A Research Strategy for Environmental, Health, and Safety Aspects of Engineered Nanomaterials (2012)

Chapter: 6 Implementing the Research Strategy and Evaluating Progress

Previous Chapter: 5 Research Priorities and Resource Needs
Suggested Citation: "6 Implementing the Research Strategy and Evaluating Progress." National Research Council. 2012. A Research Strategy for Environmental, Health, and Safety Aspects of Engineered Nanomaterials. Washington, DC: The National Academies Press. doi: 10.17226/13347.

6


Implementing the Research Strategy and Evaluating Progress

INTRODUCTION

This report has articulated the rationale for an environmental, health, and safety (EHS) risk-research strategy related to engineered nanomaterials (ENMs) (Chapter 1) and proposed a conceptual framework for addressing EHS risks (Figure 2-1). Chapter 3 summarized the current state of the science and high-priority data gaps on the potential EHS risks posed by ENMs. Chapter 4 described the fundamental tools and approaches needed to pursue an EHS risk research strategy. Chapter 5 presented the committee’s proposed research agenda, short-term and long-term research priorities, and estimates of needed resources.

This chapter focuses on implementation of the research strategy and evaluation of its progress, elements that the committee considered integral to its charge. It envisions a strategy that is fully integrated and coordinated, that addresses short-term and long-term needs, and that evolves as information is gleaned and progress is made. It places the discussion of Chapters 3-5 into the context of this broader vision. The present chapter also addresses the following core components that reflect elements identified in the 2009 National Research Council report (NRC 2009) as necessary for implementing an effective research strategy:

Infrastructure for implementation and accountability: Two distinct types of new or expanded infrastructure are needed for implementing the strategy: expansion of institutional arrangements, including interagency coordination, stakeholder engagement, public-private partnerships, and management of potential conflicts of interest; and mechanisms for integrating informatics and information-sharing into the research structure.

Evaluation of research progress and revision of the strategy: A critical element of an effective research strategy is the inclusion of processes for evalua-

Suggested Citation: "6 Implementing the Research Strategy and Evaluating Progress." National Research Council. 2012. A Research Strategy for Environmental, Health, and Safety Aspects of Engineered Nanomaterials. Washington, DC: The National Academies Press. doi: 10.17226/13347.

tion of progress in relation to the goals of the strategy and for refinement and adaptation of the strategy as the information base evolves and drives the need for change.

Resources needed to conduct research and implement the strategy: An integral part of an effective strategy is a means for continuing assessment of resources for conducting the research and for implementing the strategy. That includes assessing the adequacy of current resources, how they are to be deployed, and how additional resources would best be acquired and used.

Key audiences for implementing the strategy: The strategy should effectively consider and integrate the needs of and appropriate roles for the full array of stakeholders involved in implementing the strategy or concerned with its outcomes. These stakeholders include the National Nanotechnology Initiative (NNI) and the federal agencies within its structure; the private sector, including nanomaterial developers and users; consumers; and the broader scientific community, including academic researchers and non-governmental organizations.

Many of the questions posed in formulating a strategy for research on nanomaterials are equally applicable to strategies that might be developed for other emerging technologies. Lack of knowledge and high degrees of uncertainty, with a rapidly changing landscape of perceived risks and benefits, are inherent in the rollout of any new technology. As with nanomaterial research, there are likely to be challenges in developing common protocols for a community of researchers that turns its attention to the evaluation of the environmental and health implications of any new technology and seeks to compare the results of research among laboratories. For those reasons, the proposed research strategy can be considered a model approach for developing a strategy that examines the risks produced by other emerging technologies.

INFRASTRUCTURE FOR IMPLEMENTATION AND ACCOUNTABILITY

Mechanisms for effective implementation of an EHS research strategy are just as essential to its success as is the substance of the identified research, a key finding in NRC (2009). Questions that must be grappled with include the following: What are the most effective approaches to achieving the stated goals? How will research efforts be coordinated to ensure a coherent approach to achieving the stated goals? What mechanisms and approaches are in place or could be created to enable interdisciplinary research that crosses established funding and agency boundaries and to foster effective coordination and partnerships?

As noted in Chapter 1, the committee acknowledges the contribution that the NNI has made toward implementation (NEHI 20101, Chapter 8). Most nota-

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1A final version of the strategy was published in October 2011 (NEHI 2011a). Because the committee’s report had already gone to peer review, NEHI (2011a) was not reviewed by this committee.

Suggested Citation: "6 Implementing the Research Strategy and Evaluating Progress." National Research Council. 2012. A Research Strategy for Environmental, Health, and Safety Aspects of Engineered Nanomaterials. Washington, DC: The National Academies Press. doi: 10.17226/13347.

bly, through the naming of the National Nanotechnology Coordination Office (NNCO) Coordinator for EHS, the Office of Science and Technology Policy (OSTP) has vested leadership and a measure of accountability for EHS research. This NNCO EHS coordinator is charged with leading efforts to integrate nanotechnology EHS research, to identify and leverage domestic and international collaborations, and to serve as the NNI point of contact for stakeholders on nanotechnology EHS issues (NEHI 2010). The Nanotechnology Environmental Health Implications (NEHI) working group (NEHI 2010) also calls on NNI agencies to explore and exploit new media and networking opportunities to improve interagency communication and stakeholder interaction, to develop new mechanisms for NNI agencies to partner with industry, to facilitate “development of joint programs among NNI agencies to fund EHS research of mutual interest and avoid unproductive redundancy” (p. 78), to expand work in data storage and management, and to “develop and maintain data communication infrastructures and organization” (p.79).

The committee lays out below implementation needs of two major kinds: institutional arrangements and informatics and information-sharing. The discussion includes models and means to address the key needs and provide accountability to the broader community of stakeholders.

Institutional Arrangements

As noted earlier, to ensure successful implementation of a research strategy, accountability must be integral to the strategy’s development and execution. There are numerous dimensions of accountability:

•  Ensuring and assigning ownership of the overall strategy.

•  Establishing appropriate means of governance among parties implementing the strategy.

•  Establishing and applying mechanisms for accomplishing exploratory, translational, and targeted research in the context of the strategy, including an appropriate balance between government and private-sector funding and facilitating needed or desired interdisciplinary research.

•  Assigning responsibility for executing elements of the strategy.

•  Ensuring that stakeholders are involved in and have substantive input into formulating and reviewing the strategy.

•  Monitoring progress in comparison with elaborated research goals and timelines to ensure that the strategy is conducted effectively and efficiently and to ensure that responsible parties are held accountable for the extent of research progress.

•  Coordinating periodic review and revisions to the strategy.

•  Ensuring that sufficient resources are devoted to conducting the needed research and to implementing the overall strategy and allocating and managing the resources.

Suggested Citation: "6 Implementing the Research Strategy and Evaluating Progress." National Research Council. 2012. A Research Strategy for Environmental, Health, and Safety Aspects of Engineered Nanomaterials. Washington, DC: The National Academies Press. doi: 10.17226/13347.

•  Managing potential or perceived conflicts of interest resulting from the dual missions of the federal government in nanotechnology—investment in the development and commercialization of nanotechnology and in ensuring its safety.

•  Ensuring wide dissemination of research results to decision-makers and other stakeholders.

This section discusses the needs for and approaches to providing accountability in implementing the strategy in four categories: enhancing interagency coordination, providing for stakeholder engagement in the research strategy and its revision, conducting and communicating the results of research funded through public-private partnerships, and managing potential conflicts of interest. The committee’s conclusions in the four areas also are presented.

