I believe this is the first time I’ve seen any guidelines for the safe handling of nanomaterials that are neither from Europe nor from the US. I imagine that’s due to translation issues or lack of publicity rather than a failure to create guidelines.
In any event, Indrani Barpujari, Advisor (Governance) at the Atal Bihari Vajpayee Institute of Good Governance and Policy Analysis, Bhopal, India, has written a commentary on draft regulations for India (from her Draft Guidelines for Safe Handling of Nanomaterials commentary in Economic and Political Weekly, Vol. 51, Issue No. 23, 04 Jun, 2016 ISSN [Online] – 2349-8846 [appears to be open access]),
It is indeed laudable that as a first step towards regulation of nanotechnology in India, the Nano Mission under the Department of Science and Technology has come out with the draft “Guidelines and Best Practices for Safe Handling of Nanomaterials in Research Laboratories and Industries.” Taking cognisance of the imperative for safe handling of nanomaterials, the Nano Mission has constituted a task force consisting of eminent experts who have prepared this document. Involving the control of matter at the nanoscale, nanomaterials are characterised by small dimensions, large surface area, and high reactivity which while making them amenable to a large variety of applications in various sectors also render them potentially dangerous for human health and environmental safety, with considerable scientific uncertainty regarding the risks. Nanotechnology presents before policymakers a classic case of “Collingridge dilemma” or a “dilemma of control” with policy decisions required to be taken on the basis of uncertain scientific facts and under conditions of some urgency. It is the unique combination of “high expectations and huge uncertainties” (Van Lente 2010) associated with nanotechnology which has provided the required thrust for the current guidelines.
The draft guidelines, basically intended as standard operating procedure (SOP) for handling nanomaterials in research laboratories and industries, prescribe a combination of engineering controls, work practices and personal protective equipment as part of a robust exposure control strategy. These lay down the process for identifying hazards, taking note of the specific effect of surface chemistry, shape, size and morphology on toxicity caused to various organs. These address the potential exposure pathways and concomitant safety measures to mitigate the same. While prescribing certain best practices for handling nanomaterials generally, the guidelines also lay down another set of best practices specifically pertaining to the making and handling of nanopowders and use of products relating to food and healthcare. A precautionary approach is advocated with detailed life cycle assessment and strong binding procedures with respect to stakeholder involvement for various players while formulating best practices in the food sector particularly.
While the draft guidelines as a first step cover reasonable ground, it may be relevant to look at these in the context of the discourse on nanotechnology regulation abroad as well as in India. The focus of modern “risk societies” being more on “manufactured risks” or risks which are the product of human activity (Giddens 1999), governments, particularly in the developed world, are increasingly realising the need for risk-based regulation, to address potential risks from emerging technologies like nanotechnology, while promoting their development. Preliminary steps have been taken to regulate nanotechnology despite the admitted difficulty in doing so owing to the scientific uncertainty regarding its risks and limited amenability to traditional risk management approaches (Schummer and Pariotti 2008).
Thus, it may be surmised that the developed world’s engagement with nanotechnology to harness its benefits has been characterised by an almost unprecedented focus on regulating its risks and developing an anticipatory governance framework, taking on board different stakeholders including the public and incorporating societal concerns. On the other hand, with an almost single-minded focus on promotion in the initial years, the official pursuit of nanotechnology in India has not accorded much priority to its potential risks with the result than a large number of nano-based products are already out in the markets, without any regulation (Barpujari 2011a). In India, the government is the primary promoter of nanotechnology, pursued under the mission on nanoscience and technology (Nano Mission) with a huge budget outlay targeted at the development of nano-applications and creating adequate infrastructural and human capabilities for this purpose.
The Indian scientific establishment has high expectations from nanotechnology, with the technology expected to help meet the development needs of the country, while also positioning India as a forerunner in the global arena. Srivastava and Chowdhury (2008) observe that Indian scientists at the helm of affairs perceive that Indian science should not lose out on this opportunity to establish itself as a global leader and that it should not “miss the bus” as it did during the previous semiconductor revolution. Sahoo and Deshpande Sarma’s (2010) survey on risk perceptions among thirty scientists working in public-funded scientific institutions/laboratories indicate that Indian scientists are not very much perturbed by the risks of nanotechnology, and few take special precautions while working with nanomaterials, while very few are interested in taking up risk research.
The fact that the policy establishment is yet to take into serious consideration the potential risks of the technology is also evident from the low priority accorded to risk research, which should precede regulation. A very small number of projects are being publicly funded to look into toxicity issues, and there is almost no engagement with the social sciences and humanities, as evidenced by the lack of government funding for such studies.
At the same time, it must be acknowledged that different stakeholders in India particularly policy researchers, civil society actors and research institutions pursuing risk research have been persistently making the case for nanotechnology regulation in the country and taken the lead in charting the way ahead. It is acknowledged that problems in developing risk-based regulation are particularly compounded for a developing country like India, owing to a lack of resources, expertise and regulatory mandate. The absence of regulation, it is anticipated, would be even worse as in the event of some of the risks materialising, developing countries would be ill-equipped to handle and mitigate these (Barpujari 2011b).
Particularly noteworthy is a regulatory matrix for India developed by TERI [The Energy and Resources Institute] (2009) comprising several central legislation, rules and notifications which could have relevance for regulation of environmental risks, occupational health and safety risks arising from nanotechnology development and applications in India. Another report (TERI 2012) has provided leads for adopting a precautionary approach and developing an anticipatory regulatory framework for nanotechnology in the South Asian region, taking the particular case of India, Pakistan and Sri Lanka.
Vajpayee offers more insight with her suggestions for “The Way Ahead” and I strongly suggest reading her commentary if you’re interested in a perspective from South Asia. There’s also a list of references at the end of the commentary, should you wish to explore further.