Tag Archives: nanosunscreens

Canada’s plans for nanosunscreens mentioned at Europe’s Nanotechnology Safety for Success Dialogue and sunscreens in Australia

I posted (April 14, 2011) about the March 29 – 30, 2011 Nanotechnology Safety for Success Dialogue which took place in Brussels (Belgium). I took note of a fierce debate over a nanomaterials definition. (The debate was whether there should be an interim definition or if they should wait until they had enough information to create a finalized definition.

Thankfully a reader has recently redirected my attention to this meeting as I had failed to notice that Canada made a presentation at the meeting. Consequently, I have found more information about Canada’s nanotechnology activities as they pertain to safety through an international organization. (I have searched the Health Canada website and the Canadian federal nanoportal and am unable to locate this presentation on either site.)

The presentation (all 15 slides) was given by Ratna Bose, Ph. D., Manager, Nonprescription Drugs Evaluation Division; Bureau of Gastroenterology, Infection, and Viral Diseases; Therapeutic Products Directorate. There is a Health Portfolio Nanotechnology WG (I imagine this means working group). Here’s how the portfolio is organized and managed (from slide #3),

Chaired by Science Policy Directorate
• Co-ordinates activities and facilitates information sharing on nanotechnology and nanomaterials within HC
• Includes representatives from Directorates regulating nanomaterials
• Each Directorate is responsible for policies and guidances specific to their respective jurisdiction

Here are the products Health Canada regulates (from slide #5),

Health Canada Regulated Products that May Contain Nanotechnology

• Drugs
• Medical devices
• Biotechnology products
• Tissue engineering products
• Vaccines
• Natural Health products
• Food Ingredients, packaging, manufacturing process

I notice that the head states that the products may contain nanotechnology, which seems odd. They might contain nanomaterial(s) and/or be nanotechnology-enabled but they can’t contain nanotechnology in the same way they contain biology. Plus, I thought Agriculture Canada regulated food (I will check this out).

This is what they are proposing for future work (from slide #12),

Regulatory Perspective
Develop standardized risk assessment methods
Develop regulatory, product-specific guidance documents
Build regulatory capacity/expertise

Scientific Perspective
Continue participation in international activities (e.g., ISO, OECD)
Explore collaborative work to develop methodologies to detect, characterize and measure NMs by working with industry as well as domestic and international partners

Awareness Perspective
Develop public engagement and risk communication strategies
Engage industry stakeholders

Under Awareness Perspective they’ve linked public engagement and risk communication together. Is risk communication the only reason they’re planning public engagement?

The slides indicate that there will be a case study developed around nanosunscreens. From slides 13 & 14,

Sunscreens are regulated as drugs in Canada, subject to either the Food and Drug Regulations or the Natural Health Product Regulations depending on the active ingredient and claim.

The Sunburn Protectants Monograph outlines active ingredients and their concentrations, as well as appropriate warnings, directions for use, and claims which are generally considered to be safe and effective.

The nanomaterial based sunscreens are excluded from the Sunburn Protectants monograph.

In order to satisfy the Safety & Effectiveness requirements of the Regulations, safety data are being requested.

I wonder where the safety data is coming from?

Meanwhile, there was a May 23, 2011 post by Dr. Andrew Maynard on the University of Michigan’s Risk Science Blog about a recent nanosunscreen event in Australia. From the posting,

Last week, the Victoria branch of the Australian Education Union (AEU) passed a resolution recommending that “workplaces use only nanoparticle-free sunscreen” and that sunscreens used by members on children are selected from those “highlighted in the Safe Sunshine Guide produced by Friends of the Earth” as being nano-free. The AEU also resolved to provide the Friends of the Earth Safe Sunscreen Guide and Recommendations to all workplaces their members are associated with. Given what is currently known about sunscreens – nano and otherwise, I can’t help wonder whether this is an ill-advised move.

The debate over the safety or otherwise of nanoparticle-containing sunscreens has been going on for over a decade now. Prompted by early concerns over possible penetration through the skin and into the body of the nanosized titanium dioxide and/or zinc oxide particles used in these products – and potential adverse impacts that might result – there has been a wealth of research into whether these small particles can actually get through the skin when applied in a sunscreen. And the overall conclusion is that they cannot. There have been a small number of studies that demonstrate that, under specific conditions, some types of nanoparticle might penetrate through the upper layers of the skin. But the overwhelming majority of studies have failed to find either plausible evidence for significant penetration, or plausible evidence for adverse health impacts [emphasis mine] – a body of evidence that led the Environmental Working Group to make an about-face from questioning the use of nanoparticle-containing sunscreens to endorsing them in 2010.

