Tag Archives: Environment Canada

Does digitizing material mean it’s safe? A tale of Canada’s Fisheries and Oceans scientific libraries

As has been noted elsewhere the federal government of Canada has shut down a number of Fisheries and Oceans Canada libraries in a cost-saving exercise. The government is hoping to save some $440,000 in the 2014-15 fiscal year by digitizing, consolidating, and discarding the libraries and their holdings.

One would imagine that this is being done in a measured, thoughtful fashion but one would be wrong.

Andrew Nikiforuk in a December 23, 2013 article for The Tyee wrote one of the first articles about the closure of the fisheries libraries,

Scientists say the closure of some of the world’s finest fishery, ocean and environmental libraries by the Harper government has been so chaotic that irreplaceable collections of intellectual capital built by Canadian taxpayers for future generations has been lost forever.

Glyn Moody in a Jan. 7, 2014 post on Techdirt noted this,

What’s strange is that even though the rationale for this mass destruction is apparently in order to reduce costs, opportunities to sell off more valuable items have been ignored. A scientist is quoted as follows:

“Hundreds of bound journals, technical reports and texts still on the shelves, presumably meant for the garbage or shredding. I saw one famous monograph on zooplankton, which would probably fetch a pretty penny at a used science bookstore… anybody could go in and help themselves, with no record kept of who got what.”

Gloria Galloway in a Jan. 7, 2014 article for the Globe and Mail adds more details about what has been lost,

Peter Wells, an adjunct professor and senior research fellow at the International Ocean Institute at Dalhousie University in Halifax, said it is not surprising few members of the public used the libraries. But “the public benefits by the researchers and the different research labs being able to access the information,” he said.

Scientists say it is true that most modern research is done online.

But much of the material in the DFO libraries was not available digitally, Dr. Wells said, adding that some of it had great historical value. And some was data from decades ago that researchers use to determine how lakes and rivers have changed.

“I see this situation as a national tragedy, done under the pretext of cost savings, which, when examined closely, will prove to be a false motive,” Dr. Wells said. “A modern democratic society should value its information resources, not reduce, or worse, trash them.”

Dr. Ayles [Burton Ayles, a former DFO regional director and the former director of science for the Freshwater Institute in Winnipeg] said the Freshwater Institute had reports from the 1880s and some that were available nowhere else. “There was a whole core people who used that library on a regular basis,” he said.

Dr. Ayles pointed to a collection of three-ringed binders, occupying seven metres of shelf space, that contained the data collected during a study in the 1960s and 1970s of the proposed Mackenzie Valley pipeline. For a similar study in the early years of this century, he said, “scientists could go back to that information and say, ‘What was the baseline 30 years ago? What was there then and what is there now?’ ”

When asked how much of the discarded information has been digitized, the government did not provide an answer, but said the process continues.

Today, Margo McDiarmid’s Jan. 30, 2014 article for the Canadian Broadcasting Corporation (CBC) news online further explores digitization of the holdings,

Fisheries and Oceans is closing seven of its 11 libraries by 2015. It’s hoping to save more than $443,000 in 2014-15 by consolidating its collections into four remaining libraries.

Shea [Fisheries and Oceans Minister Gail Shea] told CBC News in a statement Jan. 6 that all copyrighted material has been digitized and the rest of the collection will be soon. The government says that putting material online is a more efficient way of handling it.

But documents from her office show there’s no way of really knowing that is happening.

“The Department of Fisheries and Oceans’ systems do not enable us to determine the number of items digitized by location and collection,” says the response by the minister’s office to MacAulay’s inquiry. [emphasis mine]

The documents also that show the department had to figure out what to do with 242,207 books and research documents from the libraries being closed. It kept 158,140 items and offered the remaining 84,067 to libraries outside the federal government.

Shea’s office told CBC that the books were also “offered to the general public and recycled in a ‘green fashion’ if there were no takers.”

The fate of thousands of books appears to be “unknown,” although the documents’ numbers show 160 items from the Maurice Lamontagne Library in Mont Jolie, Que., were “discarded.”  A Radio-Canada story in June about the library showed piles of volumes in dumpsters.

And the numbers prove a lot more material was tossed out. The bill to discard material from four of the seven libraries totals $22,816.76

Leaving aside the issue of whether or not rare books were given away or put in dumpsters, It’s not confidence-building when the government minister can’t offer information about which books have been digitized and where they might located online.

Interestingly,  Fisheries and Oceans is not the only department/ministry shutting down libraries (from McDiarmid’s CBC article),

Fisheries and Oceans is just one of the 14 federal departments, including Health Canada and Environment Canada, that have been shutting physical libraries and digitizing or consolidating the material into closed central book vaults.

I was unaware of the problems with Health Canada’s libraries but Laura Payton’s and Max Paris’ Jan. 20, 2014 article for CBC news online certainly raised my eyebrows,

Health Canada scientists are so concerned about losing access to their research library that they’re finding workarounds, with one squirrelling away journals and books in his basement for colleagues to consult, says a report obtained by CBC News.

The draft report from a consultant hired by the department warned it not to close its library, but the report was rejected as flawed and the advice went unheeded.

Before the main library closed, the inter-library loan functions were outsourced to a private company called Infotrieve, the consultant wrote in a report ordered by the department. The library’s physical collection was moved to the National Science Library on the Ottawa campus of the National Research Council last year.

“Staff requests have dropped 90 per cent over in-house service levels prior to the outsource. This statistic has been heralded as a cost savings by senior HC [Health Canada] management,” the report said.

“However, HC scientists have repeatedly said during the interview process that the decrease is because the information has become inaccessible — either it cannot arrive in due time, or it is unaffordable due to the fee structure in place.”

….

The report noted the workarounds scientists used to overcome their access problems.

Mueller [Dr. Rudi Mueller, who left the department in 2012] used his contacts in industry for scientific literature. He also went to university libraries where he had a faculty connection.

The report said Health Canada scientists sometimes use the library cards of university students in co-operative programs at the department.

Unsanctioned libraries have been created by science staff.

“One group moved its 250 feet of published materials to an employee’s basement. When you need a book, you email ‘Fred,’ and ‘Fred’ brings the book in with him the next day,” the consultant wrote in his report.

“I think it’s part of being a scientist. You find a way around the problems,” Mueller told CBC News.

