I started discussing the Council of Canadian Academies and its mid-term assessment report (Review of the Council of Canadian Academies; Report from the External Evaluation Panel 2010) yesterday and will finish today with my thoughts on the assessment of the Council’s nanotechnology report and its impact.
Titled Small is Different: A Science Perspective of the Regulatory Challenges on the Nanoscale (2008), the Council’s report is one of the best I’ve read. I highly recommend it to anyone who wants an introduction to some of the issues (and was much struck by its omission from the list of suggested nanotechnology readings that Peter Julian [Canadian MP] offered in part 2 of his interview). Interestingly, the Council’s nanotechnology report is Case Study No. 3 in the mid-term expert panel assessment report’s Annex 6 (p. 33 in the print version and p. 37 in PDF).
Many respondents were concerned that Health Canada has made no response to, or use of, this report. However, Health Canada respondents were highly enthusiastic about the assessment and the ways in which it is being used to inform the department’s many – albeit still entirely internal – regulatory development activities: “We’ve all read it and used it. The fact that we haven’t responded to the outside is actually a reflection of how busy we’ve been responding to the file on the inside!” [emphases mine]
The report has been particularly valuable in providing a framework to bring together Health Canada’s five – very different – regulatory regimes to identify a common approach and priorities. The sponsor believes the report’s findings have been well-incorporated into its draft working definition of nanomaterials, [emphasis mine] its work with Canadian and international standards agencies, its development of a regulatory framework to address shorter- and longer-term needs, and its creation of a research agenda to aid the development of the science needed to underpin the regulation of nanomaterials in Canada.
I think the next time somebody confronts me as to why I haven’t responded externally to some notice (e.g., paid my strata fees), I’ll assure them that I’ve been ‘responding on the inside’. (Sometimes I cannot resist the low-hanging fruit and I just have to take a bite.)
As for the second paragraph where they claim that Health Canada has incorporated suggestions from the report for its nanomaterials definition, that’s all well and good but the thinking is changing and Health Canada doesn’t seem to be responding (or to even be aware of the fact). Take a look at the proposed definition in the current draft bill before the US Senate where in addition to size, they mention shape, reactivity, and more as compared the Health Canada 1 to 100 nm. size definition. (See details in this posting from earlier in the week where I compare the proposed US and Canadian definitions.)
Additionally, I think they need to find ways to measure impact that are quantitative as well as this qualitative approach, which itself needs to be revised. Quantitative measures could include the numbers of reports disseminated in print and online, social networking efforts (if any), number of times reports are mentioned in the media, etc. They may also want to limit case studies in future reports so they can provide more depth. The comment about the ‘internal’ impact could have been described at more length. How have the five different Health Canada regulatory regimes come together? Has something substantive occurred?
Finally, it’s hard to know if the Julian’s failure to mention the council’s report in his list of nanotechnology readings is a simple failure of memory or a reflection of the Council’s “invisibility”. I’m inclined to believe that it’s the latter.