If you’re interested in the nanosunscreen discussion, I highly recommend Andrew’s writing on the subject, the report by the Environmental Working Group, and the report by the Friends of the Earth for a comprehensive view of the discussion.

As for me, I believe, given the information at hand, that nanosunscreens are relatively safe for most adults and I reserve the right to change my opinion should new information emerge. Meanwhile, I look forward to learning more about Health Canada’s nanotechnology safety efforts and hope that one day the information will be easily accessible on the Health Canada website or the federal nanoportal. Who knows maybe there’ll be a public engagement exercise on the topic of nanosunscreens?

ETC group, nanotechnology and Africa

There’s a lot of valuable information and insight along with an almost old-fashioned approach to the politics in the October 6, 2010 article, Big continent and tiny technology: Nanotechnology and Africa, by Kathy Jo Wetter of the ETC Group. The article is well written and researched. Here’s an excerpt from the its technical explanation of nanotechnology,

Nanotechnology is a suite of techniques used to manipulate matter on the scale of atoms and molecules. Nanotechnology speaks solely to scale: Nano refers to a measurement, not an object. A nanometre (nm) equals one-billionth of a metre. Ten atoms of hydrogen lined up side-by-side equal one nanometre. A DNA molecule is about 2.5nm wide (which makes DNA a nanoscale material). A red blood cell is enormous in comparison: about 5,000nm in diameter. Everything on the nanoscale is invisible to the unaided eye and even to all but the most powerful microscopes….

Key to understanding the potential of nanotech is that, at the nanoscale, a material’s properties can change dramatically; the changes are called ‘quantum effects’. With only a reduction in size (to around 300nm or smaller in at least one dimension) and no change in substance, materials can exhibit new characteristics – such as electrical conductivity, increased bioavailability, elasticity, greater strength or reactivity – properties that the very same substances may not exhibit at larger scales. For example, carbon in the form of graphite (like pencil ‘lead’) is soft and malleable; at the nanoscale carbon can be stronger than steel and is six times lighter; nanoscale copper is elastic at room temperature, able to stretch to 50 times its original length without breaking.

The point that some countries might choose to block the importation of nanomaterials due to issues around risk (as per the participants in a regional awareness-raising workshop in the Côte d’Ivoire) is well taken. From the article,

Here was a group of experts in Africa questioning the received wisdom of nanotechnology’s central role in solving the problems of the developing world, even going so far as to suggest that in some cases it may make sense to ‘say no to nano’.

I thought this next passage was particularly cogent,

Because nanoscale manipulations are now possible and, because the basic components of both living and non-living matter exist on the nanoscale (e.g., atoms, molecules and DNA), it is now possible to converge technologies to an unprecedented degree. Technological convergence, enabled by nanotechnology and its tools, can involve biology, biotechnology and synthetic biology, physics, material sciences, chemistry, cognitive sciences, informatics, geoengineering, electronics and robotics, among others. At the nanoscale there is no qualitative difference between living and non-living matter.

I first came across the statement about there being no appreciable gap between living and nonliving matter in a book about philosopher Alfred North Whitehead’s work, Process and Reality (which was written in the late 1920s). At the time, that statement affected my thinking profoundly and forced me to examine my assumptions about the boundaries between living and nonliving matter.

Getting back to the article, the section about market impact is interesting and problematic for me,

The most direct impact of new designer materials created using nanotechnology is multiple raw-material options for industrial manufacturers, which could mean major disruptions to traditional commodity markets. It is too early to predict with certainty which commodities or workers will be affected and how quickly. However, if a new nano-engineered material outperforms a conventional material and can be produced at a comparable cost, it is likely to replace the conventional commodity. History shows that there will be a push to replace commodities such as cotton and strategic minerals – both heavily sourced in Africa and critical export earners – with cheaper raw materials that can be sourced or manufactured by new processes closer to home.