Unsanctioned, underground libraries aside, the assumption that digitizing documents and books ensures access is false.  Glyn Moody in a Nov. 12, 2013 article for Techdirt gives a chastening example of how vulnerable our digital memories are,

The Internet Archive is the world’s online memory, holding the only copies of many historic (and not-so-historic) Web pages that have long disappeared from the Web itself.

Bad news:

This morning at about 3:30 a.m. a fire started at the Internet Archive’s San Francisco scanning center.

Good news:

no one was hurt and no data was lost. Our main building was not affected except for damage to one electrical run. This power issue caused us to lose power to some servers for a while.

Bad news:

Some physical materials were in the scanning center because they were being digitized, but most were in a separate locked room or in our physical archive and were not lost. Of those materials we did unfortunately lose, about half had already been digitized. We are working with our library partners now to assess.

That loss is unfortunate, but imagine if the fire had been in the main server room holding the Internet Archive’s 2 petabytes of data. Wisely, the project has placed copies at other locations …

That’s good to know, but it seems rather foolish for the world to depend on the Internet Archive always being able to keep all its copies up to date, especially as the quantity of data that it stores continues to rise. This digital library is so important in historical and cultural terms: surely it’s time to start mirroring the Internet Archive around the world in many locations, with direct and sustained support from multiple governments.

In addition to the issue of vulnerability, there’s also the issue of authenticity, from my June 5, 2013 posting about science, archives and memories,

… Luciana Duranti [Professor and Chair, MAS {Master of Archival Studies}Program at the University of British Columbia and Director, InterPARES] and her talk titled, Trust and Authenticity in the Digital Environment: An Increasingly Cloudy Issue, which took place in Vancouver (Canada) last year (mentioned in my May 18, 2012 posting).

Duranti raised many, many issues that most of us don’t consider when we blithely store information in the ‘cloud’ or create blogs that turn out to be repositories of a sort (and then don’t know what to do with them; ça c’est moi). She also previewed a Sept. 26 – 28, 2013 conference to be hosted in Vancouver by UNESCO (United Nations Educational, Scientific, and Cultural Organization), “Memory of the World in the Digital Age: Digitization and Preservation.” (UNESCO’s Memory of the World programme hosts a number of these themed conferences and workshops.)

The Sept. 2013 UNESCO ‘memory of the world’ conference in Vancouver seems rather timely in retrospect. The Council of Canadian Academies (CCA) announced that Dr. Doug Owram would be chairing their Memory Institutions and the Digital Revolution assessment (mentioned in my Feb. 22, 2013 posting; scroll down 80% of the way) and, after checking recently, I noticed that the Expert Panel has been assembled and it includes Duranti. Here’s the assessment description from the CCA’s ‘memory institutions’ webpage,

Library and Archives Canada has asked the Council of Canadian Academies to assess how memory institutions, which include archives, libraries, museums, and other cultural institutions, can embrace the opportunities and challenges of the changing ways in which Canadians are communicating and working in the digital age.
Background

Over the past three decades, Canadians have seen a dramatic transformation in both personal and professional forms of communication due to new technologies. Where the early personal computer and word-processing systems were largely used and understood as extensions of the typewriter, advances in technology since the 1980s have enabled people to adopt different approaches to communicating and documenting their lives, culture, and work. Increased computing power, inexpensive electronic storage, and the widespread adoption of broadband computer networks have thrust methods of communication far ahead of our ability to grasp the implications of these advances.

These trends present both significant challenges and opportunities for traditional memory institutions as they work towards ensuring that valuable information is safeguarded and maintained for the long term and for the benefit of future generations. It requires that they keep track of new types of records that may be of future cultural significance, and of any changes in how decisions are being documented. As part of this assessment, the Council’s expert panel will examine the evidence as it relates to emerging trends, international best practices in archiving, and strengths and weaknesses in how Canada’s memory institutions are responding to these opportunities and challenges. Once complete, this assessment will provide an in-depth and balanced report that will support Library and Archives Canada and other memory institutions as they consider how best to manage and preserve the mass quantity of communications records generated as a result of new and emerging technologies.

The Council’s assessment is running concurrently with the Royal Society of Canada’s expert panel assessment on Libraries and Archives in 21st century Canada. Though similar in subject matter, these assessments have a different focus and follow a different process. The Council’s assessment is concerned foremost with opportunities and challenges for memory institutions as they adapt to a rapidly changing digital environment. In navigating these issues, the Council will draw on a highly qualified and multidisciplinary expert panel to undertake a rigorous assessment of the evidence and of significant international trends in policy and technology now underway. The final report will provide Canadians, policy-makers, and decision-makers with the evidence and information needed to consider policy directions. In contrast, the RSC panel focuses on the status and future of libraries and archives, and will draw upon a public engagement process.

So, the government is shutting down libraries in order to save money and they’re praying (?) that the materials have been digitized and adequate care has been taken to ensure that they will not be lost in some disaster or other. Meanwhile the Council of Canadian Academies is conducting an assessment of memory institutions in the digital age. The approach seems to backwards.

On a more amusing note, Rick Mercer parodies at lease one way scientists are finding to circumvent the cost-cutting exercise in an excerpt (approximately 1 min.)  from his Jan. 29, 2014 Rick Mercer Report telecast (thanks Roz),

Mercer’s comment about sports and Canada’s Prime Minister, Stephen Harper’s preferences is a reference to Harper’s expressed desire to write a book about hockey and possibly a veiled reference to Harper’s successful move to prorogue parliament during the 2010 Winter Olympic games in Vancouver in what many observers suggested was a strategy allowing Harper to attend the games at his leisure.

Whether or not you agree with the decision to shutdown some libraries, the implementation seems to have been a remarkably sloppy affair.

Canada-US Regulatory Cooperation Council’s Nanotechnology Work Plan

Thanks for Lynn L. Bergeson for her Dec. 1, 2012 posting on the Nanotechnology Now website for the information about a Nov. 28, 2012 webinar that was held to discuss a Nanotechnology Work Plan developed by the joint Canada-US Regulatory Cooperation Council (or sometimes it’s called the US-Canada Regulatory Cooperation Council),

The RCC requested that industry provide more information on the commercial distribution of nanomaterials, as well as more transparency by claiming confidentiality of only that information absolutely critical to market advantage.

