Ten years ago, President Clinton laid the foundation stone of the current global Nanotechnology Initiative.  In a speech given at at Caltech, he announced the formation of the US National Nanotechnology Initiative, and set a chain of events in motion that has led to economies and businesses around the world investing in the technology of the small.  A decade on, nanotechnology is a multi-billion dollar research and development enterprise, is touted as holding the promise of reviving economies, creating jobs and solving global challenges, and is already adding to the performance and value of innumerable products.

Against this backdrop, the UK Government has just released its first a new strategy for the successful and safe development of nanotechnology – or nanotechnologies to be precise. [See update for why this isn’t the first strategy]

I was interested to read the strategy, having just finished helping to review the US National Nanotechnology Initiative for the President’s Council of Advisers on Science and Technology (the PCAST review of the NNI is due to be published shortly).  The UK has had a strong presence in the nanotechnology arena for some years, combined with a pragmatic approach to technology development. So I was expectant of a strong and sensible strategy that mapped out how the country planned to be a key player in the “next industrial revolution.”

Sadly, I was disappointed.

At the risk of boring readers, I’m going to include somewhat detailed comments on the strategy below.  But here are my headline reflections:

• Successful nanotechnologies need strategic investment in science. The strategy focuses on three key areas: exploiting nanotechnology breakthroughs commercially, addressing potential health, safety and environmental impacts, and regulating the technology and its products.  However, there is no specific emphasis on exploratory science. The implicit assumption is that the machinery of knowledge generation – funding for exploratory research, and the expertise to generate new knowledge – is in place.  But this is a very rash assumption indeed.  Without strategic investment in funding exploratory nanoscale science, especially at the interface between disciplines, the UK is likely to loose out to other countries that recognize the need to drive innovation through knowledge creation.  The US and China in particular are steaming ahead here – without a clear research strategy, the UK is destined to become marginalized.
• Innovation begets innovation. While the strategy addresses the commercial exploitation of nanotechnology in general terms, it stops short of considering how innovative new approaches can be used to get innovative new technologies to market – including alternative financing models, new ways of enabling technology transfer, and overcoming institutional barriers to change.
• Risk and regulation cannot drive an effective nanotechnologies strategy. I’m a strong advocate of dealing with the potential adverse impacts of nanotechnologies.  But developing a national nanotechnologies strategy that is two thirds-focused on understanding and addressing potential risks seems a little over the top, even to me!  Strategic risk-research and responsive oversight are absolutely essential to the safe and sustained development of nanotechnology-based products and processes.  But in the broader context, they should support the overall aims of improving quality of life, stimulating economic growth and providing jobs – not be the heart and soul of the whole enterprise.
• Nanotechnologies risk research isn’t just about reassuring people that products are safe. Despite a heavy emphasis on risk and regulation, the strategy seems to reflect a somewhat naive understanding of why research into potential risks, handling uncertainty and developing responsive oversight is important.  Repeatedly, the need to reassure “the public” that the products they buy are safe is highlighted as an important driver.  But how about the need of businesses to develop and market products responsibly?  Many businesses that have a culture (or are developing one ) of placing a high priority on producing safe and responsible products are desperate for better information on how to do this with nanotech-enabled products.  Yet it’s telling that the UK strategy has no clear link between environmental, health and safety research and business, industry and innovation.
• Strategies should be built on sound data. There are a number of places in the report where the data are suspect – especially in the section dealing with business, industry and innovation.  At the least, I would expect a Government-level report to get the facts right.  For instance, it is claimed that the UK is fourth in the world in terms of the number of nanotechnology patents applied for, after the US, Japan and Germany.  Yet the latest figures – published last year – show the UK ranking 11th in terms of the number of patents filed in the country (in 2008, 68 nanotechnology patents were filed in the UK, compared to 3,729 in the US and 5,030 in China.  That’s around 0.5% of all nanotechnology patents filed in 2008).  The report also estimates “the global market in nano-enabled products is expected to grow from $2.3 bn in 2007 to $81 bn in 2015,” yet the basis for these figures is not explained (they come from a report that will set you back $6,000 if you want to read it!).  These figures seem very low – especially compared to estimates of between $1 trillion and $3 trillion from other sources for the future worth of products based in some way on nanotechnology.  In effect, the UK Government figures are meaningless without further explanation.  And if they are correct, I have to wonder why governments and industry around the world are investing tens of billions of dollars in a technology that is only going to be worth… tens of billions of dollars!
• If you are going to form a Nanotechnology Research Strategy Group, make sure their scope extends beyond just addressing risks. I have to applaud the UK strategy for listing a sensible set of nanotechnology environmental, health and safety research priorities (Appendix A of the report).  But to make these THE research priorities of the Nanotechnology Research Strategy Group – that just send a message that the UK government is only interested in potential risks.  Changing the name of the group might be a good idea!
• Resist the temptation to include past activities as strategic actions. Call me a pedant, but I do find it frustrating where a strategy includes stuff that has already been done in its list of actions.  It smacks of padding things out, rather than looking forward to what needs to be done, and how.  Actions 3.3 – 3.6, just for example, refer to activities already underway – nothing particularly strategic about that!
• Don’t confuse toxicology with risk science.  There are three action points in the report (3.14 – 3.16) specifically aimed at developing the UK’s toxicology skills base.  This is good – it should be developed.  But so should expertise in exposure assessment, risk assessment, risk management, handling uncertainty and oversight.  Sadly, the strategy seems to assume that toxicology is the be-all and end-all of risk identification, assessment and management, whereas in reality it is only one component.
• If you are going to reach out to members of the public, take it seriously. In 2009 BIS supported what is possibly the best lay source of information on nanotechnologies – Nano & Me.  But rather than praising the initiative and supporting it, the UK strategy is rather less than luke-warm.  According to the strategy, the website has completed its 5 months (5 months?!) trial period, and will now be evaluated – that’s it.  This effort needs to be run longer – much longer.  It needs to be funded better.  And it needs to be promoted by the Government, not treated like an embarrassing relative.