Yes, if manufacturers can find a way to make their products cheaper, they will certainly do that regardless of whom may get hurt as Americans found out when production of various electronics products was outsourced to places where labour is cheaper. As for reliance on  commodities for export, Canadians know that story well.

What seems to have been ignored in Wetter’s article is the pressure to produce more closer to home for environmental reasons. It’s at this point that the article starts to lose credibility for me.

The section on Health and Environmental Aspects is carefully designed to evoke great concern while remaining nominally truthful,

While there is great uncertainty about the toxicity of nanoparticles, hundreds of published studies now exist that show manufactured nanoparticles, currently in widespread commercial use (including zinc, zinc oxide, silver and titanium dioxide) can be toxic.

Damning all uses of the nanoparticles (as named in the article) seems as helpful as announcing that peanuts,which are in widespread commercial use, can be toxic. Interestingly, the author does not mention the use of zinc oxide and/or titanium dioxide nanoparticles in sunscreens which have been given a cautious passing grade by the Environmental Working Group (EWG). (I last posted about nanosunscreens and the EWG, June 16, 2010.)

Yes, people should have concerns and more research on environmental and health impacts of nanomaterials and nanotechnology-enabled products is urgently needed but the article, unless very carefully read, could be deemed misleading with regard to health and environmental impacts.

The section I was specifically referring to when I described this article has having an old-fashioned approach to the politics comes at the end with, Who’s in Control?,

Many who envision nanotech bringing benefits to Africa ignore the realities of technology transfer and intellectual property. Intellectual property is being driven by the North and promotes the interests of dominant economic groups, both North and South. A 2006 study reported that Africa accounts for just 0.4 per cent of all patents granted throughout the world, while the United States and Europe together account for 81.8 per cent.

More than 12,000 patents in the field of nanotechnology have been awarded, granted over three decades (1976–2006) by the three offices responsible for most of the world’s nanotech patenting – the US Patent & Trademark Office (USPTO), the European Patent Office and the Japan Patent Office.[6] As of March 2010, close to 6,000 nanotech patents had been granted by the USPTO and a further 5,184 applications were waiting in the queue. Multinational corporations, universities and nanotech start-ups (primarily in the OECD countries) have secured ‘foundational patents’ on nanotech tools, materials and processes – that is, seminal inventions upon which later innovations are built – and nanotech ‘patent thickets’ are already causing concern in the US and Europe.

While I agree with much of the analysis, I think the author does not seem to be aware that China is quickly catching up (or has China already caught up?) to the US in terms of claiming patents for advances in science and technology.

The reference to North and South seems dated to me especially in light an alliance (as cited in the article itself) between India, Brazil and South Africa,

South Africa is also a player in a cooperative nanotech R&D programme under the India-Brazil-South Africa Dialogue Forum (IBSA). Nanotech is one area of science collaboration, led by India, funded by a US$3 million trilateral research pool.

The geopolitics are changing rapidly and couching the discussion about developing/emerging economies and nanotechnology in terms coined more than 30 years ago seems counterproductive. For anyone who’s interested, do read the article because there’s lots of good material but caution needs to be exercised.

Nano Bite for August 2010

The August 2010 newsletter (Nano Bite) from NISE (Nanoscale Informal Science Education) Network features the nanosunscreen debate (from the newsletter),

It seems questions about the safety of nanoparticles in sunscreen come up every year around this time.  This year, Friends of the Earth posted an article that was critical of nano-particles in sunscreens (“make nano a no-no on your summer vacation!”).  Andrew Maynard, the Director of the University of Michigan Risk Science Center (and NISE Net advisor), posted a reply on his blog questioning some of the conclusions Friends of the Earth were drawing from the studies they cited.  The Environmental Working Group also has an investigation of nanotechnology and sunscreens that draws some different conclusions, read it here.

I also covered some of the debate here.

On a completely other note, there’s an online workshop being held on how to start a Nano Science Café,

Science cafes are live events in casual settings like pubs or coffeehouses, where scientists engage the public in conversations about current science topics. From September 13 – 24,  the NISE Network will offer a two-week online workshop that will introduce you to science cafes with a nano theme. Discussion will be led by three moderators who have run successful cafe series in their own communities: Amanda Thomas (Oregon Museum of Science and Industry), Brad Herring (Museum of Life and Science), and Jen Larese (WGBH).

