Financing nano risk studies

Financing nano risk studies

By the AVICENN team – Last modification June 2022

A small proportion of nano research budgets address risks

Even scientists involved in toxicology and ecotoxicology studies admit that it is prohibitively expensive to properly assess the health and environmental risks of nanomaterials. In January 2012, Mark Wiesner, director of CEINT (USA), which studies the effects of nanomaterials on the environment, summed up the situation as follows: “the number and variety of nanomaterials is staggering, there are not enough test tubes in the world to perform all the necessary experiments^“1With Prevalence of Nanomaterials Rising, Panel Urges Review of Risks, New York Times, Jan. 25. 2012. In 2009, researchers estimated the cost of toxicity studies for existing nanomaterials at a minimum of $250 million, or even $1.18 billion depending on the degree of precaution adopted, requiring between 34 and 53 years of studies²The Impact of Toxicity Testing Costs on Nanomaterial Regulation, About. Sci. Technol., 2009, 43 (9).

How much of the public budget for nanoscience and nanotechnology research is dedicated to studies on the health and environmental risks of nanotechnologies? 5% in 2010 in the US, not even 3% in Europe between 2007 and 2013³See “National Nanotechnology Initiative Environmental, Health, and Safety Research Strategy” National Science and Technology Council (NSTC), October 2011 for the United States; and for Europe: Overview of the EC EHS research plans and perspective Katalagarianakis, G., 2011; see the list of these projects conducted in May 2012 by the Institute of Technology Assessment of the Austrian Academy of Sciences or the more detailed “Compendium of Projects in the European NanoSafety Cluster”. February 2012 and another one in 2015 by CIEL, Öko-Institut and ECOS: Report on the Joint Seminar on NanoSafety: ProSafe, NanoREG, SIINN, OECD, NanoDefine at the Euronano forum 2015, Riga, Latvija (cf. also EuroNano Forum 2015 – Joint Seminar on NanoSafety: ProSafe, NANoREG, SIINN, OECD, NanoDefine and NanoValid, June 2015). What about today?

Roger Lenglet, in his “Nanotoxics” survey published in March 2014 by Actes Sud, explained the low percentages available at the time by “the way in which manufacturers present their needs to political advisors and make the case for their competitiveness”. The investigative journalist had thus collected the words of a lobbyist “who walks the corridors of Brussels for a French firm” and who summarized their argument as follows: “Anything you take away from us to give to prevention will set Europe back from international competitors”.

And in France? As part of the “growth” plan, 10% of the 80 million euros allocated to nanotechnology projects are supposed to have been allocated to studying the social and health dimensions of nanotechnologies⁴Interministerial communiqué presenting the government’s “commitments” on the follow-up to the public debate, February 13, 2012 with no mention of the projects concerned, the studies carried out and the results obtained.
In February 2012, the Fillon government committed to develop public research in the fields of toxicology, ecotoxicology and metrology and to amplify research on benefits and risks, taking into account the entire life cycle and reducing uncertainties… without specifying the financial means that would be devoted to it.

In April 2012, the French Academy of Technologies recommended that 5 to 10% of the budgets of all research projects on nanoparticles funded by public authorities and local governments be devoted to the study of risks and ways their prevention⁵See recommendation #8 of the report Risques liés aux nanoparticules manufacturées, Académie des Technologies, April 2012.

According to the High Council for Public Health (HCSP), “since 2005, the National Research Agency (ANR) has funded 59 projects on the theme of nanomaterials, for a total budget of 23.7 million euros“⁶Until 2019? 2021 ? The report does not specify this. Cf. Global Evaluation of the National Health and Environment Plans (2004-2019), HCSP, March 2022 (p. 231): “The main aspects addressed are the main sources of contamination (produced by the industrial sector and present in food products…), exposure and impact on human health as well as that of aquatic organisms (fish, crustaceans, phytoplankton, mollusks), and bacterial communities and ecosystems. The study of their behavior in complex matrices, their biotic and abiotic degradation, their bioaccumulation, and their trophic transfer are also addressed. The theme of micro-plastics and more recently nano-plastics and their toxicity (especially as endocrine disruptors) is an emerging topic..