Enhancing Interagency Coordination

A shortcoming identified in the 2009 National Research Council report was the inadequacy of mechanisms in the NNI structure to ensure accountability for implementation of the research strategy. This problem reflects the largely coordinating and information-sharing roles of the NNI and of the primary body in the NNI that addresses environmental health and safety issues, the Nanoscale Science, Engineering and Technology (NSET) Subcommittee’s NEHI. NEHI’s mission includes (NEHI 2011b)

•  “Providing for information exchange among Federal agencies that support nanotechnology research…;

•  “Facilitating the identification, prioritization, and implementation of research and other activities required for the responsible research necessary to develop, use, and oversee nanotechnology;

•  “Promoting communication of information related to research on environmental, health, and safety implications of nanotechnology;

•  “Adaptively managing (i.e., coordinating, reviewing, and revising) the interagency EHS research strategy…;

•  “Assisting in developing information and strategies as a basis for drafting guidance in the safe handling and use of nanomaterials and products;

•  “With input from NSET and other interagency groups, supporting the development of tools and methods to identify, prioritize, and manage strategies for specific research to enable risk analysis and regulatory decision-making for nanomaterials and products incorporating nanomaterials [emphasis added].”

Those “bottom-up” functions—interagency coordination, information exchange, facilitation, and communication—clearly are important and necessary. However, they are insufficient to ensure the degree of accountability needed to develop and execute a national EHS research strategy (NRC 2009, pp. 47-49).

Suggested Citation: "6 Implementing the Research Strategy and Evaluating Progress." National Research Council. 2012. A Research Strategy for Environmental, Health, and Safety Aspects of Engineered Nanomaterials. Washington, DC: The National Academies Press. doi: 10.17226/13347.

NEHI’s function needs to be supplemented with a “top-down” authority to direct and oversee the EHS research budgets and associated activities within and among NNI agencies and between government and the private sector (Denison 2007a, p. 4).

As discussed previously, OSTP’s naming of an NNCO EHS coordinator is a step in this direction. However, as the title of the position suggests, the role of the coordinator stops short of the needed “top-down” authority inasmuch as the role is to “ensure effective communication and coordination of the NNI… and of agency EHS R&D efforts and integration of these efforts with the NNI Strategy for Nanotechnology-Related EHS Research (Nanowerk News 2010).” Hence, it appears that the new position principally formalizes and raises the role and function already served by NEHI rather than creating an entity with additional budget and oversight authority.

Various models have been proposed and others might be considered to provide greater authority. One model envisioned under the proposed “NNI Amendments Act of 2010” (Section 103 of Subtitle A of H.R. 5116, the America COMPETES Reauthorization Act of 2010)2 was for an associate director of OSTP to be appointed and made responsible for “oversight of the coordination, planning, and budget prioritization” of EHS research-related activities. The act further delineated those responsibilities:

“(1) ensuring that a research plan for the EHS research activities required under subsection (b) is developed, updated, and implemented…,
“(2) encouraging and monitoring the efforts of the agencies participating in the Program to allocate the level of resources and management attention necessary to ensure that the… environmental… concerns related to nanotechnology, including human health concerns, are addressed under the Program, including the implementation of the research plan described in subsection (b); and
“(3) encouraging the agencies required to develop the research plan under subsection (b) to identify, assess, and implement suitable mechanisms for the establishment of public-private partnerships for support of EHS research.”

Under the proposed legislation, the OSTP associate director would chair a panel that comprised senior officials of the federal agencies funding relevant research “to develop, periodically update, and coordinate the implementation of a research plan.” In carrying out that activity, the associate director would be

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2This passed the U.S. House of Representatives on May 29, 2010. S. 3605, the Senate bill of the same name, was reported out of the Committee on Commerce, Science, and Transportation, but it did not include the provisions related to nanotechnology that were in the House bill. It was the Senate version of the America COMPETES Reauthorization Act that ultimately was enacted in the 111th Congress and signed by President Obama on January 4, 2011.

Suggested Citation: "6 Implementing the Research Strategy and Evaluating Progress." National Research Council. 2012. A Research Strategy for Environmental, Health, and Safety Aspects of Engineered Nanomaterials. Washington, DC: The National Academies Press. doi: 10.17226/13347.

required to solicit and take into account the recommendations of a newly established EHS subpanel of the external advisory panel established pursuant to the original legislation that established the NNI (the 21st Century Nanotechnology Research and Development Act of 2003, Section 4).

The research plan called for under the proposed legislation would have been required to:

“(A) specify near-term research objectives and long-term research objectives;
“(B) specify milestones associated with each near-term objective and the estimated time and resources required to reach each milestone;
“(C) with respect to subparagraphs (A) and (B), describe the role of each agency carrying out or sponsoring research in order to meet the objectives specified under subparagraph (A) and to achieve the milestones specified under subparagraph (B);
“(D) specify the funding allocated to each major objective of the plan and the source of funding by agency for the current fiscal year; and
“(E) estimate the funding required for each major objective of the plan and the source of funding by agency for the following 3 fiscal years.”

The plan was required to be made public and updated annually. A public database was to be established and maintained with all EHS research projects funded under the plan by NNI agencies, “including a description of each project, its source of funding by agency, and its funding history,… grouped by major objective as defined by the research plan.” (See Section 102 of Subtitle A of H.R. 5116, the America COMPETES Reauthorization Act of 2010.)

Most of the previously identified elements to ensure accountability would be addressed through the provisions of the 2010 proposed legislation. The proposed legislation was passed by the House of Representatives but not by the Senate in the 111th Congress; at the time of this writing, it has not been reintroduced in the 112th Congress.

Another approach that might be housed in the existing NNI and NEHI structure would be to designate a person (Maynard 2007), a small group of senior health and environmental officials (Denison 2007b), or an agency with lead responsibility and to provide this entity with the budgetary and management authority needed to direct the EHS research. The officials might be drawn principally from NNI agencies whose missions are to protect human health and the environment and have related research capabilities. Whether situated in or outside the current NNI structure, such an entity would need to have decision-making authority that is independent of the parts of NNI charged with advancing nanotechnology development (Denison 2007a, p. 4). (See section below, “Managing Potential Conflicts of Interest.”)

An example that may serve as a model for interagency coordination and sharing of research roles is the agreement that was reached between the Environmental Protection Agency (EPA) and the Department of Energy (DOE) con-

Suggested Citation: "6 Implementing the Research Strategy and Evaluating Progress." National Research Council. 2012. A Research Strategy for Environmental, Health, and Safety Aspects of Engineered Nanomaterials. Washington, DC: The National Academies Press. doi: 10.17226/13347.

cerning radon research (EPA 1987, 1989). In the middle 1980s, extremely high concentrations of radon were found in homes in Pennsylvania and led to intense public interest and Congressional attention to issues related to indoor radon. In a reauthorization of the Superfund Amendments and Reauthorization Act, Congress designated EPA as the lead agency for addressing radon and other indoor pollutants. However, DOE had a long history of research in radiation biology, anthropogenic sources of radiation exposure, and energy efficiency and building science. Each agency had its supporters, and the tension between them created considerable turmoil.

To address the problems, a memorandum of understanding was signed in September 1987 that defined primary responsibilities for each agency (EPA 1987, 1989). EPA’s role was applied research, particularly that related to monitoring and mitigation techniques and to operational indoor-radon programs. DOE was responsible for basic research in methods for reducing overall exposure to radiation, for investigation of health and environmental effects of radon exposure, and for issues related to the further development of energy efficiency in buildings. Within a few years, EPA clearly led with action programs and public outreach regarding radon exposures, and DOE had a substantial basic-research and applied-research program that fostered understanding of exposure issues, radiation biology, and basic science.