To compare risk assessment and risk management practices to highlight and identify best practices, data gaps, and differences between the two jurisdictions, the RCC sought nominations of a nanomaterial substance for a case study. Four nanomaterial substances were nominated: multiwall carbon nanotubes, nanocrystalline cellulose, nano silver, and titanium dioxide. The RCC has selected multiwall carbon nanotubes for the case study. The RCC intends to hold in March 2013 a workshop in Washington, D.C., to discuss information collected to date and approaches moving forward. In spring 2013, the RCC will hold one or two conference calls or webinars to discuss information gathered between countries and the path forward. Finally, in fall 2013, the RCC expects to hold a stakeholder consultation/workshop on results to date.

Here’s some background on the RCC. First announced in February 2011, the RCC had its first ‘stakeholder’ session (attended by approximately 240)  in January 2012 in Washington, DC. where a series of initiatives, including nanotechnology, were discussed (from the US International Trade Administration RCC Stakeholder Outreach webpage),

Agriculture and Food, Session A

  • Perimeter approach to plant protection

Agriculture and Food, Session B

  • Crop protection products

Agriculture and Food, Session C

  • Meat/poultry – equivalency
  • Meat/poultry – certification requirements
  • Meat cut nomenclature

Agriculture and Food, Session D

  • Veterinary drugs
  • Zoning for foreign animal disease

Agriculture and Food, Session E

  • Financial protection to produce sellers

Agriculture and Food, Session F

  • Food safety – common approach
  • Food safety – testing

Road Transport – Motor Vehicles

  • Existing motor vehicle safety standards
  • New motor vehicle safety standards

Air Transport

  • Unmanned aircraft

Transportation

  • Intelligent Transportation Systems

Transportation

  • Dangerous goods means of transportation

Marine Transport

  • Safety and security framework & arrangement for the St. Lawrence Seaway & Great Lakes System
  • Marine transportation security regulations
  • Recreational boat manufacturing standards
  • Standard for lifejackets

Rail Transport

  • Locomotive Emissions
  • Rail Safety Standards

Environment

  • Emission standards for light-duty vehicles

Personal Care Products & Pharmaceuticals

  • Electronic submission gateway
  • Over-the-counter products – common monographs
  • Good manufacturing practices

Occupational Safety Issues

  • Classification & labelling of workplace hazardous chemicals

Nanotechnology

  • Nanotechnology

Led jointly by senior officials from Canada and the United States, the purpose of the various technical review sessions was to seek expert advice and technical input from the approximately 240 stakeholders in attendance.

Since the Jan. 2012 meeting, a Nanotechnology Work Plan has been developed and that’s what was recently discussed at the Nov. 28, 2012 webinar. I did find more on a Canadian government website, Canada’s Economic Action Plan Nanotechnology Work Plan webpage,

Nanotechnology Work Plan

 Canada Leads: Karen Dodds, Assistant Deputy Minister, Science and Technology Branch, Environment Canada (EC)

Hilary Geller, Assistant Deputy Minister, Healthy Environments and Consumer Safety Branch, Health Canada (HC)

U.S. Lead: Margaret Malanoski, Office of Information and Regulatory Affairs, Office of Management and Budget

Deliverable Outcome: Share information and develop common approaches, to the extent possible, on foundational regulatory elements, including criteria for determining characteristics of concern/no concern, information gathering, approaches to risk assessment and management, etc. Develop joint initiatives to align regulatory approaches in specific areas such that consistency exists for consumers and industry in Canada and the US.

Principles: Identification of common principles for the regulation of nanomaterials to help ensure consistency for industry and consumers in both countries

3-6 months:

Canada provides initial feedback on US “Policy Principles for the US Decision-Making Concerning Regulation and Oversight of Applications of Nanotechnology and Nanomaterials”.

6-12 months:

Countries complete an initial draft of shared principles for the regulation of nanomaterials.

12-18 months:

Update of draft principles informed from on-going stakeholder and expert consultations.

18th month:

Stakeholder consultation / workshop on results to date and future ongoing engagement.

Beyond 18 months:

Countries complete final draft of shared principles for the regulation of nanomaterials.

Workplan for Industrial Nanomaterials

Priority-Setting: Identify common criteria for determining characteristics of industrial nanomaterials of concern/no-concern

1-3 months:

  1. Define and finalize workplan (1st month)
  2. Develop mechanisms for stakeholder outreach and engagement (1st month)
  3. Conference call with relevant stakeholders to share and discuss workplan and call for Industry to volunteer nanomaterials for joint CAN/US review

3-6 months:

Share available scientific evidence regarding characteristics of industrial nanomaterials including that obtained from existing international fora (e.g. OECD Working Party on Manufactured Nanomaterials [Canada is a lead in the OECD Working Party on Manufactured Nanomaterials]).

8th month:

Stakeholder workshop to discuss information collected to date and approaches moving forward.

6-12 months:

Initiate an analysis of characteristics of select nanomaterials: similarities, differences, reasons for them.

Initiate discussions on approaches to consider for common definitions and terminology.

12th month:

Second conference call with relevant stakeholders to discuss non-CBI information gathered between the Countries and to discuss path forward in terms of development of reports and analyses.

12-18 months:

Develop draft criteria for determining characteristics of industrial nanomaterials of concern/no-concern.

15th month:

Third conference call with relevant stakeholders to discuss progress and to prepare for the upcoming stakeholder consultation/workshop.

Here’s information for the leads should you feel compelled to make contact,

Canada

(Lead) Karen Dodds, Assistant Deputy Minister, Science and Technology, Environment Canada ([email protected]; ph. 613- 819-934-6851)

Hilary Geller, Assistant Deputy Minister, Healthy Environments and Consumer Safety Branch ([email protected]; ph. 613-946-6701)

United States

(Lead) Margaret Malanoski, Office of Management and Budget ([email protected])

I gather that the ‘stakeholders’ are business people, researchers, and policy analysts/makers as there doesn’t seem to be any mechanism for public consultation or education, for that matter.

Trent University (Ontario, Canada) and nanosilver toxicology studies

One of the scientists on a research team at Trent University (Ontario, Canada) is claiming that safety questions about nanomaterials are not being asked and so the team is embarking on a study of silver nanoparticles and their impact on a lake ecosystem. From the May 2, 2012 news item on Nanowerk,

Dr. Chris Metcalfe, professor and director of the Institute for Watershed Science at Trent University, is the principal investigator on the Lake Ecosystem Nanosilver (LENS) project with Trent researchers, Drs. Maggie Xenopoulos, Holger Hintelmann and Paul Frost, and colleagues from Fisheries and Oceans Canada and Environment Canada.