These are the most recent figures available, but they need to be substantiated and compared with the budgets devoted to R&D for industrial applications.

The percentages mentioned above are often criticized as being too small: 3 or 5% is indeed a small proportion⁷Two researchers from Denmark, Steffen Foss Hansen and David Gee, have again recently advocated that between 5 and 15% of research and development should be devoted to studies on the health and environmental issues of emerging technologies in order to anticipate and reduce potential risks while maximizing the commercial life of the resulting applications. Cf. Adequate and Anticipatory research on the potential hazards of emerging technologies: a case of myopia and inertia, Journal of Epidemiology & Community Health History, 2014;68(9): 890-5, September 2014. However, in absolute terms, the 3% figure still represented the modest sum of 90 million dollars in the United States alone for the year 2010 and 102 million euros in Europe between 2007 and 2013⁸See “National Nanotechnology Initiative Environmental, Health, and Safety Research Strategy” National Science and Technology Council (NSTC), October 2011 for the United States; and for Europe: Overview of the EC EHS research plans and perspective Katalagarianakis, G., 2011; see the list of these projects conducted in May 2012 by the Institute of Technology Assessment of the Austrian Academy of Sciences or the more detailed “Compendium of Projects in the European NanoSafety Cluster” February 2012 and another one in 2015 by CIEL, Öko-Institut and ECOS: Report on the Joint Seminar on NanoSafety: ProSafe, NanoREG, SIINN, OECD, NanoDefine at the Euronano forum 2015, Riga, Latvija (cf. also EuroNano Forum 2015 – Joint Seminar on NanoSafety: ProSafe, NANoREG, SIINN, OECD, NanoDefine and NanoValid, June 2015). Between 2015 and 2020, the sum envisaged by Europe was close to 200 million euros⁹Researchers create nanosafety research strategy for the EU, FIOH, 20 June 2013.
Setting percentages in relation to public support for nanotechnology research and development is not necessarily the most appropriate way to proceed – especially since this support itself is questionable.

One avenue that could be explored is to devote part of the research tax credit to risk studies. In France alone, the amount is close to 5 billion euros per year for a questionable effecticiency¹⁰See Une refonte du crédit d’impôt recherche?, Sénat, juillet 2012 ; Crédit d’Impôt Recherche : la gabegie, {SCIENCES²}, 18 July 2013 and the report of the Cour des Comptes on L’évolution et les conditions de maîtrise du crédit d’impôt en faveur de la recherche, September 2013. The Centre d’Information sur l’Environnement et d’Action pour la Santé (CEIAS), an association under the law of 1901, even proposes that “the money from the Research Tax Credit, which is government money, should be used in its entirety by companies to evaluate the short- and long-term toxicity of new materials”.

Should taxpayers pay?

A certain number of stakeholders consider that research on the risks linked to manufactured nanomaterials should not be mainly financed with public funds since the commercialized nanoproducts already allow private companies to make profits. There is therefore “privatization of profits” and “socialization of costs” as Christian Gollier, President of the Toulouse School of Economics, summarized in economic terms during the Symposium “How to debate new technologies?” organized on November 8, 2011 by the Centre d’Analyse Stratégique¹¹FRANCE : Review of the proposals of the Centre d’Analyse Stratégique on the governance of nanotechnologies, Veillenanos.fr, 15 November 2011.

Controversies over the financial participation of private companies

Would co-financing between public and industrial organizations be the solution? Not everyone agrees, as evidenced by the recent controversy surrounding the May 2012 announcement of the partnership between the German Ministry of the Environment, the Federal Institute for Occupational Safety and Health (BAuA) and chemical industry giant BASF around a study on the health effects of nanoparticles. BASF, which is reportedly contributing 3.5 million euros to the funding of the study, is also one of the main producers of nanomaterials, so there are doubts about the impartiality and objectivity of any future results.

