reflects both how thinking on the challenges and opportunities presented by engineered nanomaterials has advanced, and actions to ensure their safe use have not!
The report itself draws on extensive interviews with experts around the world, and the depth and quality of the writing reflects this. Perhaps not surprisingly, many of the recommendations arising from this process will be familiar to readers—the challenges haven’t changed that much over the years, and solutions still seem few and far between in many cases.
But familiar as many (not all) of the recommendations are, they are still important to the sustainable development of emerging nanotechnologies, and bear re-iterating.
And there are three in particular that are worth calling out:
Functionality: we need to focus on the properties and functionalities of speciﬁc nanomaterials as the key driver rather than treat all materials in the size range as one single class.
To my mind, this is the single most important conclusion to arise from the report. It moves the debate on environmental impact away from generic nanomaterials—an ill-defined class of materials that have no unifying impact-relevant characteristics—towards materials that present unconventional risks due to novel behaviour. This is a smart move, as it opens the door to addressing materials that have the potential to cause harm in ways that are not covered by conventional understanding, and avoids endless (and usually fruitless) discussions on what defines a nanomaterial.
Essentially, the Royal Commission have stated that it is not what you call a material that is important, but what it does.
Of course, there is still the issue of what defines a “novel material.” While I’m sure this will be debated to death in certain quarters, here are some pointers from the report. Novel materials are:
- New materials hitherto unused or rarely used on an industrial scale, such as certain metallic elements (e.g. rhodium, yttrium, etc.) and compounds derived from them;
- new forms of existing materials with characteristics that differ signiﬁcantly from familiar or naturally-occurring forms (e.g. nanoforms of silver and gold that exhibit signiﬁcant chemical reactivity, enhanced biocidal properties or other properties not manifest in the bulk form);
- new applications for existing materials or existing technological products formulated in a new way, which may lead to substantially different exposures and hazards from those encountered in past uses (e.g. the use of cerium oxide as a fuel additive); and
- new pathways and destinations for familiar materials that may enter the environment in forms different from their manufacture and envisaged use (e.g. microscopic plastic particles arising from mechanical action in marine ecosystems).
Information: we need to establish directed research programme on the properties and functionalities of materials in order to inform risk assessment and risk management strategies.
There’s nothing new here. The Royal Society and Royal Academy of Engineering said as much in 2004, and I have gone on record repeatedly stressing the need for strategic research programmes. But the fact that the Royal Commission on Environmental Pollution pulled this out as one of their three main priorities highlights how little is still being achieved in this area.
Maybe this time, someone will listen.
Adaptive management: we need to recognise the degree of ignorance and uncertainty and the time it will take to address these (insofar as they can be addressed). We also need to develop ﬂexible and resilient forms of adaptive management to allow us to handle such difficult situations and emergent technologies.
Whichever way you look at things, conventional approaches to risk assessment and management are unlikely to work in the short term for novel materials.
Materials that behave in unconventional ways will always be developed faster than a deep knowledge of how they interact with and impact on human health and the environment. And any attempt to avoid managing risks until a full and complete conventional risk assessment has been conducted will jeopardize innovation, people’s health and the environment. This doesn’t mean that quantitative risk assessment needs to be abandoned—it is still the best tool we have for making evidence-based decisions on reducing and managing potential harm. But in the short term, novel approaches are needed to managing risks, to avoid undue harm without stifling innovation.
For instance, if you are manufacturing carbon nanotubes, you cannot wait ten years for government agencies to set hard and fast exposure limits—you need guidance now on effective ways to reduce potential risks if you are to have a hope of getting viable products out of the door. And that means taking unconventional approaches to establishing pragmatic, flexible acceptable exposure levels that are based on the best available information.
The results may not be as robust as what regulators will come up with in several years’ time. But I can guarantee that they will help the manufacturer protect the workforce without being crippled by unnecessary investment in control and containment technologies.
This is just one example of where flexible and resilient forms of adaptive management can both protect people and the environment while enabling the sustainable use of novel materials—there are many more.
And as the Royal Commission recognizes, the increasing pace of innovation means that such innovative approaches to risk management are going to become more and more important.
We recommend that it is desirable to move beyond one-off public engagement ‘projects’ to recognise the importance of continual ‘social intelligence’ gathering and the provision of ongoing opportunities for public and expert reﬂection and debate. We see these functions as crucial if, as a society, we are to proceed to develop new technologies in the face of many unknowns.
This is a specific recommendation in the report rather than an overarching recommendation (as the first three points were). But it is worth highlighting, because the interplay between society, science and technology is only going to get more complex over the coming years. And the sustainable development of any new technology is going to have to factor in new directions in the “democratization of science and technology.”
Overall, this is an important report, and one that should be taken seriously. It represents an evolution in thinking rather than a step-change (with perhaps the exception of re-framing the debate over nanomaterials in terms of novel materials). But nevertheless it makes clear recommendations that are essential to the safe and successful use of engineered nanomaterials.
But back to the “stuff.” ‘New stuff” (novel materials) is essential to solving global challenges that the “old stuff” we have to hand simply cannot handle. And these are big challenges that include renewable energy, global warming, water purification and disease treatment. But as the Royal Commission on Environmental Pollution implies, new stuff requires new ways of doing business if we are going to see the benefits while avoiding potential pit-falls.
And at the end of the day, this means thinking innovatively about research, risk management and reaching out to citizens and other stakeholders.