WASHINGTON, Feb. 2 (AScribe Newswire) -- The Environmental
Law Institute (ELI) recommends that the U.S. Environmental
Protection Agency (EPA) implement a research action
plan for developing an effective environmental, health
and safety governance structure for nanotechnologies.
In comments on EPA's Draft Nanotechnology White Paper
filed Jan. 31, ELI states that the paper fails to
address governance issues in any depth, and that
analysis of what options the Agency has for oversight
of emerging technologies should proceed in tandem
with development of scientific data defining health
and environmental risks. ELI's Comments outline the
themes that should guide EPA in developing a nanotechnology
governance structure and provide recommendations
for specific areas of research and policy analyses
necessary to ensure that an effective governance
structure is developed in a timely manner.
Specifically,
ELI calls for research on EPA's existing statutory
and regulatory authorities to determine: how these
authorities can be used as a basis for a nanotechnology
governance structure; whether current regulations
and guidances should be modified; and whether new
statutory authorities are needed. This analysis should
be used to develop an integrated, multi-statute regulatory
blueprint designed to incorporate into the governance
structure a full life cycle perspective that includes
basic research and development, manufacturing, and
product use and disposal.
Further, ELI's
research action plan emphasizes the need to examine
whether regulatory programs should be tailored to
small and medium-sized companies. In looking at alternative
governance approaches that do not rely on traditional
regulation, ELI's plan encourages EPA to consider
developing user-friendly publicly-accessible environmental,
health, and safety databases and consideration of
the role of tort liability and insurance products.
The plan also recommends that EPA consider the viability
of facility-based disclosure programs. ELI's Comments
also highlight the need for a long range action plan
for involving stakeholders in the development of
a governance structure and for communicating with
the public about nanotech environmental, health,
and safety issues.
ELI's Comments
call on the Agency to coordinate and collaborate
with other countries not only to generate needed
scientific data and methods, but also to consider
a harmonized framework for governmental oversight.
ELI will hold a symposium in Spring 2006 on the development
of governance structures in the U.S., Europe, and
Asia and the implications for corporate environmental
management if disparate governance structures emerge.
The Symposium will examine whether harmonization
is feasible and desirable.
ELI's Comments
are available at: http://www2.eli.org/research/nanotech.htm
CONTACT: Leslie
Carothers, ELI President, 202-939-3855
ABOUT ELI:
The Environmental Law Institute is an independent,
non-partisan education and policy research center
committed to improving environmental law and governance
and promoting innovative solutions.
Media Contact: Leslie Carothers,
202-939-3855
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