Another model of coordination among federal agencies originates in OSTP: the Committee on Environment, Natural Resources, and Sustainability (CENRS) established by the National Science and Technology Council (OSTP 2011). CENRS is cochaired by OSTP, the National Oceanic and Atmospheric Administration, and EPA. It provides a formal mechanism for interagency coordination relevant to environment, natural resources, and sustainability policy and R&D issues nationwide and globally. The model has been effectively used in coordinating research on particulate matter (PM) funded by multiple federal agencies. In the early 1990’s, PM research was largely uncoordinated and fragmented. Following the promulgation of a new PM standard by EPA in 1997, there was a call for a research agenda. A report by the NRC Committee on Research Priorities for Airborne Particulate Matter published in 1998 laid the groundwork for an integrated research and management program. This committee was charged with monitoring progress and did so over a six-year period. Within a few years, coordination among funding agencies, investigators, and regulators benefited from an interagency working group chaired by EPA but with representation of all the key participants (CENR 2011). The oversight effort identified research gaps and collectively supported the research to address them. The oversight program also fostered collaborative efforts among investigators when this approach was perceived as the optimal means of solving problems. The coordination of the PM research agenda clearly has enhanced research productivity and utility in public-policy decisions. CENRS also is using the model to coordinate climate issues in the federal government, including upgrades of meteorology and air-quality models and how the improved models should be optimized for global and regional issues.

Suggested Citation: "6 Implementing the Research Strategy and Evaluating Progress." National Research Council. 2012. A Research Strategy for Environmental, Health, and Safety Aspects of Engineered Nanomaterials. Washington, DC: The National Academies Press. doi: 10.17226/13347.

NEHI (2010) acknowledges the need for stronger agency coordination and describes some new initiatives, including more active involvement by the Consumer Product Safety Commission and the Food and Drug Administration, the naming of the new NNCO EHS coordinator, the development of an interagency Web site, and a new charge to NEHI to clarify research priorities and identify cross-agency collaboration opportunities.

Conclusion:

While recognizing the important coordinating role of NNI, the committee concludes that to implement its strategy effectively an entity with sufficient management and budgetary authority is needed to direct development and implementation of a federal EHS research strategy throughout NNI agencies and to ensure its integration with EHS research undertaken in the private sector, the academic community, and international organizations. Progress in implementation of the strategy will be severely limited in the absence of such an entity. It would be helpful for NNCO to identify funding needs and mechanisms for interagency collaboration on high-priority research annually.

Providing for Stakeholder Engagement in the Research Strategy

NRC (2009) concluded that the federal nanotechnology-related EHS research strategy did not adequately seek and incorporate the inputs and perspectives of various stakeholders. Input into the strategy was limited to that from the NNI agencies and was constrained by their experience, expertise, and resources. The review concluded that such an insular approach results in an insular research strategy (NRC 2009, p. 49):

The reason is that federal agencies have a vested interest in justifying the applicability of current efforts rather than critically assessing what is not being done and how deficiencies might be addressed. For example, when agencies are developing their own research strategies, they tend to ask, What research can we do within our existing capabilities?, rather than the more appropriate, What research should we be doing? Other relevant questions need to be addressed, such as, Are resources adequate? Are adequate mechanisms and organizational structures in place to achieve the desired goals? As a result, the federal strategy becomes a justification for current activities based on a retrospective examination that demonstrates success rather than the development of a prospective strategy that questions current practices with an eye to future research needs.

Only by actively soliciting from the outset and integrating the needs of those who have a stake in the outcomes of the strategy can it be responsive and ensure that the right questions are being asked and answered.

Suggested Citation: "6 Implementing the Research Strategy and Evaluating Progress." National Research Council. 2012. A Research Strategy for Environmental, Health, and Safety Aspects of Engineered Nanomaterials. Washington, DC: The National Academies Press. doi: 10.17226/13347.

Progress has been made in engaging stakeholders in the development of NEHI (2010). NNI held four public workshops focused on various aspects of nanotechnology-related EHS that solicited reaction to the 2008 strategy (NEHI 2008, 2010): “Human and Environmental Exposure Assessment”, “Nanomaterials and the Environment and Instrumentation, Metrology, and Analytical Methods”, “Nanomaterials and Human Health and Instrumentation, Metrology, and Analytical Methods”, and “Risk Management and Ethical, Legal, and Societal Implications of Nanotechnology.” Participants were asked to review and update the state of the science and to identify critical research gaps and barriers to conducting needed research.

NNI also published a request for information in the Federal Register and established an online portal to receive input on its 2011 draft strategy during a designated comment period (NEHI 2010).

The NNI has established several industry partnerships called Consultative Boards for Advancing Nanotechnology (CBANs) that are limited to industry and, as the name suggests, are aimed primarily at developing nanotechnology. Nonetheless, they do provide a potential means of obtaining input from industry stakeholders.

NRC (2009) cited one model for stakeholder input drawn from the practice of an existing NNI agency, the National Institute for Occupational Safety and Health (NIOSH) (NORA 2008):

The National Occupational Research Agenda (NORA) is a partnership program to stimulate innovative research and improved workplace practices. Unveiled in 1996, NORA has become a research framework for NIOSH and the nation. Diverse parties collaborate to identify the most critical issues in workplace safety and health. Partners then work together to develop goals and objectives for addressing these needs.

NORA has several appealing features that go beyond NNI’s efforts to date and that could be considered as a model for stakeholder engagement. NORA provides means by which the needs of stakeholders—“from universities, large and small businesses, professional societies, government agencies, and worker organizations”—inform the research questions and by which stakeholders are directly involved in the development of the research strategy designed to meet those needs. Various means of involvement are provided, recognizing the differential capacity of individuals and stakeholder groups.

In contrast with the process used by NNI, the NORA process of stakeholder engagement is continuing, rather than one-time or occasional, with input solicited and considered at all stages of strategy development and execution. Finally, national and sector-specific research agendas are produced and maintained in addition to an overall national strategy.

NORA identifies the diversity of stakeholders that it engages as key to its success. Going well beyond submitting comments on draft documents or attending meetings, stakeholders actively participate in standing “councils.” For ex-

Suggested Citation: "6 Implementing the Research Strategy and Evaluating Progress." National Research Council. 2012. A Research Strategy for Environmental, Health, and Safety Aspects of Engineered Nanomaterials. Washington, DC: The National Academies Press. doi: 10.17226/13347.

ample, the Manufacturing Sector Council has representatives of state agencies, hospitals, insurance companies, universities, consulting firms, federal agencies, manufacturers, and labor unions. In addition to producing its sector research agenda, the council prepared and released a dozen fact sheets summarizing the state of information for different occupational health and safety problems in the manufacturing sector. Leaders of each sector council participate in a cross-sector council, the goal being “to enhance the effectiveness of the NORA Sector Councils through coordination of their activities, sharing information, and seeking efficiencies in dealing with issues that are common in two or more sectors” (NORA 2011).

The standing nature of the NORA stakeholder venues, the variety of interim and final products, the sector-specific strategies to supplement the national strategy, and the diversity of stakeholders engaged are all features that could be incorporated into a stakeholder-engagement effort focused on nanotechnology research needs and strategy development. NORA holds biennial symposia to discuss research findings, their implications, and future needs.

Although NORA serves the needs of NIOSH in soliciting stakeholder engagement, NNI’s purview is far broader and involves multiple agencies and departments with differing agendas, cultures, processes, and practices. The NORA model would need considerable adaptation to ensure meaningful stakeholder engagement in this more complex setting. Nonetheless, some of NORA’s features—opportunities to provide input, the provision for substantive stakeholder leadership roles, and the success in involving a broad array of stakeholders— would be desirable features of stakeholder engagement needed to develop and implement the current research strategy.

Conclusions:

To implement its strategy effectively, the committee concludes that several elements are needed to enhance stakeholder engagement:

•  Establishing a standing means to receive input and actively engage stakeholders at all stages of strategy development, implementation, and revision.

•  Establishing stakeholder groups representing or with interest in EHS implications relevant to specific sectors of application of nanotechnology and nanomaterials.

•  Ensuring that diverse stakeholders are provided with a means of playing leadership roles in strategy development, implementation, and revision.

The committee notes that these conclusions go beyond stakeholder engagement opportunities provided under the NNI, and provide a framework for engagement of a broader cross-section of stakeholders. For example, standing councils and stakeholder groups need not and should not be limited to “inside-the-beltway” participants. The process for selecting their membership should be

Suggested Citation: "6 Implementing the Research Strategy and Evaluating Progress." National Research Council. 2012. A Research Strategy for Environmental, Health, and Safety Aspects of Engineered Nanomaterials. Washington, DC: The National Academies Press. doi: 10.17226/13347.

designed to be as inclusive as possible and invite nominations through broadly disseminated channels.

