Biomedical Engineering Reference
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separation of accountability for development of applications and assessment of potential implication of
nanotechnology would help ensure that the public health implications has appropriate priority” (NRC
2009, p. 11).
Progress toward achieving a clear separation in management and budgetary authority and
accountability between the functions of developing and promoting applications of nanotechnology and
understanding and assessing its potential health and environmental implications
The committee sees little progress in establishing clear and discernibly separate management and
budgetary structure between the two potentially conflicting functions in the NNI itself or the agencies that
pursue or fund research on both applications and EHS risk implications of engineered nanomaterials.
Therefore, this indicator is red. Both functions continue to operate under the same management and
budget structures in the NNI and in its member agencies. In its first report, the committee noted possible
models and mechanisms that could be used to separate accountability for the NNI's dual functions, for
example, elevating oversight of the EHS research portfolio in OSTP (NRC 2012; pp. 166-169), assigning
responsibility and comparable authority for the two functions to different offices or to senior staff
members in individual agencies or in the NNI itself (NRC 2012; pp.167, 173-174), or separating the two
functions into independent entities—a model used elsewhere to address potentially conflicting issues
related to nuclear power (p. 174). The committee acknowledges that in the absence of a change in its
statutory mandate, the NNI would be hard-pressed to establish wholly separate management and
budgetary structures and authorities for its dual functions. In the absence of such a change, the committee
encourages the NNI and participating agencies to consider other approaches for managing perceived or
actual conflicts of interest and biases. If not adequately addressed, such perceptions could undermine
public trust and confidence in the research, technology, and government processes that are meant to
ensure the health, and safety of ENMs.
Continued separate tracking and reporting of EHS research activities and funding distinct
from those for other, more basic or application-oriented research
The NNI has made considerable progress on this issue, commencing before the committee issued
its first report. That progress constitutes an impressive step toward creating the transparency noted above.
The Office of Management and Budget (OMB) call to NNI agencies for detailed information on FY 2009
EHS research project funding facilitated easier identification of research projects most directly relevant to
EHS risk. That data call helped to inform the NNI's Environmental, Health, and Safety Research Strategy
(NSET 2011). The NNI supplement to the president's 2013 budget (NSET 2012) also provides narrative
information on agency-specific EHS research activities and projects.
Despite the impressive progress, the tracking of EHS research progress and performance between
and within NNI agencies remains challenging. As noted by GAO in its May 2012 report, performance
information— such as outcomes, outputs, quality, timeliness, customer satisfaction, and efficiency—can
inform such critical management decisions as priority-setting and resource allocation. Without project-
specific information, researchers and other stakeholders have only a vague understanding of the research
questions, methods, materials, and study populations being addressed through the NNI. Although periodic
OMB data calls for EHS research project funding are helpful and could be made even more helpful if they
included clearer guidance on how agencies should differentiate research directly relevant to EHS risk
from applications research with EHS implications, they cannot address the need for a continuing (ideally
annual) system for identifying and tracking EHS research projects and their performance.
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