Enrollment for the workshop opens August 6 and closes on September 3.  You can find out more about the science cafe workshop and how to enroll on nisenet.org at http://www.nisenet.org/community/events/online_workshop/how_start_nanoscience_cafe

Exciting, yes?

As usual there’s nano haiku but this month there are two!

Teeny-tiny stuff,
you act so different now.
Wish you were still big.

by Leigha Horton of the Science Museum of Minnesota.  Interested in how teeny-tiny stuff acts different?  See the NISE Net’s science theater play Nano Dreams and Nano Nightmares and hands-on activity Exploring Properties – Surface Area.

A hot summer day?
Try some fresh nano ice cream
but in large portions.

by Luke Donev of the Museum of Nature and Science in Dallas, TX.  Brad’s recipe is posted on the Nano Bite blog here.

Sunscreen and nanoparticles from ivy

I like a story about science research that starts with a question even if it does lead to another nanosunscreen posting this year (from a news item on Science Daily),

“What makes the ivy in [the] backyard cling to the fence so tightly?”

Associate professor of bioengineering at the University of Tennessee, Knoxville, Mingjun Zhang, asked himself that question one day while watching his son play in their back yard. Zhang’s answer may lead to the development of a new type of nanosunscreen, one that uses plant-based nanoparticles rather than metal-based ones.

Zhang speculated the greenery’s hidden power lay within a yellowish material secreted by the ivy for surface climbing. He placed this material onto a silicon wafer and examined it under an atomic force microscope and was surprised by what they found — lots of nanoparticles, tiny particles 1,000 times thinner than the diameter of a human hair. The properties of these tiny bits create the ability for the vine leaves to hold almost 2 million more times than its weight. It also has the ability to soak up and disperse light which is integral to sunscreens. [emphasis mine]

Michael Berger at Nanowerk has written an article (Harmless natural nanoparticles show potential to replace metal-based nanoparticles in sunscreen) discussing Dr. Zhang’s work in more depth,

Quite impressively, the team’s study indicates that ivy nanoparticles can improve the extinction of ultraviolet light at least four times better than its metal counterparts.

Zhang points out that sunscreens made with ivy nanoparticles may not need to be reapplied after swimming. “That’s because the plant’s nanoparticles are a bit more adhesive so sunscreens made with them may not wash off as easily as traditional sunscreens,” he says. “And while sunscreens made with metal-based nanoparticles give the skin a white tinge, sunscreens made with ivy nanoparticles are virtually invisible when applied to the skin.”

This certainly looks promising but they don’t seem to be anywhere near to producing sunscreens containing ivy nanoparticles.

Nanotechnology and sunscreens: recalibrating positions and the excruciating business of getting it as right as possible

I’ve been waiting for Andrew Maynard’s comments (on his 2020 Science blog) about the Friends of the Earth (FoE) guest bloggers’ (Georgia Miller and Ian Illuminato) response (ETA June 6, 2016: Just how risky can nanoparticles in sunscreens be? Friends of the Earth respond; a 2020 Science blog June 15, 2010 posting) to his posting (Just how risky could nanoparticles in sunscreens be?) where he challenged them to quantify the nanosunscreen risk to consumers.  His reflections on the FoE response and the subsequent discussion are well worth reading. From Andrew’s posting, The safety of nanotechnology-based sunscreens – some reflections,

Getting nanomaterials’ use in context. First, Georgia and Ian, very appropriately in my opinion, brought up the societal context within which new technologies and products are developed and used:

“why not support a discussion about the role of the precautionary principle in the management of uncertain new risks associated with emerging technologies? Why not explore the importance of public choice in the exposure to these risks? Why not contribute to a critical discussion about whose interests are served by the premature commercialisation of products about whose safety we know so little, when there is preliminary evidence of risk and very limited public benefit.”

Andrew again,

… we need to think carefully about how we use scientific knowledge and data – “evidence” – in making decisions.

As he goes on to point out, cherrypicking data isn’t a substantive means of supporting your position over the long run.

Unfortunately it’s a common practice on all sides ranging from policymakers, politicians, civil society groups, consumers, medical institutions, etc. and these days we don’t have the luxury, ignorance about downsides such as pollution and chemical poisoning on a global scale for example, that previous generations enjoyed.