“This is a high profile project that will have the eyes of the scientific community on Trent,” said Professor Metcalfe. “We’re fortunate that we have four world-class researchers on our team.” Over the past decade, tiny substances called nanomaterials have become part of our daily lives.

It’s possible that the clothes you’re wearing, or the sunscreen you just applied, contain nanomaterials. Because of this growing use, there is now concern that nanomaterials may pose threats to the environment.

“We have seen an exponential growth in the use of nanomaterials,” said Professor Xenopoulos, an associate professor in the Biology department at Trent University. “However, questions of safety are not being asked.” [emphasis mine]

Likely the claim is a little overenthusiasm or a lack of clarity on the speaker’s part since there has been more than one study about nanosilver particles and safety, including one at Purdue University mentioned in a March 4, 2010 posting on the Beyond Pesticides blog. The Purdue study (The effects of silver nanoparticles on fathead minnow (Pimephales promelas) embryos) is behind a paywall.

Here’s a bit more about silver nanoparticles and the LENS study,

While the benefits of nanomaterials are recognized, we know little about their risks to health and the environment. Due to their extremely small size, nanomaterials interact with cells and organic molecules, raising questions about their impact on organisms.

Due to their antibacterial properties, nanosilver particles are among the most widely-used nanomaterials in consumer goods. Clothing, home appliances, paint, bandages and food storage containers are a few of the products which may contain nanosilver. As we use and dispose of these products, there is a risk that nanosilvers will travel through our municipal water systems into our lakes and rivers.

The research team is working to understand the effect of nanosilver particles on the aquatic environment. Initial laboratory research conducted at Trent indicates that nanosilver can strongly affect aquatic organisms at the bottom of the food chain, such as bacteria, algae and zooplankton.

To further examine these effects in a real ecosystem, the team is conducting a study at the Experimental Lakes Area, near Kenora, in northwestern Ontario.

The LENS project will monitor changes in a lake’s ecosystem that occur after the addition of nanosilver. It will follow nanosilver as it travels through the lake ecosystem, track effects through the entire food web, and determine how resulting changes alter ecosystem function.

There’s more about the LENS project on the Trent University LENS (Lake Ecosystem Nanosilver) Project page (excerpt),

Our previous laboratory research has shown that nanosilver in the aquatic environment first affect organisms at the bottom of the food chain, including bacteria, algae and zooplankton. These responses may have devastating effects upon aquatic ecosystems by reducing overall productivity and altering the cycling of nutrients, such as carbon, nitrogen and phosphorus. There may be compensatory mechanisms within aquatic ecosystems that can mitigate these responses, but it is impossible to predict these responses using laboratory studies. Through support from the Strategic Grants Program of the Natural Sciences and Engineering Research Council of Canada and Environment Canada, a team of researchers from Trent University, Environment Canada and Fisheries and Oceans Canada will conduct a study at the Experimental Lakes Area (ELA) in northwestern Ontario by adding nanoform silver to a small lake over two summer field seasons ion 2013-14. During nano-silver additions, we will monitor the lake for changes to nutrient cycling and the biological effects within the entire food chain. However, in 2012, before starting the lake additions, we will refine our approach by determining what happens in mesocosms (i.e. plastic tubes) that are deployed in lakes. ELA has been used for over 40 years as a living laboratory to study the effects of pollutants in the environment, including past studies of the impacts of pollution from phosphorus, acid deposition, mercury and endocrine disruptors. These studies have resulted in policies to reduce the impacts of pollution. While we do not take lightly the impact that this study will have upon a lake in ELA, this approach is the only way to determine ecosystem level impacts and to influence regulatory policy regarding the ecological risks of NMs.

This is a three-year project, which starts this year (2012).

One more muzzle for Canadian government scientists

It’s a wee bit puzzling as to why government scientist (Natural Resources Canada), Scott Dallimore had to get permission from the minister before talking to journalists about his co-authored study featuring a flood in northern Canada that took place 13,000 years ago. From the article by Margaret Munro for PostMedia News on canada.com (ETA Jan. 6, 2014: Munro’s article seems to have been removed for all the news sites but it  can be found on her own blog here.)

NRCan [Natural Resources Canada] scientist Scott Dallimore co-authored the study, published in the journal Nature on April 1, about a colossal flood that swept across northern Canada 13,000 years ago, when massive ice dams gave way at the end of the last ice age.

The study was considered so newsworthy that two British universities issued releases to alert the international media.

It was, however, deemed so sensitive in Ottawa that Dallimore, who works at NRCan’s laboratories outside Victoria, was told he had to wait for clearance from the minister’s office.

Dallimore tried to tell the department’s communications managers the flood study was anything but politically sensitive. “This is a blue sky science paper,” he said in one email, noting: “There are no anticipated links to minerals, energy or anthropogenic climate change.”

But the bureaucrats in Ottawa insisted. “We will have to get the minister’s office approval before going ahead with this interview,” Patti Robson, the department’s media relations manager, wrote in an email after a reporter from Postmedia News (then Canwest News Service) approached Dallimore.

Robson asked Dallimore to provide the reporter’s questions and “the proposed responses,” saying: “We will send it up to MO (minister’s office) for approval.” Robson said interviews about the flood study needed ministerial approval for two reasons: the inquiring reporter represented a “national news outlet” and the “subject has wide-ranging implications.”

At this point Environment Canada and Health Canada have similar rules in place for their scientists and any potential media interviews. I have commented on a similar situation previously in my Sept. 21 2009 posting, which includes a link to an earlier story by Margaret Munro about Environment Canada and its gag order.

I gather the scientists can discuss the gag order without recourse to the ‘Minister’s Office’, they just can’t discuss their own work. That seems rather odd especially in light of a government that loves to trumpet its investment in science. If the public never gets to hear about the exciting discoveries that our publicly funded scientists are making, how can the government expect to get support for its science spending policies?

Regulating nanomaterials according to the US GAO and EPA

It’s been a banner week for information about nanomaterials regulation. As I noted yesterday, the US General Accountability Office has just released its  report titled Nanotechnology: Nanomaterials Are Widely Used in Commerce, but EPA Faces Challenges in Regulating Risk. Hats off to the authors: Anu Mittal, lead author, and Elizabeth Erdmann, David Bennett, Antoinette Capaccio, Nancy Crothers, Cindy Gilbert, Gary Guggolz, Nicole Harkin, Kim Raheb, and Hai Tran.

