Review of Recent Reports and National Research Council Committee Workshop - Research Progress on Environmental Health and Safety Aspects of Engineered Nanomaterials - page 13

percent), it was not clear that the projects met the definition for PCA 7—research primarily directed at the
EHS impacts of nanotechnology development and corresponding risk assessment, risk management, and
methods for risk mitigation” (p. 18). Those projects accounted for more than $15 million in reported EHS
funding or 18% of the total projects. The latter issue identified in the report, nonuniformity of reporting
approaches, had been raised by GAO in 2008 and was the subject of one of its recommendations for
improvement. 5 In addition, GAO noted that agencies were focusing on limited categories of nanomaterials
(primarily carbon nanotubes, nanosilver, and nanoscale titanium dioxide). The report noted that the 2011
NNI EHS research strategy provides an approach to setting priorities among nanomaterials for EHS
research, although it commented that it was too early to determine the influence of the approach on the
agencies' research.
The 2012 GAO report states that “NNI agencies have collaborated extensively on EHS research
and strategies” and have initiated numerous formal collaborative EHS research projects. GAO further
reported that “nonfederal stakeholders who responded to GAO's Web-based questionnaire on
nanotechnology EHS research” said “that they benefited from collaboration with the NNI member
agencies” (GAO 2012, p. 1). Three types of collaborations were identified as the most frequent: “joint
data gathering and sharing, joint research solicitations or funding of research consortia, and competitive
grants” (p. 34). The questionnaire also identified a “lack of funding and limited awareness” of
opportunities for collaboration for some NNI agencies as continuing challenges (p. 1). GAO (2012)
comments that despite those challenges, “most respondents rated the 2011 NNI EHS research strategy as
somewhat or very effective at addressing nanotechnology EHS research needs” (GAO 2012, p. 1).
Focusing on the 2011 NNI strategic plan (NSET 2011), the 2011 NNI EHS research strategy
(NEHI 2011), and the NNI supplement to the president's 2012 budget (NSET 2012), GAO (2012) found
that the NNI's EHS program had addressed or partially addressed all six characteristics of what GAO
identified as desirable characteristics of a national strategy. The GAO was particularly positive about how
the three strategy documents address the first two criteria: purpose, scope, and methodology and problem
definition and risk assessment. For desirable characteristic 3 (goals, subordinate objectives, activities, and
performance measures), GAO suggests that additional work is needed to articulate priorities, milestones,
or outcome-related performance measures that can be used to measure the effectiveness of
implementation of an EHS strategy. The 2012 GAO report comments that “independent reviews of the
prior NNI strategy documents also noted an absence of performance information” (p. 46). (This finding is
also reflected in PCAST 2012 [noted above], regarding the lack of metrics for assessing the effects of
federal investments in nanotechnology.) With respect to the fourth and fifth characteristics, GAO's
assessment was that the strategy documents had partially addressed resources, investments, and risk
management and organizational roles, responsibilities, and coordination (p. 47). However, concerns were
raised, because, although “the 2011 NNI EHS research strategy identifies research goals, . . . it is up to the
agencies to determine how their funding should be spent” (p. 48). Consequently, there is a perceived lack
of oversight of agency roles and little discussion of how agencies will be held accountable for the goals
and research needs of the NNI strategy documents. GAO (2012) suggests that “the NNI strategy
documents . . . partially address the sixth characteristic describing integration and implementation”
(p. 48). This concern arises because the strategy documents do not discuss agency-level EHS research
strategies and efforts to map agency strategies to the NNI-level documents are not publically available.
The 2012 GAO report made two recommendations to the director of the Office of Science and
Technology Policy (OSTP). It has recommended that “the Director of OSTP coordinate development by
the NNI member agencies of performance measures, targets, and time frames for nanotechnology EHS
research that align with the research needs of the NNI, consistent with the agencies' respective statutory
authorities, and include this information in publicly available reports” (p. 51). In addition, it recommends
5 GAO (2008) recommended “that the Director, OSTP, in consultation with the Director, NNCO, and the
Director, OMB [Office of Management and Budget], provide better guidance to agencies regarding how to report
[nanotechnology EHS] research” (p. 30). However, GAO (2012) states that “as of February 2012, updated guidance
had not been issued” (p. 20).