Three of the scientists whose work was cited by FoE as proof that nanosunscreens are dangerous either posted directly or asked Andrew to post comments which clarified the situation with exquisite care,

Despite FoE’s implications that nanoparticles in sunscreens might cause cancer because they are photoactive, Peter Dobson points out that there are nanomaterials used in sunscreens that are designed not to be photoactive. Brian Gulson, who’s work on zinc skin penetration was cited by FoE, points out that his studies only show conclusively that zinc atoms or ions can pass through the skin, not that nanoparticles can pass through. He also notes that the amount of zinc penetration from zinc-based sunscreens is very much lower than the level of zinc people have in their body in the first place. Tilman Butz, who led one of the largest projects on nanoparticle penetration through skin to date, points out that – based on current understanding – the nanoparticles used in sunscreens are too large to penetrate through the skin.

These three comments alone begin to cast the potential risks associated with nanomaterials in sunscreens in a very different light to that presented by FoE. Certainly there are still uncertainties about the possible consequences of using these materials – no-one is denying that. But the weight of evidence suggests that nanomaterials within sunscreens – if engineered and used appropriately – do not present a clear and present threat to human health.

Go to the comments section of the 2020 Science blog for the full text of Peter Dobson’s response, Brian Gulson’s response posted by Andrew on Gulson’s behalf, and Tilman Butz’s response posted by Andrew on Butz’s behalf. (I found these comments very helpful as I had made the mistake of assuming that there was proof that nanoparticles do penetrate the skin barrier [as per my posting of June 23, 2010].)

I want to point out that the stakes are quite high despite the fact that sunscreens are classified as a cosmetic. I’ve heard at least one commentator (Pat Roy Mooney of The ETC Group, Interview at 2009 Elevate Festival at 4:32) scoff because nanotechnology is being used in cosmetics as if it’s frivolous. Given the important role sunscreens play in our health these days, a safe sunscreen has to be high on the list of most people’s priorities but this leads to a question.

Should we stop developing more effective nanotechnology-enabled sunscreens (and by extension, other nanotechnology-enabled products) due to concern that we may cause more harm than good?

Andrew goes on to provide some interesting insight into the issue citing the Precautionary Principle and supplementing his comments with some of Richard Jones’ (author of Soft Machines book and blog and consultant to UK government on various nanotechnology topics) suggestions to refine the Precautionary Principle guidelines,

1. what are the benefits that the new technology provides – what are the risks and uncertainties associated with not realising these benefits?

2. what are the risks and uncertainties attached to any current ways we have of realising these benefits using existing technologies?

3. what are the risks and uncertainties of the new technology?

I strongly suggest that anyone interested in the issues around risk, the precautionary principle, emerging technologies, and the role of research read this posting (as well as its predecessors) and as much of the discussion as you can manage.

One additional thought which was posited in the comments section by Hilary Sutcliffe (you’ll need to scroll the comments as I haven’t figured out how to create a direct link to her comment) has to do with the role that companies have with regard to their research and making it available in the discussion about health, safety, and the environment (HSE),

… we need to be able to access ‘the best available information’ in order to make informed decisions in the face of uncertainty and enable the rounded assessment that Prof Richard Jones suggests. This is indeed essential, but ‘we’ are usually constrained by the lack of one very large chunk of ‘available information’ which is the HSE testing the companies themselves have done which leads them to judge the material or product they have developed is safe.

Further in the comment she goes on to discuss a project (What’s fair to share?) that her organization (MATTER) is planning where they want to discuss how companies can share their HSE data without giving away intellectual property and/or competitive advantages.

Finally, I want to paraphrase something I said elsewhere. While I am critical of the tactics used by the Friends of the Earth in this instance, there is no doubt in my mind that the organization and other civil society groups serve a very important role in raising much needed discussion about nanotechnology risks.

Examining communication strategies for nanotechnology and for the BP oil spill

This won’t be a very long posting as it’s really a pointer to a couple commentaries by Dietram Scheufele (nanosunscreens) and Matthew Nisbet (BP oil spill).

First up Scheufele ( last mentioned here in a posting about Google influencing online searches for information nanotechnology; note: you can find out more about that in an interview with Elizabeth Baum) highlights in his June 17, 2010 posting, a public education/advertising campaign that the US Friends of the Earth (FOE) organization recently kicked off,

The timing is impeccable, of course, keeping alive a news wave started last week by a push from NY Senator Sen. Chuck Schumer to have the Food and Drug Administration looking into a possible link between retinyl palmitate in sun screens and skin cancer in humans.