In discussing some of the oversight and regulatory issues associated with nanotechnology and other emerging technologies they had this to say (from the report),

Nanotechnology is an example of a fast-paced technology that poses challenges to agencies’ policy development and foresight efforts. We have conducted past work looking at the challenges of exercising foresight when addressing potentially significant but somewhat uncertain trends,5 including technology-based trends that proceed at a high “clockspeed,” that is, a (1) faster pace than trends an agency has dealt with previously or (2) quantitative rate of change that is either exponential or exhibits a pattern of doubling or tripling within 3 or 4 years, possibly on a repeated basis.6 As our prior work has noted, when an agency responsible for ensuring safety faces a set of potentially significant high-clockspeed technology-based trends, it may successfully exercise foresight by carrying out activities such as

• considering what is known about the safety impact of the trend and deciding how to respond to it;

• reducing uncertainty as needed by developing additional evidence about the safety of the trend; and

• communicating with Congress and others about the trends, agency responses, and policy implications.

Similarly, our 21st Century Challenges report raised concern about whether federal agencies are poised to address fast-paced technology-based challenges. [GAO, 21st Century Challenges: Reexamining the Base of the Federal Government, GAO-05-325SP (Washington, D.C.: February 2005)] Other foresight literature illustrates the potential future consequences of falling behind a damaging trend that could be countered by early action. These analyses suggest that unless agencies and Congress can stay abreast of technological changes, such as nanotechnology, they may find themselves “in a constant catch-up position and lose the capacity to shape outcomes.” (p.7/8 print version, p. 11/2 PDF)

(Seems to me the Canadian government could also do with some thoughtful consideration of fast-changing technologies and the challenges they pose to the institutional oversight mechanisms currently in place.)

The report goes on to describe various nano-enabled product categories in various industry sectors. It’s an overview that includes products (e.g. nano-enabled cell phones) currently or soon-to-be on the market. I was particularly taken with an image of a cell phone  that tagged parts  already nano-enabled (on some models) along with parts that may, in the future, become nano-enabled (p. 14 print version or p. 18 PDF).

The toxicity roundup is one of the best presentations I’ve seen. For example,

  • Size. Research assessing the role of particle size on toxicity has generally found that some nanoscale (<100 nanometers) particles are more toxic and can cause more inflammation than conventionally scaled particles of the same composition. Specifically, some research indicates that the toxicity of certain nanomaterials, such as some forms of carbon nanotubes and nanoscale titanium dioxide, may pose a risk to human health because these materials, as a result of their small size, may be able to penetrate cell walls, causing cell inflammation and potentially leading to certain diseases. For example, the small size of these nanomaterials may allow them to penetrate deeper into lung tissue, potentially causing more damage, according to some of the studies we reviewed. In addition, some nanomaterials may disperse differently into the environment than conventionally scaled materials of the same composition because of their size. However, according to EPA, the small particle size may also cause the nanomaterials to agglomerate, which may make it more difficult for them to penetrate deep lung tissue. (pp. 23/4 print version, pp. 27/8 PDF)

This a much more measured but still cautious approach to the toxicology issues as they relate to size and this approach is maintained throughout.

There’s more than one way to be exposed,

In addition to toxicity, the risk that nanomaterials pose to humans and the environment is also affected by the route and extent of exposure to such materials. Nanomaterials can enter the human body through three primary routes: inhalation, ingestion, and dermal penetration. (p. 25 print version, p. 29 PDF)

They also make the distinction between exposure as a consequence of consuming products and exposure due to occupation.

Moving on from toxicity, their section on the international scene wowed me because this is the only report I’ve seen which notes that Canada’s nanomaterials inventory has yet to occur.

One thing I hadn’t realized was how similar Environment Canada’s and the US Environmental Protection Agency’s approach to nanomaterials has been. From my April 2, 2010 posting,

Here’s what Environment Canada has to say about nanomaterials (the information on this page is dated from 2007 …) NOTE: The page originally cited is no longer available, go to this page,

The Domestic Substances List (DSL) is the sole basis for determining whether a substance is new. Any chemical or polymer not listed on the DSL is considered to be new to Canada and is subject to the notification requirements under the Regulations. Substances listed on the DSL do not require notification1 in advance of manufacture in or import into Canada.

The Act and the Regulations apply to new nanomaterials just as any other substance, whether a chemical or a polymer.

Substances listed on the DSL whose nanoscale forms do not have unique structures or molecular arrangements are considered existing. Existing nanomaterials are not subject to the Regulations and do not require notification. For example, titanium dioxide [emphasis mine] (CAS No. 13463-67-7) is listed on the DSL and since its nanoscale form does not have unique structures or molecular arrangements, it is not subject to the Regulations.

Compare,

In its 2008 document, EPA stated that a nanomaterial is a new chemical for purposes of regulation under TSCA only if it does not have the same “molecular identity” as a chemical already on the inventory. Under TSCA, a chemical is defined in terms of its particular molecular identity.

Thus, because titanium dioxide is already listed on the TSCA inventory, nanoscale versions of titanium dioxide, which have the same molecular formula, would not be considered a new chemical under TSCA, despite having a different size or shape, different physical and chemical properties, and potentially different risks. [emphasis mine] (p. 34 print version, p. 38 PDF)

I gather the EPA adopted the strategy one year after Environment Canada. Given how often the various jurisdictions copy each other’s approaches, I wonder which country (or possibly a jurisdiction such as the European Commission) actually set this strategy.

The report offers an excellent summary of Canada’s current regulatory approach and plans. I’ve reproduced the passage in full here,

Canadian officials have proposed but have not implemented a one-time requirement for companies to provide information on nanomaterials produced in or imported into Canada. Canadian importers and manufacturers would be required to report their use of nanomaterials produced or imported in excess of 1 kilogram. In 2009, Canadian officials reported to the OECD that information required would include chemical and trade name; molecular formula; and any available information on the shape, size range, structure, quantity imported or manufactured, and known or predicted uses. Also required would be any available information on the nanomaterial’s physical and chemical properties—such as solubility in water and toxicological data, among others. Under the proposal, companies could claim information as confidential, but regulators would publish a summary of information provided. Canada plans to use this information to help develop a regulatory framework for nanomaterials and to determine which information requirements would be useful for subsequent risk assessments. Canadian officials stated they originally hoped to issue this requirement in the spring of 2009 but could not predict when it would be implemented.