Conducting and Communicating the Results of Research Funded Through Public-Private Partnerships

NEHI (2010) briefly acknowledges the need to develop and leverage public-private partnerships. It notes the continuing use of the Small Business Innovation Research program and the Small Business Technology Transfer program. It notes that “new programs could support industry-public partners-agency collaborations on EHS research,” but it provides or proposes none. NEHI (2010) has an equally short and nonspecific section on the related topic of knowledge dissemination.

As noted earlier, the NNI has established several industry partnerships called Consultative Boards for Advancing Nanotechnology (CBANs), though these are, as the name suggests, aimed primarily at developing nanotechnology.

Another example of a partnership is the Industry Consortium for Environmental Measurement of Nanomaterials (ICEMN) that involves stakeholders from industry and academia who are working to provide the California Department of Toxic Substances Control (DTSC) or other regulatory bodies with information that could be used to measure nanomaterials in air, surface water, and soil and to assess if these methodologies can be adapted to quantify or to characterize environmental concentrations of these nanomaterials. The consortium was established in response to a “data call-in” by DTSC for information on analytic test methods, and on fate and transport in the environment from manufacturers or importers of certain nanomaterials (DTSC/ICEMN 2011; NIA 2011).

Various models have been recommended by stakeholders to facilitate effective, reliable public-private partnerships to conduct nanomaterial EHS research. One such model is the Health Effects Institute (HEI) (HEI 2011). HEI is a nonpartisan, nonprofit research institute, jointly funded by the automotive industry and EPA that focuses on the health effects of air pollution. Strengths of the HEI model include its ability to solicit and fund targeted, policy-relevant research, its quality control and independent governance and peer-review procedures, and its operational transparency and commitment to release all research results (Denison 2007a; Maynard 2007). Others have cited limitations of the model for nanotechnology-related EHS research, including a much broader scope of research than that under the HEI, challenges associated with conducting research on proprietary materials, and research that occurs in many different agencies and industry sectors (Teague 2007).

Other models that have been considered germane to the conduct and communication of nanotechnology-related EHS research through public-private partnerships include the Foundation for the National Institutes of Health (FNIH 2011) and the National Cancer Institute (NCI) Nanotechnology Characterization Laboratory (NCI 2011a).

Suggested Citation: "6 Implementing the Research Strategy and Evaluating Progress." National Research Council. 2012. A Research Strategy for Environmental, Health, and Safety Aspects of Engineered Nanomaterials. Washington, DC: The National Academies Press. doi: 10.17226/13347.

Conclusion:

To implement its strategy effectively, the committee concludes that EHS research requires public-private partnerships that provide for quality control, independent governance, peer-review of research results, operational transparency, and a commitment to release all research results and underlying data.

Managing Potential Conflicts of Interest

NNI was established to fill dual functions: to develop and promote nanotechnology and its applications and to identify and mitigate risks arising from such applications (21st Century Nanotechnology Research and Development Act [2003]). That duality is reflected in the diverse missions of the agencies and departments that make up NNI and in some of the offices within agencies engaged in NNI activities.

The housing of dual purposes in the same entity (NNI) and their coordination through the same office (NNCO) have raised concerns among some stakeholders regarding the potential for a conflict of interest. NRC (2009) noted that the conflict is a “false dichotomy,” but it is clear that there are tensions between the goals of the two functions. The debate over the adequacy of the portion of the total NNI budget devoted to addressing EHS concerns is one manifestation. An equally contentious disagreement is that over NNI’s classification of research projects with respect to their “EHS relevance” and its tendency to “overcount” the dollars spent on EHS research (NRC 2009). NRC (2009, p. 11) noted that “the committee is concerned that the actual amount of federal funding specifically addressing the EHS risks posed by nanotechnology is far less than portrayed in the NNI document and may be inadequate.” The present committee is pleased that the accounting for and reporting of direct EHS-research spending are much improved in the latest draft NNI strategy (NEHI 2010).

In response to those concerns, NRC (2009) and stakeholders have called for more distinct lines of authority to be established to perform the two functions. The NRC (2009, p. 11) committee stated that “a clear separation of accountability for development of applications and assessment of potential implications of nanotechnology would help to ensure that the public-health mission has appropriate priority.” One stakeholder, the Environmental Defense Fund, provided specific recommendations for achieving this separation in accountability (Denison 2007b, p. 7):

Ensuring that both goals receive equal consideration would require, at a minimum, that the responsibility to address the two distinct goals be assigned to different offices and senior staff members, who are given parallel and comparable degrees of authority, and who report directly to the highest levels within their individual agencies and within NNI. We believe

Suggested Citation: "6 Implementing the Research Strategy and Evaluating Progress." National Research Council. 2012. A Research Strategy for Environmental, Health, and Safety Aspects of Engineered Nanomaterials. Washington, DC: The National Academies Press. doi: 10.17226/13347.

that a clear division of labor and interests is critical if public confidence in the ability of the federal government to facilitate the responsible development of nanotechnology is to be restored.

Such a structure would have the additional advantage of ensuring that risk implications of nanotechnology are addressed by research that is intended and directly targeted to answer specific risk-relevant questions and that such research would be directed by—and its relevance and adequacy assessed by— scientists trained in the health or environmental sciences who work in agencies charged with these related missions (Denison 2007a, p. 4). It also would facilitate more transparent accounting of the funding of direct risk research, as distinct from more basic or applications-oriented research, some of which may also yield findings relevant to understanding risk (Denison 2007a). A separation in authority and accountability need not and should not be accomplished in a manner that would “silo-ize” risk research or impede cross-fertilization and synergies between the two lines of research or the free flow of research ideas and results.

A historical precedent and model for addressing perceived and actual conflicts between the federal government’s interest in developing and its interest in managing the risks posed by new technologies was the establishment of the Nuclear Regulatory Commission (U.S. NRC). The Atomic Energy Commission (AEC), established by the Atomic Energy Act of 1946, was explicitly assigned the functions of both encouraging the use of nuclear power and regulating its safety. Concerns about that dual charge grew among proponents and critics of nuclear power and came to a head in the middle 1970s, when Congress abolished AEC. Congress then assigned the oversight functions of AEC to a new entity, U.S. NRC, and shifted federal nuclear energy research and development to DOE (Denison 2007a, p.4; U.S. NRC 2010a,b).

U.S. NRC’s mission and work specifically include risk research: “As part of its regulatory program, the NRC conducts an extensive research program to provide independent information and expertise to support its safety decision making” (U.S. NRC 2010a). That research is conducted through the U.S. NRC’s Office of Regulatory Research, which “provides leadership and plans, recommends, manages and implements programs of nuclear regulatory research” (U.S. NRC 2010c). The office also engages in considerable cooperative research with “DOE and other federal agencies, the nuclear power industry, U.S. universities, and international partners” (U.S. NRC 2010c). However, it operates and is managed independently, and U.S. NRC has extensive guidelines and procedures intended to ensure that it avoids conflicts of interest that could arise from its use of DOE laboratories for technical assistance and research (Callan 1998; Travers 1999) or from its hiring contractors who have also worked on or are competing for DOE contracts (Dingbaum 2002; Denison 2007a).

Far from operating in a “silo” and being unable to take advantage of the cross-fertilization arising from research conducted on applications, U.S. NRC

Suggested Citation: "6 Implementing the Research Strategy and Evaluating Progress." National Research Council. 2012. A Research Strategy for Environmental, Health, and Safety Aspects of Engineered Nanomaterials. Washington, DC: The National Academies Press. doi: 10.17226/13347.

has established an approach intended to allow safety research to be conducted in a manner that transparently manages potential conflicts of interest while maintaining its independent decision-making (Denison 2007a, p. 5). Adoption of a similar set of accountability mechanisms for nanotechnology-related EHS research would help to ensure that nanotechnology’s risk implications get the attention that they need even as federal investment in nanotechnology development proceeds (Denison 2007a, p. 1).

