Biomedical Engineering Reference
In-Depth Information
for the military but disruptive for the general society. Alternatively, some form of
civilian review mechanism would likely offer greater independence and objectiv-
ity, but would almost certainly be limited (even with security clearances) in its
access to information and key personnel.
Moreno (2006) has recommended the formation of an advisory committee to
consider the ethical and policy aspects of military development and utilization of
neurotechnologies. Such a committee, if constituted, could potentially take on the
related function of assessing the civilian spillover implications of such military
technologies.
Alternatively, a model that could be used, with some important modifications, is the
environmental impact statement (EIS) required under the National Environmental
Policy Act (NEPA) for major federal actions that will significantly affect the human
environment (NEPA 1969). The agency sponsor of such a project must undertake
an analysis of the potential environmental impacts of the project and indentify
potential alternatives that might reduce any such adverse impacts. The agency first
undertakes an initial screening assessment called an environmental statement (ES)
to determine whether the project is likely to have significant environmental impacts;
a full EIS is only required for the relatively small subset of projects that are likely to
have substantial impacts. The EIS has been interpreted to be a procedural require-
ment, with the sponsor agency under no obligation to adopt any substantive alterna-
tives to its proposed project. Nevertheless, the procedural requirement to study and
report environmental impacts of, and alternative to, a project is seen as having two
major benefits. First, it creates awareness within the sponsoring agency of the poten-
tial environmental impacts of its actions, by requiring the hiring of staff with environ-
mental expertise who will then conduct an analysis that will be shared with the key
decision makers and staff within the agency. In addition to this internal educational
and awareness benefit, a second benefit of the EIS is to inform the public of the poten-
tial impacts of proposed projects, thereby triggering the political process to debate the
wisdom of the project and its possible alternatives (Rodgers 1990).
The impact assessment model created for environmental effects by NEPA has now
been cloned into a number of other contexts, such as (1) social impact assessment
statements for many development and other projects (Dietz 1987), (2) a privacy impact
assessment statements implemented by many private companies and mandated by all
federal agencies by Section 208 of the E-Government Act of 2002 (Clarke 2009), (3)
health impact assessments “to examine the effects that a policy, program, or project
may have on the health of a population” (Collins and Koplan 2009), and (4) ethical tech-
nology assessments (Palm and Hansson 2006). In 2007, the National Science Advisory
Board for Biosecurity (NSABB 2007) proposed an impact-assessment type model for
dual-use problems in which investigators would identify potential substantive dual-use
concerns associated with their research and confer with local oversight boards about
those concerns.
Military and intelligence agencies that are developing new technologies that
could have significant detrimental civilian implications could be required to conduct
an impact assessment, perhaps called a civilian impact assessment statement (CIAS).
Just as NEPA screens out projects with minor environmental impacts from having
to conduct a full EIS, the military entity responsible for a new technology would
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