With regard to current law, a report prepared for the government of Canada in 2008 stated that Canada has no specific requirements for nanomaterials and is considering whether they are needed. However, Health Canada and Environment Canada—two agencies responsible for health and the environment—have taken the first steps in recognizing the potentially unique aspects of nanomaterials. These regulatory agencies are currently relying on existing authority delegated to them through legislation, such as the Canadian Environmental Protection Act, to address nanomaterials. Specifically, in June 2007, Environment Canada released a new substances program advisory announcing that nanomaterials will be regulated under the act’s new substances notification regulations. Per this advisory, any nanomaterial not listed on Canada’s chemical inventory—the Domestic Substances List—or with “unique structures or molecular arrangements” compared to their non-nano counterparts, requires a risk assessment. A review panel of the Canadian Academies found that, while it is not necessary to create new regulatory mechanisms to address the unique challenges presented by nanomaterials, the existing regulatory mechanisms could and should be strengthened in a variety of ways, such as by creating a specific classification for nanomaterials and by reviewing the regulatory triggers that prompt review of the health and environmental effects. (pp. 45/6 print version, pp. 49/50 PDF)

As far as I’m aware, there are no comparable summaries available in Canadian reports available to the public. No doubt there are nits to be picked but all I can say is thank you for giving me the most comprehensive and succinct overview I’ve seen yet of the emerging Canadian regulatory framework for nanomaterials.

For interested parties, there is some additional information about Health Canada’s public consultation on their interim definition of nanomaterials in my April 28, 2010 posting.

Synthetic biology: commercialization, Canadian farmers, and public discourse

You may see synthetic biology (or more properly a synthetic organism) referred to as ‘Synthia’. The term was coined (or, for some word play, created) by the ETC Group as they note in their May 20, 2010 news release about J. Craig Venter’s latest accomplishment (noted on this blog here and here),

The construction of this synthetic organism, anticipated and dubbed “Synthia” by the ETC Group three years ago, will stir a firestorm of controversy over the ethics of building artificial life and the implications of the largely unknown field of synthetic biology.

Clearly the ETC Group, which is based in Canada, has been gearing up for a campaign. It’ll be interesting to note whether or not they are successful at making ‘Synthia’ stick. I gather the group was able to capitalize on ‘frankenfoods’ for the campaign on genetically modified foods but someone else coined that phrase for them. (You can read about who coined the phrase in Susan Tyler Hitchcock’s book, Frankenstein; a cultural history.)

The advantage with ‘frankenfoods’ is the reference to an internationally recognized cultural icon, Frankenstein, and all of the associations that naturally follow. With ‘Synthia’, the ETC Group will have to build (link? graft?) the references to/onto the term.

I shouldn’t forget that the ETC Group does make an important point with this,

The team behind today’s announcement, led by controversial scientist and entrepreneur Craig Venter, is associated with a private company, Synthetic Genomics Inc, bankrolled by the US government and energy behemoths BP and Exxon. Synthetic Genomics recently announced a $600 million research and investment deal with Exxon Mobil in addition to a 2007 investment from BP for an undisclosed amount. Venter, who led the private sector part of the human genome project ten years ago, has already applied for patents related to Synthia’s technology.

In a possibly related (to the ETC Group) statement, the National Farmers Union (NFU) had this to say (from the May 22, 2010 news item on CBC News),

The National Farmers Union says the development of a synthetic cell could lead to worrisome, long-term consequences.

“This new technology raises serious concerns about who controls it, what it will be used for, and its potential impact,” [Terry] Boehm [president, NFU] said.

There are two things I want to note. First, the concerns raised by the ETC Group, the NFU, and others in Canada and across the globe are important and require discussion. Second, all of the parties involved business interests, civil society groups, scientists, government agencies, etc. work independently and together (formally and informally) to promote their interests.

In a related note: In a May 23, 2010 CBC news item (published on Sunday during a long weekend),

The government is looking for ways to monitor online chatter about political issues and correct what it perceives as misinformation.

The move started recently with a pilot project on the East Coast seal hunt. A Toronto-based company called Social Media Group has been hired to help counter some information put forward by the anti-sealing movement.

The Department of Foreign Affairs and International Trade has paid the firm $75,000 “to monitor social activity and help identify … areas where misinformation is being presented and repeated as fact,” Simone MacAndrew, a department spokesperson, said in an email.

The firm alerts the government to questionable online comments and then employees in Foreign Affairs or the Department of Fisheries and Oceans, who have recently been trained in online posting, point the authors to information the government considers more accurate.

It appears to be just the beginning. [emphases mine]

(Digression alert! Does this mean I’ll be able to easily get more information about nanotechnology research in Canada, about the national institute, about nanomaterials, about proposed regulatory frameworks, etc.?)

I have to admit to being suspicious about this ‘information initiative’ when the announcement appears to have been made in an email during a holiday weekend. As well, it seems a bit schizoid given the government’s ban (I’ve commented about that here) on direct communication between journalists and scientists working for Environment Canada. So, the government will contact us if they think we have it wrong but a journalist can’t directly approach one of their scientists to ask a question.

Returning to my main focus, the impact that all these groups with their interests, by turns competitive and collegial, will have on the synthetic biology debate is impossible to evaluate at this time. It does seem that much of the framing for the discussion has been predetermined by various interest groups while the rest of us have remained in relative ignorance. I think the ‘pre-framing’ is inevitable given that most of us would not be interested in engaging in a discussion about developments which were largely theoretical, until recently.

For those who are interested in learning about the science and the debates, check out the Oscillator here. She notes that we’ve had some parts of this discussion as early as the 19th century,

My ScienceBlogs colleague PZ Myers compares the synthetic genome to Wöhler’s chemical synthesis of urea in 1828. In the 19th century, scientists debated whether or not the chemicals that make up living cells–organic chemistry–had to be made by a cell possessing a “vital spark” or could be made by humans in a test tube. By synthesizing urea from ammonium cyanate, Wöhler broke down some of the mysticism associated with living cells. From that point on, organic chemistry stopped being magic and became a science.