Conclusions:

To implement its strategy (or other strategies) effectively, the committee concludes that a clear separation in management and budgetary authority and accountability is needed between the functions of developing and promoting applications of nanotechnology and of understanding and assessing its potential health and environmental implications. Such a separation is needed to ensure that progress in implementing an effective EHS-research strategy is not hampered. The separation in management of applications-targeted and implications-targeted research needs to be achieved through means that do not impede the free flow of ideas and results between the two lines of research.

To that end it would be helpful for:

•  Responsibility in addressing the two distinct goals to be assigned within NNI agencies to different offices and senior staff members, who would be given parallel and comparable degrees of authority and would report directly to the highest levels in their individual agencies and in NNI.

•  Research that is directly targeted at understanding risk questions to be tracked and reported separately from other more basic or applications-oriented research even though the latter may well yield findings relevant to understanding risk.

•  The targeting and assessment of the relevance and adequacy of risk-relevant research to be assessed by scientists trained in the health or environmental sciences who work in agencies charged with health and environmental protection (Denison 2007a, p. 4).

Informatics and Information-Sharing

Just as institutional arrangements are critical to the implementation of the nanotechnology-related EHS research strategy, so is the development and use of informatics for information collection, analysis, and sharing. Chapter 4 described informatics in the context of method and model development and validation and presented research needs in those activities. Chapter 5 addressed informatics as one component of a larger research and knowledge infrastructure

Suggested Citation: "6 Implementing the Research Strategy and Evaluating Progress." National Research Council. 2012. A Research Strategy for Environmental, Health, and Safety Aspects of Engineered Nanomaterials. Washington, DC: The National Academies Press. doi: 10.17226/13347.

needed to advance the committee’s research priorities. This section addresses broader organizational means of enhancing the collaboration necessary for implementation of an informatics infrastructure. Appendix B presents implementation scenarios for the development of methods, predictive models, a federated data-sharing network, and a semantic informatics infrastructure to illustrate how a systems approach could accelerate nanoscience and nanotechnology research and translation.

Informatics depends on the acquisition, processing, and sharing of large amounts of data and models (NNN 2011). Optimal use of informatics requires collaboration among academics, industry, regulatory bodies, metrology institutions, and laboratories. It also requires working relationships among various organizations in the research community—standard-development organizations, contract research organizations, material providers, and organizations performing interlaboratory studies. The benefits of collaboration are numerous and include the breaking down of data silos, the ability to conduct semantic searches and to share data and models, the use of Web-based tools for rapid dissemination and communication between disciplines, and ultimately acceleration of research (NEHI 2010). There have been not only scientific and technical barriers to broader use of informatics but organizational and cultural challenges. That is evidenced in part by the fact that despite the large amount of nanotechnology-related data that have been produced over the last 10 years in academic and industry laboratories, there remains a dearth of reliable, discoverable data that are standardized, verified, and capable of being shared effectively (NNN 2011, p. 13).

Issues that stymie collaboration are varied and include cultural barriers to data-sharing, intellectual-property concerns regarding data-sharing and data access, differences in expectations, unmet needs for proper annotation and attribution, lack of incentives, and differences in technologic infrastructure. The discussion below provides examples of means by which collaboration may be fostered to support an informatics infrastructure to aid nanotechnology-related EHS research.

One means of facilitating coordination of informatics projects is the Semantic Web, which is a set of practices and standards designed to enable individuals to structure their data so that they are compatible with Web-based exchange. The Semantic Web provides a common framework for data-sharing and data reuse among applications, enterprises, and communities (NEHI 2010; NNN 2011, p. 23). Ontologies have evolved for specific sets of users that have common naming conventions (“namespaces”) and allow computers to search similar concepts to identify appropriate data regardless of how they are organized in a given namespace. For example, data from the Gene Ontology (used for mining genetic data) (Gene Ontology 2011) can be combined with data from the Nanoparticle Ontology (which integrates data in nanomedicine) (Thomas et al. 2011).

Suggested Citation: "6 Implementing the Research Strategy and Evaluating Progress." National Research Council. 2012. A Research Strategy for Environmental, Health, and Safety Aspects of Engineered Nanomaterials. Washington, DC: The National Academies Press. doi: 10.17226/13347.

The power of the Semantic Web for nanotechnology is that it allows separate database systems to share their data and basic applications so that they are interoperable and can be easily joined (“federated”) through a common framework for data-sharing. Such a system avoids the proliferation of data silos while allowing data to be annotated, curated, and maintained by experts. That flexibility even provides for international data-sharing in spite of language differences.

One model of collaboration that relies on the Semantic Web is NCI’s cancer Biomedical Informatics Grid (caBIG). caBIG aims to create a collaborative computational and research network that connects scientists and institutions to facilitate collaboration, data integration, and data-sharing in cancer research (Fenstermacher et al. 2005). The NCI caBIG Nanotechnology Working Group (caBIG Nano WG)— which comprises participants in academe, government agencies, industry, and other organizations— was established in 2009 for researchers interested in applying informatics and computational approaches to nanotechnology, with an emphasis on nanomedicine. caBIG Nano WG is now integrating data, federating nanotechnology databases via pilot projects for enabling the semantic search and retrieval of nanomedicine and nanotoxicology datasets, and aiding in the dissemination of standard protocols (NNN 2011, p. 17). For example, a pilot portal (the cancer Nanotechnology Laboratory [NCI 2011b]) is federating with other databases—such as the Oregon Nanoscience and Microtechnologies Institute Nanomaterial Biological Interactions knowledge base, the National Nanomanufacturing Network Web portal, the NIOSH Nanoparticle Information Library, NanoHUB, and the Collaboratory for Structural Nanobiology— in a series of demonstrations (Nanoinformatics 2010). The demonstrations serve as test beds to elicit requirements from stakeholders for future collaborations in the development, validation, and dissemination of analytic methods; information on the error, uncertainty and robustness of the methods; laboratory expertise; the minimum characterization required for particular ENMs; the development, validation, and sharing of structural, predictive, and risk models; and access to computational facilities.

Grass-roots initiatives that are intended to coordinate networks of researchers could help to foster collaboration in the collection, curation, dissemination, and analysis of nanotechnology-related EHS data and to engage stakeholders. One example outside the nanotechnology realm is the iPlant Collaborative (iPlant Collaborative 2011), a $50 million-per-year program funded by the National Science Foundation (NSF) and begun in 2008 at the University of Arizona to foster communication and share content in the plant-science community.

The intent of sharing data and making data accessible stems from the principle that doing so will move science forward (NAS/NAE/IOM 2009). The practice is becoming more standard. For example, NSF now requires all grant proposals to include a two-page data-management plan for how data will be disseminated and shared publicly (NNN 2011, p. 19). (See Box 6-1 for additional discussion.) Such efforts could provide opportunities for developing formats and databases for nanomaterial data and further encourage collaboration.

Suggested Citation: "6 Implementing the Research Strategy and Evaluating Progress." National Research Council. 2012. A Research Strategy for Environmental, Health, and Safety Aspects of Engineered Nanomaterials. Washington, DC: The National Academies Press. doi: 10.17226/13347.

BOX 6-1 National Science Foundation Data-Management Plan

One strategy for developing a data source and standard submission practice is NSF’s recently instituted requirement for a data management plan: proposals submitted or due on or after January 18, 2011, must include a supplementary “Data Management Plan” that describes how data will be disseminated and shared publicly. There is no repository for this information or standard format for submission; NSF merely requires that data be made available in some form, be archived, and include “analyzed data and the metadata that define how these data were generated. These are data that are or that should be published in theses, dissertations, refereed journal articles, supplemental data attachments for manuscripts, books and book chapters, and other print or electronic publication formats.”

