Companies perceive themselves as clearly responsible for potential impacts to human health and environment in the research, development, and production stages, but this responsibility is gradually externalized to other stakeholders throughout the product life cycle. This clear acknowledgement of industrial responsibility is in sharp contrast to a less uniform perception of regulation: Respondents' opinions varied as to whether industrial standards or governmental regulations should be established to regulate NPM handling during the each life cycle stage. Respondents' opinions were divided between industrial standards and no regulations during research and development, most thought that production should be regulated via industrial standards, and their opinions were divided between industrial standards and governmental regulations during use and at end of life.
The combination of industry's externalization of responsibility and regulations throughout the life cycle may be problematic, as current regulations generally do not cover NPMs. Thus, we may have a vacuum in corporate and public policy for ensuring that NPMs are developed and used in a safe manner. In an agent network analysis conducted in Switzerland, approximately 85% of the participants perceived government agencies as being completely responsible for environmental safety throughout the NPM life cycle, but only one of four regulatory bodies regarded itself as completely responsible (Wiek et al. 2007). Furthermore, approximately 60% of the participants perceived industry as being completely responsible for risk assessment, but only four of ten industrial participants perceived themselves as completely responsible for risk assessment. This leads to an important question: What should regulators do when industry does not convey a clear opinion on responsibility and regulatory action, although most industry members think some type of regulation is needed? In our opinion, this depends on whether industry takes sufficient voluntary initiatives for preventive strategies.
Precaution in Practice
We postulated in the introduction that the success of voluntary industry initiatives may depend on the extent to which preventive procedures are systematically implemented within industry, the industry's capacity to improve these practices, and industry's own perspectives on issues such as regulation and responsibility. In an earlier study, we found that 65% of Swiss and German companies producing or using NPMs did not conduct risk assessment and could not identify a systematic approach for assessing NPM risks, and we thus questioned whether the level of risk assessment initiatives within a company depends on the company's safety culture (Helland et al. 2008). The safety performance of a company is influenced by the willingness, opportunity, and capability to change, which are influenced by management and organizational, technological, and behavioral factors (Ashford and Zwetsloot 2000).
Preventing harm arising from production or products by eliminating problems at the source may involve changes in production technology, input substitution, process redesign and reengineering, and final product design and reformulation. About two thirds of the companies surveyed did not have such procedures in place, but most respondents assessed their existing routines for performing these procedures to be sufficient. This may imply that there are few or no incentives for considering alternative technology options, and thus a business-as-usual approach is chosen. One exception was the procedure of risk assessment. Although most of the companies surveyed did not have risk assessment procedures in place, many respondents expressed a desire to improve their performance, which indicates that companies need assistance in this area. The lack of established risk assessment and management frameworks for NPMs is problematic for the companies producing and using NPMs (Reijnders 2006; Davis 2007).
One challenge relates to the difficulties of agreeing on common nomenclature and standards. Initiatives to overcome these difficulties are in progress, however. The American National Standards Institute (ANSI) established the ANSI Nanotechnology Standards Panel (ANSI-NSP) in 2004 to coordinate the development of voluntary, consensus standards for nanotechnology applications, and in June 2005, the International Standards Organization launched ISO/TC 229, a technical committee on nanotechnology that oversees the development of standards for nanotechnologies, including classification, terminology and nomenclature, metrology, characterization, calibration, and EHS issues (ANSI 2007).
Awareness among key actors in a company (managers, engineers, researchers, safety experts, product designers, etc.) is heavily influenced by social factors such as communication and cooperation with other stakeholders, in addition to the existing corporate culture and core values (Ashford and Zwetsloot 2000). Increasing awareness among companies' key actors through training and outreach activities can improve a company's safety culture. The surrounding network of agents may therefore provide important contributions to industry for governing risks, but, nonetheless, greater industry contributions to the public knowledge on NPMs have been called for (Helland and Kastenholz 2007; Wiek et al. 2007). We may conclude from our results that most companies have an established network through which risk information is exchanged. This information exchange usually takes place among companies and between companies and universities. Nonetheless, the extent to which risk information is also transferred from companies to universities (e.g., through the funding of external research) is not clear. Most respondents think that improvements in information exchange are needed.
Another result of insufficient communication with external stakeholders may be related to consumer response. Nanotechnology experts may not be inclined to initiate the risk assessment expected by the public, as they perceive fewer risks associated with nanotechnology than laypeople do (Siegrist, Keller, et al. 2007; Siegrist, Wiek, et al. 2007).2 Although a high share of respondents claimed to include stakeholder concerns during product development, most did not have procedures in place for engaging stakeholders, and many did not find stakeholder involvement important. This may impede the entrance of some products into the market. Conversely, 14 respondents indicated a desire to improve their stakeholder engagement procedures.
Push, Hold, or Pull?
Do the companies have to be pushed or pulled to improve their precautionary measures, or is the current situation satisfactory? In the case of NPMs, industry believes that regulation should be evidence-based (Helland et al. 2006), but the fate of NPMs throughout the life cycle receives little industry attention (Helland et al. 2008). Thus, we must ask whether current scientific evidence warrants regulatory action. Industry's opinion on this is not clear. Two unifying opinions expressed in this study stand out: Emissions should be kept as low as possible, and specific characteristics of irreversibility are reason enough for taking precautionary measures. Industry does not necessarily see monitoring and demonstrating such characteristics as its responsibility, however. Building on the consensus opinion of the respondents, one may draw two specific questions of high priority for government–industry collaboration:
What are the possible sources of NPM emissions throughout the product life cycle, how high are such emissions, and what is the environmental fate of such emissions?
What NPM characteristics indicate potential irreversibility for ecosystemic interactions (e.g., persistency, bioaccumulation), and which NPMs specifically inhibit such characteristics?
On the basis of this study, we are not convinced that the current level of voluntary initiatives will be sufficient. Although most applications may be quite safe, there is still the concern that consumers may be exposed to unassessed risks. Developing proactive risk management strategies appears to be an urgent task for regulators and industry to minimize the risk of harm to the environment and the public health.