Does the Venter Institute’s achievement show that life is just chemicals? I don’t think so …

Comparing nanomaterials definitions: US and Canada

In light of yesterday’s (April 26, 2010) posting about Health Canada and their nanomaterials definition, Andrew Maynard’s April 23, 2010 post at 2020 Science (blog) is quite timely. Andrew has some details about new nanomaterials definitions being proposed in the both the US Senate and House of Representatives so that their Toxic Substances Control Act can be amended. From Andrew’s posting, an excerpt about the proposed House bill,

The House draft document is a little more explicit. It recommends amending section 3(2) of the original act with:

“(C) For purposes of this Act, such term may include more than 1 form of a substance with a particular molecular identity as described in sub-paragraph (A) if the Administrator has determined such forms to be different substances, based on variations in the substance characteristics. New forms of existing chemical substances so determined shall be considered new chemical substances.” (page 6)

with the clarification that

“The term ‘substance characteristic’ means, with respect to a particular chemical substance, the physical and chemical characteristics that may vary for such substance, and whose variation may bear on the toxicological properties of the chemical substance, including—

(A) chemical structure and composition

(B) size or size distribution

(C) shape

(D) surface structure

(E) reactivity; and

(F) other characteristics and properties that may bear on toxicological properties” (page 11)

Both the Senate bill and the House discussion document provide EPA with the authority to regulate any substance that presents a new or previously unrecognized risk to human health as a new substance. This is critical to ensuring the safety of engineered nanomaterials, where risk may depend on more than just the chemistry of the substance. But it also creates a framework for regulating any new material that presents a potential risk – whether it is a new chemical, a relatively simple nanomaterial, a more complex nanomaterial – possibly one that changes behavior in response to its environment, or a novel material that has yet to be invented. In other words, these provisions effectively future-proof the new regulation.

I prefer the definition in the draft House of Representatives bill to Health Canada’s because of its specificity and its future-oriented approach. Contrast their specificity with this from the Interim Policy Statement on Health Canada’s Working Definition for Nanomaterials:

Health Canada considers any manufactured product, material, substance, ingredient, device, system or structure to be nanomaterial if:

1. It is at or within the nanoscale in at least one spatial dimension, or;

2. It is smaller or larger than the nanoscale in all spatial dimensions and exhibits one or more nanoscale phenomena.

For the purposes of this definition:

* The term “nanoscale” means 1 to 100 nanometres, inclusive;

* The term “nanoscale phenomena” means properties of the product, material, substance, ingredient, device, system or structure which are attributable to its size [emphasis mine] and distinguishable from the chemical or physical properties of individual atoms, individual molecules and bulk material; and,

* The term “manufactured” includes engineering processes and control of matter and processes at the nanoscale.

You’ll notice the House of Representatives’ draft bill offers five elements to the description (chemical composition, size or size distribution [emphasis mine], shape, surface structure, reactivity, and other characteristics and properties that may bear on toxicological properties). So in the US they include elements that have been identified as possibly being a problem and leave the door open for future discovery.

The proposed legislation has another feature, Andrew notes that,

Both the Senate bill and the House discussion document provide EPA with the authority [emphasis mine] to regulate any substance that presents a new or previously unrecognized risk to human health as a new substance. This is critical to ensuring the safety of engineered nanomaterials, where risk may depend on more than just the chemistry of the substance. But it also creates a framework for regulating any new material that presents a potential risk – whether it is a new chemical, a relatively simple nanomaterial, a more complex nanomaterial – possibly one that changes behavior in response to its environment, or a novel material that has yet to be invented. In other words, these provisions effectively future-proof the new regulation.

As far as I can recall, Peter Julian’s (MP – NDP) tabled draft bill for nanotechnology regulation in Canada does not offer this kind of ‘future-proofing’ although it could be added if it is ever brought forward for debate in the House of Commons. Given the quantity of public and political discussion on nanotechnology (and science, in general) in Canada, I doubt any politician could offer those kinds of amendments to Julian’s proposed bill.

As for Canada’s proposed nanomaterials reporting plan/inventory/scheme, Health Canada’s proposed definition’s vagueness makes compliance difficult. Let me illustrate what I mean while I explain why I highlighted ‘size distribution’ in the House of Representatives draft bill by first discussing Michael Berger’s article on Nanowerk about environment, health and safety (EHS) research into the toxicological properties of nanomaterials. From Berger’s article,

” What we found in our work is that nanomaterials purchased from commercial sources may not be as well characterized as indicated by the manufacturer,” Vicki H. Grassian, a professor in the Department of Chemistry at the University of Iowa, tells Nanowerk. “For example, it might be stated that a certain nanoparticle is being sold as 30 nm in diameter and, although ’30 nm’ might be close to the average diameter, there is usually a range of particle sizes that can extend from as much as small as 5 nm to as large as 300 nm. [emphases mine]“

That’s size distribution and it reveals two problems with a reporting plan/inventory/scheme that uses a definition that sets the size within a set range. (Julian’s bill has the same problem although his range is 1 to 1000 nm.) First, what happens if you have something that’s 1001 nm? This inflexible and unswerving focus on size will frustrate the intent both of the reporting plan and of Julian’s proposed legislation. Second, how can a business supply the information being requested when manufacturers offer such a wide distribution of sizes in  products where a uniform size is claimed? Are businesses going to be asked to measure the nanomaterials? Two or three years or more after they received the products? [Aug.4.10 Note: Some grammatical changes made to this paragraph so it conveys my message more clearly.]

Then Berger’s article moves onto another issue,

Reporting their findings in a recent paper in Environmental Toxicology and Chemistry (“Commercially manufactured engineered nanomaterials for environmental and health studies: Important insights provided by independent characterization”), among other problems Grassian and first author Heaweon Park also discuss the issue of batch-to-batch variability during the production of nanoparticles and that some nanomaterials which were being sold as having spherical morphology could contain mixed morphologies such as spheres and rods [emphases mine].

That’s right, you may not be getting the same shape of nanoparticle in your batch. This variability should not pose a problem for the proposed reporting plan/inventory/scheme since shape is not mentioned in Health Canada’s definition but it could bear on toxicology issues which is why a plan/inventory/scheme is being proposed in the first place.

Interestingly, the only ‘public consultation’ meeting that Health Canada/Environment Canada has held appears to have taken place in 2007 with none since and none planned for the future (see my April 26, 2010 posting).