It’s an interesting observation which suggests a great deal of thought goes into developing campaigns by nongovernmental organizations (aka civil society groups) and by extension other interests such as companies, politicians, governments, etc. You can follow links and read more at Dietram Scheufele’s nanopublic blog.

Here’s another observation about strategy this time by Matthew Nisbett in a his June 14, 2010 posting where he comments on why he thinks the environmental groups are being relatively muted in their response to the BP oil spill in the Gulf of Mexico and how they have responded,

In my own comments quoted in the article [by Josh Gerstein on Politico], I note that environmental groups appear to have adopted a smart strategy, letting the heavy news attention and general emphasis on public accountability do the communication work for them. If environmental groups were to become more open in their criticism of the Administration or too visible in news coverage, they risk alienating the White House and may be criticized by the media and the public for being politically opportunistic. Below are additional thoughts on the article and recent trends:

* As I emphasized to Gerstein, the sound bite of the crisis so far has been James Carville’s “who’s your daddy” comment, a frame device delivered with deep emotion that instantly conveys the emphasis on public accountability that has come to dominate news narratives.

Links and the full posting  are at Nisbett’s blog, Framing Science.

In coming to conclusions and positions of my own, I find it’s helpful to understand the mechanics (yes, there’s luck but there’s also a lot of planning)  behind the messages I receive.

Not enough data to assess risk for nanoscreens?

I’m glad to see that the Friends of the Earth (FOE) civil society group (or nongovernmental agency) have responded to Andrew Maynard’s challenge. As I thought, the FOE has stated that it is impossible to assess the risk that nanoscreens (specifically the sunscreens’ titanium dioxide and/or zinc oxide nanoparticles) present as there is not enough data.

The statement (posted in a June 15, 2010 posting on the 2020 Science blog) was made in response to a challenge by Dr. Andrew Maynard (blog owner) first issued in his June 8, 2010 posting (Friends of the Earth come down hard on nanotechnology – are they right?) and further detailed in another June 8, 2010 posting (Just how risky could nanoparticles in sunscreens be?).

FOE goes on to detail some of the problems associated with providing an answer (you can view the full statement in the first link provided in the second paragraph),

Andrew – thanks for the invitation to perform some complex risk assessment using several poorly understood variables. However we do have to point out that the world’s best minds don’t yet have enough information even to design reliable nanomaterial risk assessment processes, let alone to come up with a single ‘worst case scenario’ figure for long term health impacts of using nano-sunscreens.

The huge knowledge gaps plaguing nanomaterials toxicity and exposure assessment (along with preliminary studies suggesting the potential for serious harm) are key reasons for calls by Friends of the Earth Australia and United States for a precautionary approach to management of nanotoxicity risks.

I don’t think the sarcasm with which the authors (Georgia Miller and Ian Illuminato) open their statement is absolutely necessary but their main point is well made as it opens the door to a discussion about one’s perspective on and philosophy towards risk.

The impact that engineered nanoparticles of any kind could have on life is poorly understood and research is urgently needed. The research that has been undertaken on titanium dioxide and zinc oxide nanoparticles does suggest some potentially serious problems could occur. I want to emphasize my phrasing here ‘could occur’ because to date we have no evidence that anyone using nanoscreens has had any health issues as a consequence of their use. Still, the laboratory research is concerning. So, how are we as a society and as individuals going to approach the risk?

The school of thought which supports the FOE’s application of the precautionary principle seems to be that any element of risk should curtail use until the engineered nanoparticles have been extensively tested and then declared safe. I’m not clear how testing under those conditions could ever proceed to human clinical trials. It would not be possible to test every single variable or, more importantly, every combination of variables which could result in a risk. The net result would be: no nanoscreens while people use possibly inferior to nanosunscreen products to protect themselves from the sun’s effects.

I’ve commented about the Environmental Working Group (EWG) and their assessment of nanosunscreens previously (here). Last year (2009), they, reluctantly, after an extensive meta analysis of the available research recommended nanosunscreens on the basis that there was no compelling data to suggest undue risks. The EWG has not adjusted its stance since then and, this year, are warning against sunscreens that use Vitamin A and oxybenzone as well as sunscreens that are applied in spray or powder forms.