So all in all, not a great strategy.  It’s not all bad – there are strengths in what the UK has done and intends to do in developing safe and successful nanotechnologies.  But as a strategy, this would have been flaky five years ago, and is now positively threadbare.

In a global climate where economies are eying one another up to see who’s going to take the lead in nanotechnology, I’m afraid the strategy sends a clear message – don’t worry about us!

__________________________________________

Some more specific observations

1. In the executive summary (p4), there is no mention of supporting research in nanoscience that will lead to innovation in nanotechnologies.
2. Nanotechnologies are described as being “at a very early stage in their development” (p6).  After a ten-year global push and many previous years’ research into nanoscale science, together with a wealth of nanotech-enabled products on the market, this is a dubious statement at best.
3. I’m wondering when we will see “more compact and powerful computer systems, mobile phones and wiring systems incorporating carbon nanotubes” (p6) – unless it’s just the wiring systems that will use the nanotubes.  Very unclear.
4. I’ve already questioned the projection of the global market in nano-enabled goods as $81 bn in 2015 above.
5. Apparently, the UK also has the third highest number of nanotechnologies companies in the world.  Wow!  Which countries are leading us – the US, China, Japan, Korea, Germany perhaps?  Take your pick – although I’m not sure how you will tell if you are correct, as no source was given for the claim.
6. A tricky point in any report like this is explaining what nanotechnologies are.  I’d love to know what others thought of the explanation in Box 1 (p6), which gets close to mixing and matching nanotechnologies, nanomaterials and nanoparticles.  I was confused!
7. I’ve already addressed the question of nanotechnology patents above.  Why the report didn’t cite Dang et al. I don’t know!
8. On page 7 the report states “At present, it is thought that the greatest level of risk may be posed by nanomaterials which are in the form of free particles, such as in a powder or liquid.”  This was a conclusion of the 2005 Royal Society/Royal Academy of Engineers report on nanotechnologies, and is still important.  But over the past five years, perspectives have developed and become a little more sophisticated, recognizing the need to consider how new materials might come into contact with and interact with people and the environment, rather than fixating on nanoparticles.
9. This I found interesting:  On page 9 it is stated that “Above all, it is Government’s role to protect health and the environment during the development and use of nanotechnologies.”  This possibly explains the emphasis on risk and regulation in the strategy.
10. Figure 1 in the report shows the linkages between the four different areas of the strategy.  But as mentioned above, there is no direct linkage between environmental, health and safety research, and business, industry and innovation.  I would argue that two-way links here are absolutely essential to responsible development.
11. Here’s a recurring theme in the strategy. On page 11 one challenge to the commercialization of nanotechnologies listed is “A need for industry to engage with the public in order to raise awareness of the benefits of nanotechnologies-based products, and to counter any negative perceptions or concerns” (emphasis added).  I’m sorry, this is not what public engagement is all about.  In fact, in the light of this, I’m embarrassed to have applauded the UK’s approaches to public engagement and science last week – clearly there are some communication disconnects between departments!
