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An anticipatory Governance Approach to Carbon Nanotube Risk Assessment

The November issues of the journal Risk Analysis features an article, entitled An Anticipatory Governance Approach to Carbon Nanotubes (Risk Analysis, Vol. 30, No. 11, 2010). The report introduces carbon nanotubes as 'novel materials with remarkable properties; possible beneficial applications include aircraft frames, hydrogen storage, environmental sensors, electrical transmission, and many more'. 'At the same time', the authors caution, 'precise characterization of their potential toxicity remains elusive, in part because engineered nanostructures pose challenges to existing assays, predictive models, and dosimetry'.

The article points out that in the case of CNTs, traditional strategies of risk analysis are 'of limited immediate utility to both regulators essaying to carry out their mandates, and users of CNTs seeking to provide an appropriate level of protection to employees, customers, and other stakeholders'. By contrast, the authors propose that 'the concept of anticipatory governance suggests an alternative research focus [to that of traditional risk analysis strategies],' and adopt this theoretical framework to argue that 'currently available data support treating CNTs "as if" they are hazardous, while simultaneously highlighting some systemic uncertainties in many of the experiments carried out to date'.

In the course of the article's underlying discussion, the author looks at several 'Methodological Challenges' CNTs pose to traditional risk assessment and the test and analyses conducted as part of traditional risk assessment:

  • Confounded Assays
  • Medium Interactions
  • Surfactants

The article continues to discuss 'Potential Hazards of CNTs', such as 'Inflammation and Oxidative Stress' and 'Granulomas, Fibrosis, and Secondary Effects' and looks at 'Analogies to Asbestos'. It explains that the 'Anticipatory Approach [...] recognizes that pivotal actors must make decisions in the absence of scientific certainty, and that such choices are an important element of the governance of emerging technologies'. It points out that '[s]uch an approach requires flexibility and willingness to change course based on new information, and in that sense is very similar to "adaptive management" strategies in the fields of natural resources'.

Examples of useful frameworks and concepts supporting such anticipatory decision-making are:

  • 'reasonable worst-case' scenarios as temporary fillers for data gaps
  • [a] life-cycle approach [that] facilitates consideration of possible release pathways and vulnerabilities in advance, and thus the identification of mitigation strategies prior to actual exposure
  • Life-cycle approaches [that] facilitate consideration of process alternatives with implications beyond workplace safety
  • [scoping for] alternative chemical formulation
  • functionalization of CNTs [to] improve the toxicity profile of CNTs without interfering with the very surface properties that make them valuable in many cases
  • end-of-life considerations


Follow this link to read or download the full article.

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