In most circumstances I imagine that the FOE and the EWG would be natural allies as both NGOs are focused on health and safety issues. So it’s strange that the FOE did not mention the EWG report (as I noted here) in the FOE’s own 2009 report on sunscreens although they did cite research from Japan that supports the FOE’s position but was released after the EWG’s 2009 recommendations.

In the instance of nanosunscreens, there appears to be a sharp division of opinion between the two groups. I think this points to a major philosophical difference in their approaches to risk. Faced with identical (or almost so) data sets, the FOE wants to halt use until these nanoparticles are declared safe while the EWG suggests that these nanosunscreens might be safer than conventional products currently in the marketplace and recommends their use.

The approach as exemplified by the FOE is to insist on extensive testing and guarantees as to how and when nanotechnology-enabled products are safe before they ever get near the marketplace. This is the precautionary principle being applied. Given the complex environment we all navigate on a daily basis, I can certainly understand the stance. However, I am pragmatic by nature and since testing every single possible variable and combination of variables is impossible I am more inclined to consider the data that we currently have available as inconclusive. I have read some (not all) of the materials and I’ve noticed that the scientists’ conclusions are always expressed in very measured tones.

To illustrate my point about the “measured tones”, I’ve excerpted this from FOE’s response to Andrew’s challenge in the June 15, 2010 posting on 2020 Science,

FOE: Transparent micron-particle sized zinc oxide sunscreens are commercially available; a recent article suggests most titanium dioxide nano-sunscreens on the market could be doing more harm than good. No-one need use nanoparticles in order to produce a cosmetically and functionally acceptable sunscreen.

The article is in Nature Nanotechnology (behind a paywall) and it’s the published version of Dr. Amanda Barnard’s work using a computer simulation to establish potential toxicity. From the Nature Nanotechnology article,

… using this technique [computer simulation] it is possible to draw direct comparisons between the SPF, transparency and potential toxicity of nanoparticles used in sunscreens, based on fundamental nanoscale properties, and optimize these parameters numerically. In general, optimization decisions of this type are usually based on product testing under expected usage conditions, but the results presented here do complement traditional product and consumer testing activities, and can also be applied to other thermal or chemical conditions, or applied to any other material where a trade-off is necessary when balancing efficacy, aesthetics and an undesirable side effect. [emphases mine]

I gather Dr. Barnard is viewing the use of a computer simulation in research as a complement and not as a replacement for or an equivalent to traditional testing. In an interview with Anna Salleh for the Australian Broadcasting Corporation Science Online website,

Dr Barnard found that the size and concentrations of nanoparticles that gave the best transparency and sun protection also gave the highest potential for production of free radicals.

“Where we have the highest sun-protection factor – and it’s pretty – it [the sunscreen] is also toxic, potentially,” she said.

“Ultimately we have to trade off. We can’t have our cake and eat it too.”

I’m not sure what sort of trade-off Dr. Barnard might be suggesting but it’s clear that she’s aware that the use of nanotechnology-enabled products such as nanosunscreens is not a simplistic ‘good (conventional sunscreens) vs. bad (nanosunscreens)’ situation.

Dexter Johnson makes note of the FOE’s response to Andrew’s challenge in his essay (Daring to Challenge NGOs on Nanotech Risk) on the Nanoclast blog with some pithy and thought-provoking comments.

I do have one major point of difference with Dexter, I find the FOE’s suggestion that the companies selling the nanosunscreen products should provide their testing information to be a good idea although I first saw it in a comment from Hilary Sutcliffe in the comments section of one of Andrew’s June 8, 2010 postings.

I do believe that NGOs are important players in the debate but the tenor of the FOE’s response to Andrew’s challenge makes it a little harder to hold on to that belief. From the June 15, 2010 posting on Andrew’s blog,

Andrew, we respectfully suggest that someone of your expertise and stature could play a more constructive role in these debates – debates which should not be limited to a question of technical risk assessment. [emphasis mine]

I think the challenge was very constructive indeed.

I did comment on this latest sunscreen discussion last week, Part 1 and Part 2 where I discuss the nature of risk, uncertainty and nanosunscreens.