Building Science for Environmental Protection in the 21st Century - Science For Environmental Protection: The Road Ahead - page 99

emerging issues through enhanced interdisciplinary collaboration and by using
systems thinking and enhanced analysis tools to understand the human health
and ecologic implications of important trends. Addressing emerging issues
should include consideration of the full life cycle of products, establishment of
large-scale surveillance systems to address relevant technologies and indicators,
and the analytic ability to detect historical trends rapidly.
Although EPA has engaged NACEPT and its Science Advisory Board
(SAB) to help in anticipating trends and has individual programs designed to
address concerns about existing and emerging technologies and identify promis-
ing new technologies (see, for example, EPA 2011a), the agency does not ap-
pear to have a systematic and integrated process for anticipating emerging is-
sues. The example of engineered nanomaterials (discussed below and described
in Chapter 3) illustrates some of the problems and pitfalls of current approaches
to emerging technologies. A better understanding of such technologies can help
to identify and avert ecosystem and health effects and in some cases to avoid
unwarranted concern about new technologies that pose little risk.
In principle, early consideration of environmental effects in the design of
emerging chemicals, materials, and products offers advantages to businesses,
regulatory agencies, and the public, including lower development and compli-
ance costs, opportunities for innovations, and greater protection of public health
and the environment. Yet, despite nearly 15 years of investment in engineered
nanotechnology and the use of nanomaterials in thousands of products, recogni-
tion of potential health and ecosystem effects and design changes that might
mitigate the effects have been slow to arrive. Indeed, a December 2011 report by
the EPA Office of Inspector General (EPA 2011b) found several limitations in
EPA's evaluation and management of engineered nanomaterials and stated the
following:
 “Program offices do not have a formal process to coordinate the dis-
semination and utilization of the potentially mandated information.
 “EPA is not communicating an overall message to external stake-
holders regarding policy changes and the risks of nanomaterials.
 “EPA proposes to regulate nanomaterials as chemicals and its success
in managing nanomaterials will be linked to the existing limitations of those
applicable statutes.
 “EPA's management of nanomaterials is limited by lack of risk infor-
mation and reliance on industry-submitted data.”
The Office of Inspector General concluded that “these issues present significant
barriers to effective nanomaterial management when combined with existing
resource challenges. If EPA does not improve its internal processes and develop
a clear and consistent stakeholder communication process, the Agency will not
be able to assure that it is effectively managing nanomaterial risks.”