Apparently, 3000 stakeholders have been contacted and asked for responses. I do wonder if an organization like Nano Quebec has been contacted and counted not as a single stakeholder but as representing its membership numbers (e.g. 500 members = 500 stakeholders?) whatever they may be. There is, of course, a specific Health Canada website for this interim definition where anyone can offer comments. It takes time to write a submission and I’m not sure how much time anyone has to devote to it which is why meetings can be very effective for information gathering especially in a field like nanotechnology where the thinking changes so quickly. 2007 seems like a long time ago.

Finally, Dexter Johnson on his Nanoclast blog is offering more perspective on the recent Andrew Schneider/National Nanotechnology Initiative dust up. Yes, he gave me a shout out (and I’m chuffed) and he puts the issues together to provide a different perspective on journalistic reporting environment, health and safety issues as they relate to nanotechnology along with some of the issues associated with toxicology research.

Health Canada answers questions about a nanomaterials reporting plan/inventory and about its interim policy definition of nanomaterials; news flash: IBM & a plot to bomb their nanotech facility in Switzerland

I’ve been tracking down information about Canada’s manomaterials reporting plan/inventory/scheme since January 2009 when it was first announced publicly, i.e. somewhere other than a government report or government website. Here’s my most recent posting where I detail information found in a Feb. 2010 OECD (Organization for Economic Cooperation and Development) report. In my searches I also found a notice of a a request for comments (closing date: Aug. 31, 2010) about an Interim Policy Statement for Health Canada’s Working Definition for Nanomaterials . I gather this request for feedback/public consultation is being held prior to developing the ‘nanomaterials reporting plan’ for Canadian businesses to provide information about the nanomaterials in their products circa 2008.

The whole endeavour has been a bit puzzling so I emailed Health Canada with some questions which Christelle Legault, Media Relations Officer | Agente des relations avec les médias, Regulatory Communications and Media Relations Division | Division des communications réglementaires et des relations avec les médias, Public Affairs, Consultation and Communications Branch | Direction générale des affaires publiques, de la consultation et des communication, Health Canada | Santé Canada, very kindly answered. (Her business card must be very crowded.)

Q1 – Is information about this reporting plan/inventory/scheme publicly available other than in OECD documents? Where would the average Canadian be able to locate this info?

Plans to develop an information gathering initiative for nanomaterials were discussed as part of a previous multi-stakeholder workshop. Background information on this initiative is provided in the document entitled “Proposed Regulatory Framework for Nanomaterials under the Canadian Environmental Protection Act, 1999” available under “Nanomaterials” on Environment Canada’s New Substances Website at:

http://www.ec.gc.ca/subsnouvelles-newsubs

The New Substances Website is used to communicate information to stakeholders on the regulatory program for nanomaterials under the Canadian Environment Protection Act, 1999 (CEPA 1999).

Q2 – When is the projected date for the proposed reporting plan/inventory/scheme to take place? Will it be 2011?

Information gathering initiatives for nanomaterials are currently under consideration by the Government. At this time, there are no confirmed timelines.

Q3 – How did you promote this ‘Interim statement’ consultation so there’d be some response?

The Policy Statement on Health Canada’s Working Definition for Nanomaterials was distributed to over 3,000 stakeholders in Canada and internationally via e-mail, as well as being posted on Health Canada’s website:

http://www.hc-sc.gc.ca/sr-sr/consult/_2010/nanomater/index-eng.php

Q4 – Were you aware that your adopted definition for nanomaterials is not harmonious with the 2007 definition being used by Environment Canada where nano titanium dioxide (a very commonly used nanoparticle in many products) is explicitly excluded.

The New Substances Advisory Note that was published in 2007, entitled: Requirements for Nanomaterials under the New Substances Notification Regulations (Chemicals and Polymers), relates to existing legislation for nanomaterials under CEPA 1999. The Advisory Note does not define nanomaterials, rather it describes the requirements of existing legislation to notify new nanomaterials to the Government for assessment prior to import or manufacture.

Whereas, the Interim Policy Statement on Health Canada’s Working Definition for Nanomaterials is intended to provide guidance to stakeholders on the broad scope of what is considered a nanomaterial. The working definition establishes a working means of identifying nanomaterials that will support the administration of the various laws and regulations (including CEPA 1999) that the Government uses to regulate nanomaterials. The scope of the working definition is intended to be broad so that all Government legislative and regulatory programs are captured. In some cases, the scope of nanomaterials for specific regulatory programs may be narrower than that of Health Canada’s Working Definition.

Q5 – Are there plans for public outreach/dialogue/engagement events on the topic of nanomaterials and other nanotechnology issues?

HC will be providing feedback to stakeholders after the Interim Policy Statement consultation period is completed. Depending on the result of the consultation, HC will decide on the need to further engage the stakeholders.

Q6 – Is there going to be another multi-stakeholder meeting as there was in 2007, as per the OECD report?

There are currently no scheduled multi-stakeholder meeting concerning the Environment Canada-Health Canada nanomaterial regulatory program. However, the Government is committed to holding meaningful consultations with interested stakeholders as it further develops its nanomaterial regulatory program.

Q7 – If there will be another multi-stakholder meeting, do you have details about which civil society groups, academics, business interests, policy watchdogs, and other interested parties will be invited and when it will take place?

The consultation workshop held in 2007 had representation from a wide range of stakeholders including several industry associations and small and medium enterprises (SMEs), environmental and health NGOs as well as Canadian university researchers. Regulatory authorities from other jurisdictions and other Canadian federal government departments were also part of the consultative process. For future consultations, stakeholder participation will consist of similar representation and will also include other identified interested parties as nanotechnology activity in Canada increases.

Q8 – Is there a launch date (as opposed to the vague Spring 2010) for the proposed NanoPortal mentioned in the OECD report (no. 20, Feb. 2010) of the Working Party on Nanomaterials?

Health Canada’s NanoPortal is at the last stage of development. Health Canada is now working on the final details and will provide a launch date in the near future.

Thank you Ms. Legault for providing answers to my questions.

Plot to bomb IBM nanotech facility in Switzerland

There aren’t many details so I’m not sure how solid this information is but it seems that a small group of one woman and two men were arrested. April 15, 2010, in an apparent plot to bomb an IBM nanotech facility being built in Rueschlikon (near Zurich). You can read slightly more here. The news seems to have been broken just hours ago.