The “Data Management Plan” requirement, combined with the fact that each directorate has its own requirement for deposition of information and with the current lack of a defined structure, provides an excellent opportunity to develop formats and databases for nanomaterial data that could be standardized for programs that involve nanomaterial development or EHS research. NSF could be directed to lead the effort to develop such databases, given its data-management requirement.

Conclusion:

The committee considers that NNI has taken an important step in identifying and committing to implementation of an informatics system in its 2010 draft research strategy (NEHI 2010). However, to address the high-priority research needs outlined in Chapter 5, mechanisms are needed to facilitate nanotechnology-related EHS research in the larger community of researchers and decision-makers beyond NNI. With input from the community of researchers and other stakeholders, the mechanisms may include incentives or even requirements for data-sharing, funding to develop repositories, and resources for community-building to help government and nongovernment researchers to make needed connections among disciplines with colleagues worldwide.

EVALUATING AND ASSESSING PROGRESS FOR REVISING THE STRATEGY

To be relevant, timely, and effective, the development and implementation of a risk-research strategy is an iterative process. It begins with research planning and requires focused, creative, and flexible management of the implementation process. It necessarily includes a process for monitoring and evaluating the agenda’s progress in generating the scientific research and policy-relevant information needed to reduce uncertainty and to address high-priority scientific-

Suggested Citation: "6 Implementing the Research Strategy and Evaluating Progress." National Research Council. 2012. A Research Strategy for Environmental, Health, and Safety Aspects of Engineered Nanomaterials. Washington, DC: The National Academies Press. doi: 10.17226/13347.

knowledge and decision-making gaps. That in turn informs a review process that may result in updates, revisions, and adjustments of the research agenda.

Review and Adaptation

Research activities require periodic reassessments to maintain focus, relevance, and accountability. Current activities need the same level of review and scrutiny as newly initiated activities to ensure maximum return on research investments (NRC 1998, p. 118). That is particularly true of the dynamic and rapidly growing field of nanotechnology, in that new data can inform and modify research plans, funding, processes, and risk-management decisions. Review also is needed for basic-research inputs into the committee’s strategy; for example, review and assessment of the availability and accessibility of and gaps in data on nanomaterials, products, and their uses.

Federal EHS research has been reviewed and updated periodically. In its Strategy for Nanotechnology-Related Environmental, Health, and Safety Research (NEHI 2008, p. 2), the NNI committed to reviewing and updating its plan “as research progresses.” A year later, the 2008 NNI strategy was reviewed by the National Research Council (NRC 2009). In December 2010, the NNI released for public comment a draft National Nanotechnology Initiative 2011 Environmental, Health, and Safety Strategy (NEHI 2010), which updates, revises, and replaces its 2008 strategy. It states (pp. 2-3):

Given the dynamic nature of research in this area, the NNI incorporated adaptive management into its first NNI EHS research strategy, the 2008 NNI Strategy for Nanotechnology-Related EHS Research to allow for modification of the strategy based on research progress, new findings, and product development. This document, the 2011 NNI EHS research strategy, is a result of that adaptive management process and revises and replaces the 2008 strategy.… The adaptive management process remains part of the 2011 NNI EHS research strategy to ensure proactive, science-based management of engineering nanomaterials (ENMs) into the future. Ongoing evaluation of research progress is conducted by the Nanotechnology Environmental Health Implications (NEHI) Working Group.… They will review and evaluate progress on an annual basis to ensure that the NNI EHS research strategy and activities keep pace with the rapid development of nanotechnology and evolving information on the effects of human and environmental exposure to nanomaterials.

Those efforts to review and revise the federal EHS-research strategy are commendable. The committee notes that NEHI (2010) incorporates some notable enhancements, including criteria for setting priorities for research on nanomaterials and nanotechnology-enabled products; identifying the need for reference materials, protocols, and standards for standardized measurements and the need for standardized nomenclature and terminology; a commitment to leverage

Suggested Citation: "6 Implementing the Research Strategy and Evaluating Progress." National Research Council. 2012. A Research Strategy for Environmental, Health, and Safety Aspects of Engineered Nanomaterials. Washington, DC: The National Academies Press. doi: 10.17226/13347.

public-private partnerships and explore mechanisms for interagency joint solicitation of research; giving high priority to international engagement; and detailing steps to foster and improve interagency coordination, communication, stakeholder interaction, and dissemination of knowledge and information.

Given that the federal EHS-research efforts are not the sole input into the present committee’s strategy, the committee encourages further consideration and integration of international, industrial, and other nongovernment research efforts. Continuing efforts are also needed to identify and assess changing market conditions, including the nanomaterials used and the products made and changing regulatory conditions, in that these influence the research needs and priorities articulated in the committee’s strategy.

Indicators for Evaluating Progress

The Near Term

The committee is tasked with delivering a second report 18 months after publication of this one. Issues to be addressed in the second report include an assessment of progress in understanding the EHS aspects of nanotechnology and the extent to which the short-term and long-term research priorities have been initiated or implemented. This 18-month timeframe is clearly too short to have substantial new research programs in place, let alone evaluate actual research outcomes. But the committee considers that the timeframe is sufficient to see progress in initiating research in each of the four high-priority categories identified in Chapter 5 and progress in developing the infrastructure, accountability, and coordination mechanisms discussed in this chapter. Progress in addressing those foundational elements will go a long way toward ensuring effective support and management of the research required to provide information for identifying, assessing, and effectively managing the potential EHS consequences of ENMs.

In its next report, the committee will evaluate the extent to which the research in each of the four high-priority categories identified in Chapter 5 has been initiated and the strategy implementation issues raised in the conclusions in this chapter have been addressed. (See Boxes 6-2 and 6-3 for summaries of indicators of research and implementation progress, respectively.) For examining initiation of research, the committee will simply ask whether the specific research-progress indicators are being addressed; little or no evaluation will be possible. With respect to the strategy-implementation issues, the committee will be particularly attentive to progress in establishing institutional arrangements and mechanisms that foster interagency interaction, collaboration, and accountability; developing and implementing mechanisms for stakeholder engagement; efforts to advance integration among sectors and institutions involved in EHS research, including public-private partnerships; structural changes that address conflicts of interest; and informatics and information-sharing.

Suggested Citation: "6 Implementing the Research Strategy and Evaluating Progress." National Research Council. 2012. A Research Strategy for Environmental, Health, and Safety Aspects of Engineered Nanomaterials. Washington, DC: The National Academies Press. doi: 10.17226/13347.

BOX 6-2 Research-Progress Indicators

Adaptive research and knowledge infrastructure for accelerating research progress and providing rapid feedback to advance the research

•  Extent of development of libraries of well-characterized nanomaterials, including those prevalent in commerce and reference and standard materials.

•  Development of methods for detecting, characterizing, tracking, and monitoring nanomaterials and their transformations in relevant media.

•  Development of methods to quantify effects of nanomaterials in experimental systems.

•  Advancement of systems for sharing the results of research and fostering development of predictive models for nanomaterial behaviors.

•  Extent of joining together of existing databases, including development of common informatics ontologies.

Quantifying and characterizing the origins of nanomaterial releases

Progress indicators will be related to the short-term activities identified in Chapter 5:

•  Developing inventories of current and near-term production of nanomaterials.

•  Developing inventories of intended use of nanomaterials and value-chain transfers.

•  Identifying critical release points along the value chain.

•  Identifying critical populations or systems exposed.

•  Characterizing released materials and associated receptor environments.

•  Modeling nanomaterial releases along the value chain.

Processes affecting both exposure and hazard

•  Steps taken toward development of a knowledge infrastructure able to describe the diversity and dynamics of nanomaterials and their transformations in relevant biologic and environmental media.

•  Progress toward developing instrumentation to measure key nanomaterial properties and changes in them in relevant biologic and environmental media.

•  Initiation of interdisciplinary research that can relate native nanomaterial structures to transformations that occur in organisms and as a result of biologic processes.