12. On page 15, in reading about a lack of critical mass amongst small nanotech businesses in the UK, and a lack of business leadership, I was wondering where the Nanotechnology Industry Alliance was… Surely these small businesses aren’t voiceless.
13. Page 21 lists some good research into nanotechnology environmental, health and safety issues carried out in the UK. Unless I have missed something, they are all associated with a group of researcher based in Edinburgh. Should this have been called the Scottish Nanotechnologies Strategy?
14. However, on the same page an important study into the the potential health impacts of long carbon nanotubes is credited to Ken Donaldson – Graig Poland, not Ken, was the lead author.  This sort of mistake should not occur in a report like this one!
15. I’ve already mentioned the strange name of the group established to focus on nanotechnology environmental, health and safety research above (p 22) – the Nanotechnologies Research Strategy Group.  Wonder if the UK has a shadow group looking at non-environmental, health and safety research.
16. I’ve also covered the emphasis on toxicology above, but this is so important that it’s worth mentioning again.  On page 26 the report states “A shortage of new toxicologists was identified in RCEP’s report in 2008 as a risk to the nanotechnologies field, as toxicology research is pivotal to the successful development of new materials and products.”  Looking over that RCEP report, it had a strong emphasis on toxicology which at the time was not out of place.  But the UK strategy seems to have taken one recommendation from that report and run with it, to the exclusion of every other aspect of risk identification, assessment and management.  I’m not sure what the opposite of a strategy is, but this would qualify in my books.  Strategic action towards developing safe and responsible nanotechnologies must address all aspects of risk – not just material hazard.
17. On page 27, the strategy sets out the four key areas where “nanomaterials are most likely to come into contact with humans, or the environment”: Food; Cosmetics; Healthcare devices and medicines; and Workplace health and safety.  These are all very reasonable.  But what about all the other strategic areas – products which might shed nanomaterials while being used; products that lead to inadvertent exposure; products that release nanomaterials when disposed of or recycled; products that children might chew on or ingest, and so on.  Restricting the strategy to these four areas seems, well, restrictive.
18. Following up on those medical devices and medicines, there’s no mention of the regulatory challenges presented by combination products – products that act as both a device and a medicine.  Maybe this isn’t an issue in the UK – it’s certainly one in the US.
19. When it comes to the workplace, I was intrigued to see that “there are no current plans for any specific guidance on risk management for materials other than carbon nanotubes.”  Why?  Businesses and researchers are desperate for clear guidance on working safely with nanomaterials, which is why organizations such as NIOSH, ICON and ISO have been so active in the area.  The good news is that, even if the UK government isn’t intending to provide useful information for working with nanomaterials in the immediate future, others are filling the gap.

Update, 3/18/10  When this piece was first posted, I mistakenly referred to the strategy as the UK’s first nanotechnology strategy – a perception that the report itself does nothing to dispel.  However, as Michael Kenward kindly pointed out in the comments, this is in fact the UK’s second nanotechnology strategy (as long as you don’t nit-pick over differences between “nanotechnology” and “nanotechnologies.”).  The original strategy – published in 2002 – is available here Strangely, the current strategy does not acknowledge the existence of its predecessor. [PDF, 422 KB].