•  Extent of use of experimental research results in initial models for predicting nanomaterial behavior in complex biologic and environmental settings.

Suggested Citation: "6 Implementing the Research Strategy and Evaluating Progress." National Research Council. 2012. A Research Strategy for Environmental, Health, and Safety Aspects of Engineered Nanomaterials. Washington, DC: The National Academies Press. doi: 10.17226/13347.

Nanomaterial interactions in complex systems ranging from subcellular systems to ecosystems

•  Extent of initiation of studies that address heretofore underrepresented fields of research, such as those seeking to relate in vitro to in vivo observations, to predict ecosystem effects, or to examine effects on the endocrine or developmental systems.

•  Steps toward development of models for exposure and potential effects along the ecologic food chain.

•  Extent of refinement of a set of screening tools that reflect important characteristics or toxicity pathways of the complex systems described above.

•  Extent of adaptation of existing system-level tools (such as individual species tests, microcosms, and organ-system models) to support studies of nanomaterials in such systems.

•  Identification of benchmark or reference materials, both positive and negative, for use in such studies and measurement tools and methods to estimate exposure and dose in those complex systems.

The Longer Term

As discussed in Chapter 1, the National Research Council Committee on Research Priorities for Airborne Particulate Matter was charged with developing and monitoring progress in implementing a similar risk-research strategy. That committee developed six criteria that it used to evaluate progress in conducting the high-priority research and in implementing the strategy (NRC 1998, 1999):

•  Scientific value: Does the research fill critical knowledge and data gaps?

•  Decision-making value: Does the research reduce uncertainties and inform decision-making by key stakeholders, for example, decisions about risk assessment and risk management?

•  Feasibility and timing: Is the research technically and economically feasible, and can it be done in a timeframe responsive to stakeholder and decision-maker needs?

•  Interaction and collaboration: How well does the research agenda foster the collaboration and interaction needed among scientific disciplines, agencies, academe, and private sector, especially in addressing cross-cutting issues? Are the scientific expertise, capacity, and resources appropriately used to enhance scientific creativity, quality, and productivity?

Suggested Citation: "6 Implementing the Research Strategy and Evaluating Progress." National Research Council. 2012. A Research Strategy for Environmental, Health, and Safety Aspects of Engineered Nanomaterials. Washington, DC: The National Academies Press. doi: 10.17226/13347.

BOX 6-3 Indicators of Progress in Implementation

Enhancing interagency coordination

•  Progress toward establishing a mechanism to ensure sufficient management and budgetary authority to develop and implement an EHS-research strategy among NNI agencies.

•  Extent to which NNCO is annually identifying funding needs for interagency collaboration on critical high-priority research.

Providing for stakeholder engagement in the research strategy

•  Progress toward actively engaging diverse stakeholders in a continuing manner in all aspects of strategy development, implementation, and revision.

Conducting and communicating the results of research funded through public-private partnerships

•  Progress toward establishment of effective public-private partnerships, as measured by such steps as completion of partnership agreements, issuance of requests for proposal, and establishment of a sound governance structure.

Managing potential conflicts of interest

•  Progress toward achieving a clear separation in management and budgetary authority and accountability between the functions of developing and promoting applications of nanotechnology and understanding and assessing its potential health and environmental implications.

•  Continued separate tracking and reporting of EHS research activities and funding distinct from those for other, more basic or application-oriented research.

•  Integration: How well is the research agenda coordinated and integrated with respect to planning, budgeting, and management, including between government and private organizations?

•  Accessibility: How well is information about research plans, budgets, progress, and results made accessible to agencies, research organizations, and interested stakeholders?

The present committee believes that the same criteria should be used to evaluate the extent of longer-term progress in implementing the research agenda proposed in this report. The criteria should be applied in evaluating research progress periodically. The committee notes that the NNI has already made substantial progress in addressing the latter three criteria (NEHI 2008, 2010).

Suggested Citation: "6 Implementing the Research Strategy and Evaluating Progress." National Research Council. 2012. A Research Strategy for Environmental, Health, and Safety Aspects of Engineered Nanomaterials. Washington, DC: The National Academies Press. doi: 10.17226/13347.

As previously stated, the planning, management, and implementation of the research strategy are just as critical as the identification of the research priorities themselves. Without careful attention to those processes, any research agenda will fall short of expectations, no matter how compelling and well reasoned it may be.

To evaluate research progress later, the committee suggests applying specific longer-term progress indicators that correspond to the criteria presented in NRC (1998, 1999).

Scientific Value

The scientific value of the information generated can be assessed in terms of its overall contribution to enhancing understanding of the EHS effects of ENMs and reducing the uncertainty faced by stakeholders who must make decisions about nanotechnology and managing its potential risks. As noted in Chapter 5, such scientific knowledge will fill important data gaps and provide information on what the committee believes are the most critical elements and interactions for understanding EHS effects and determining whether a material is harmful. This includes knowledge about pathways and the likelihood of exposure through the life cycle and value chain, exposure of relevant targets, activation of pathways of disease and organism effects, and resulting effects on the health of humans and ecosystems. Specific progress indicators include

•  Number, distribution, and adequacy of research projects that address priorities, gaps, and critical interactions in each part of the research agenda, including the number of research-agenda priorities planned and initiated, even if not completed, and the number of strategy-related research project applications received and funded.

•  Distribution and adequacy of research through the life cycle and value chain of ENMs.

•  Usefulness of study results for forming hypotheses for future research.

•  Usefulness of research in building new research capacity, skills, and tools for future research.

•  Extent to which uncertainty about human health and environmental risks is reduced.

Decision-Making Value

The decision-making value of the knowledge generated can be assessed in terms of its usefulness to the stakeholders who must make decisions about the development, production, and life-cycle use of ENMs. They include government agencies charged with protecting human and ecosystem health; developers, producers, suppliers, and purchasers of ENMs who must make economic and risk-

Suggested Citation: "6 Implementing the Research Strategy and Evaluating Progress." National Research Council. 2012. A Research Strategy for Environmental, Health, and Safety Aspects of Engineered Nanomaterials. Washington, DC: The National Academies Press. doi: 10.17226/13347.

management decisions in the face of scientific and regulatory uncertainty about EHS effects; and consumers of nanomaterial-enabled products. In addition to providing scientific information that reduces uncertainty about key decisions for stakeholders, the agenda should generate and make accessible basic information about the materials and products themselves— information critical for the research enterprise and important to many stakeholders. That includes information about the nanomaterials and products being produced, planned, or envisioned; identification of populations potentially exposed and at risk; prevention and control measures and practices in place or needed for protection and precaution in the face of uncertainty; identification of nanomaterial-enabled consumer products and information on consumer use; and information about disposal practices. Specific progress indicators include

•  The extent to which the research has generated knowledge or information useful for decision-makers and other stakeholders. To what extent has it identified (and, ideally, reduced) the magnitude of uncertainty about EHS effects of ENMs? For example, to what extent has the new knowledge been integrated into risk-assessment decisions or regulatory processes? To what extent has it influenced private-sector research, investment, or production decisions related to nanomaterials?

•  The extent to which the research has informed risk-management decisions— by government, industry, workers, and the public.

•  The extent to which basic information about nanomaterials has become available and accessible to researchers, decision-makers, and the public—for example, information on nanomaterials and products containing nanomaterials currently produced and in use, data on exposure and exposure pathways, identification of populations at risk, preventive measures or practices in place or needed in the face of uncertainty, disposal practices, and consumer use.

•  The usefulness of results in defining adverse effects on human health and ecosystems.

•  The usefulness of results in identifying susceptible populations.

Timing and Feasibility

This indicator is related to the operational, technical, and economic feasibility of the research. Can it realistically be done in a timeframe responsive to decision-makers’ needs? Specific progress indicators include

•  Whether the technical tools and approaches to conduct the research are available or under development.

•  Whether the research capacity and expertise for conducting the research are adequate and whether they are in the government, private sector, or academe.

Suggested Citation: "6 Implementing the Research Strategy and Evaluating Progress." National Research Council. 2012. A Research Strategy for Environmental, Health, and Safety Aspects of Engineered Nanomaterials. Washington, DC: The National Academies Press. doi: 10.17226/13347.

•  Whether the research is appropriately sequenced. Has a timeframe been articulated for each component of the research?

•  Whether funding for the task is available and adequate.

Interaction and Collaboration

The scientific expertise, research capacity, and decision-making authorities needed to ensure the safety of ENMs are varied. They are found in a host of government, private-sector, and nonprofit organizations and are embedded in multiple disciplines from chemistry, biology, toxicology, medicine, and public health to engineering, computer modeling, and informatics. The committee believes that multidisciplinary interactions and collaborations both domestically and internationally are essential for progress in understanding and addressing the EHS dimensions of ENMs. Specific progress indicators include

•  Specification of disciplines, expertise, and skills needed to achieve specific research objectives.

•  Cooperative use of resources, including mutually funded or conducted research.

•  Multidisciplinary collaboration in research projects.

•  Joint workshops and conferences, and presentations and publications across disciplinary boundaries.

•  Public-private research partnerships on specific elements of the EHS-research strategy.

•  Sharing of databases and information among agencies and disciplines.

•  Consistent use of terminology and measures among disciplines.

•  Stakeholder engagement and participation in all aspects of the research agenda.

•  Public participation in implementing the research strategy.

Integration

Given the agency-based government appropriations process, the different mandates and structures in and among government agencies, and the capacities and resources of private organizations, it is challenging to integrate the planning, budgeting, management, and monitoring of EHS research. But it is the very plethora of institutions, resources, and capacities that warrants efforts to integrate and optimize the use of federal resources, talent, and infrastructure in pursuit of the research agenda. Specific progress indicators include

•  Collaborative or coordinated planning, monitoring, and evaluation of research both domestically and internationally, including multistakeholder engagement.

Suggested Citation: "6 Implementing the Research Strategy and Evaluating Progress." National Research Council. 2012. A Research Strategy for Environmental, Health, and Safety Aspects of Engineered Nanomaterials. Washington, DC: The National Academies Press. doi: 10.17226/13347.

•  Formal processes for exchanging and integrating knowledge, experience, and expertise of the EHS research communities in the implementation, monitoring, and evaluation of the research agenda.

•  Appropriate balance and differentiation of kinds and loci of research activities, for example, applied vs basic, health vs ecosystem risk, intramural vs extramural, and public vs private.

•  Use of a full spectrum of funding mechanisms.

•  Mutually funded or conducted research.

•  Data-sharing and model-sharing among investigators in and outside the federal government.

Accessibility

The ultimate outcome of EHS research is the prevention of harm or effective management of risks associated with ENMs. Thus, the knowledge and information generated must be accessible to and shared with scientists, research sponsors, decision-makers, the public, and others interested or with a role in risk prevention and management. Specific progress indicators include

•  An accessible, searchable central database of research plans, studies, progress, funding, and results open to the research community, key stakeholders, and other interested parties.

•  An “evergreen” database of nanomaterials, products, applications, and uses, and information on effective exposure-control technologies and practices.

•  Outreach and provision of information to target, at-risk populations about EHS exposures, risks, risk prevention, and risk management.

•  Periodic reports that summarize the status of research activities, synthesize research results and accomplishments, and identify remaining knowledge gaps.

Because the lifetime of the present committee is too short to provide for an assessment of research progress in understanding the EHS aspects of nanotechnology, the committee recommends that a rigorous and critical evaluation of the progress made in implementing and conducting research in keeping with its strategy be conducted within 5 years after completion of the committee’s second report. That timeframe should be sufficient to observe progress and identify any needed changes in research directions and additional steps to maintain momentum toward addressing the identified high-priority research.

RESOURCES

There have been repeated expressions of concern that the federal funding devoted to EHS research on nanomaterials is insufficient (GAO 2008; Maynard

Suggested Citation: "6 Implementing the Research Strategy and Evaluating Progress." National Research Council. 2012. A Research Strategy for Environmental, Health, and Safety Aspects of Engineered Nanomaterials. Washington, DC: The National Academies Press. doi: 10.17226/13347.

2008). That concern was echoed in the NRC (2009) review of the federal strategy (NEHI 2008). NRC (2009) also expressed concern that the federal strategy did not identify resources necessary to address questions concerning nanotechnology-related EHS-research needs. Specifically, there was no assessment of whether the aggregate level of spending by the federal agencies was adequate to address EHS-research needs or whether the resource expenditures by the agencies were appropriate to address EHS-research needs based on their own missions (p. 30). NRC (2009) recommended development of a strategy that included the “estimated resources that would be needed to address the [research] gap over a specified time frame.”

In Chapter 5 of this report, the committee calls for maintenance of core EHS research funding at about $120 million per year over the next 5 years, as well as a strategic realignment of the federal resources being devoted to nanotechnology-related EHS research. The committee also recommends that modest additional resources from the private and public sectors, both nationally and internationally, augment the infrastructure needed to support an effective research program. The committee acknowledges, but has not attempted to estimate the resources (in addition to those required to conduct the research), needed for effective implementation of this strategy.

KEY AUDIENCES NEEDED TO IMPLEMENT THE STRATEGY

Implementation of the EHS-research strategy will require the coordinated participation of numerous entities—government, private sector, academic, and nongovernment organizations.

Government organizations have multiple roles related to understanding the potential implications of ENMs. They include conducting and supporting EHS research; ensuring coordination with ongoing research activities occurring internationally; responsibility for protecting workers, consumers, the general public, and the environment from adverse effects that may arise from exposure to nanomaterials in the workplace, products, and the general environment; and providing access to and assessing EHS-relevant information.

Private-sector nanomaterial developers and suppliers are core drivers and holders of nanotechnology-related EHS information. Manufacturers, nanomaterial suppliers, and their customers are the primary producers and handlers of the materials, so their input and knowledge are essential to the research agenda. For example, carbon nanotube (CNT) producer Bayer MaterialScience (BMS) conducts much of its toxicologic studies internally through Bayer Health Care. However, BMS is also involved in publicly supported studies through the project Nanotechnology Capacity Building NGOs, a European program to increase the understanding of nanomaterial-related EHS risks. And BMS— with other European CNT suppliers, such as Arkema and Nanocyl— is conducting workplace-exposure studies with the Producers Association of Carbon nanoTubes in Europe (PACTE) (Lux Research 2009).

Suggested Citation: "6 Implementing the Research Strategy and Evaluating Progress." National Research Council. 2012. A Research Strategy for Environmental, Health, and Safety Aspects of Engineered Nanomaterials. Washington, DC: The National Academies Press. doi: 10.17226/13347.

Academic and research institutions also play a crucial role, especially in the fundamental research relevant to understanding EHS implications of nanotechnology. Academic researchers publish a large share of peer-reviewed articles on nanotechnology-related EHS research and provide expertise relevant to development, implementation, and evaluation of an effective research strategy.

Nongovernment and consumer organizations provide an additional perspective and expertise, a voice for the general public, and a valuable means of monitoring the overall efforts and progress of a research agenda. For example, they have highlighted the need for an accessible repository of EHS data to inform the public about the uses of and risks posed by nanomaterials (Lux Research 2009).

CONCLUDING REMARKS

The committee was charged with developing an integrated research strategy for addressing EHS aspects of ENMs. The committee recognizes that the success and impact of the proposed strategy depend on the institutional arrangements for its implementation and maintenance. This chapter has addressed critical issues related to coordination, collaboration, and leadership. The committee urges that these issues receive high priority because their resolution is integral to the success of the proposed research strategy.

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Next Chapter: Appendix A: Biographic Information on the Committee to Develop A Research Strategy for Environmental, Health, and Safety Aspects of Engineered Nanomaterials
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