In Europe, a number of research projects on nano risks that have received public funding under the European framework programs for several years now also receive funding from private partners without questions of conflicts of interest having been raised. One notable exception is the recent controversy surrounding the study by British researchers who claimed to have shown that nanoparticles do not cross the skin barrier: financed within the framework of the European project NAPOLEON, now completed, but which included among its members L’Oréal and BASF… users or manufacturers of nanomaterials, they have been criticized both for their testing protocol and for the objectivity of their study.

In France, private companies also contribute to the financing of projects involving public research on the risks associated with nanotechnologies, including:

According to French researchers involved in this process, “a structuring of research requiring a close relationship between academia and industry” is necessary and “the participation of industry is essential to develop faster research facilitating the manufacture of nano-products taking the risks into account”¹³“Towards a shared concept of risk assessment for humans and the environment for an eco-design of nanoproducts”, J.Y Bottéro, J. Rose, M. Auffan, A. Masion, J. Labille, J. Boszckowski, presentation at the day “Regards sur les nanotechnologies: enjeux, débats, perspectives”, Institut de Maîtrise des Risques, 18 October 2011.

It is true that the studies on the toxicity of manufactured nanomaterials carried out so far are criticized for focusing only on nanomaterials synthesized in the laboratory.
We must ensure that the involvement of industrialists does not lead to projects and their results being overly biased¹⁴The correlation between the origin of funding and results favorable to the funder is now well documented in the scientific literature: see in particular Maxim L., Arnold G. How conflicts of interest can influence research and expertise, Hermès, 64: 48-59, 2012.. For example, one may wonder about the public funding of the “Economic and Workforce Development” component of the Labex Serenade mentioned above, which aims to promote training in the marketing of nano-products.

More generally, the expectations of industrialists in return for their investment in research on the health and environmental safety of nanotechnology were publicly summarized by two American nanomedicine researchers interviewed by the American National Science Foundation (NSF): in addition to safer materials and new applications, the expected rewards include easier access to the market and new intellectual property rights¹⁵Nanotechnology long-term impacts and research directions: 2000-2020, André Nel and David Grainger, WTEC, 2010. With what redistribution of economic revenues between private and public partners? And with what degree of knowledge sharing?¹⁶Research institutions have been encouraged to set up “public-private” partnerships (PPP) with industry and to contribute more directly to the economy. Private research gained a lot of advantages from these new regulations. These new forms of property have led to a new parcelling of knowledge, and to new monopolies. The production of science itself has gone through a significant evolution. Scientific and technological developments have been more and more oriented by market forces, and short term profitable value of potential innovations polarise research more than long term public values”.. Handbook for CSOs on European research, Fondation Sciences Citoyennes (FSC), 2010

Towards self-financing by companies? With what safeguards?

A solution from civil society would be to establish a tax paid by companies having an activity related to manufactured nanomaterials which would then go to a fund allocated to independent laboratories.

• This idea was proposed in October 2009 by the association Consommation Logement et Cadre de Vie (CLCV)¹⁷“the setting up of a fund financed by the industry, without the latter being able to intervene in the choice, design and conduct of the studies thus financed See Les nanotechnologies: pour une gouvernance de l’innovation CLCV, Actor’s notebook produced for the 2009-2010 national public debate on nanotechnology.. In April 2012, twelve European NGOs – including the Réseau Environnement Santé for France – called for the creation of such a self-financing mechanism for the management of risks associated with manufactured nanomaterials, in line with the polluter-pays principle, to relieve taxpayers and make manufacturers more accountable¹⁸See the letter which they sent to the environment ministers or prime ministers of European countries: “The concept is a self-financing mechanism, at no cost to the government, which makes the polluter pays principle operational by internalizing the external costs of managing SVHCs (editor’s note: substances of very high concern, including nanomaterials and endocrine disruptors), encourages industry to design and adopt alternative solutions while providing the resources necessary to support them, and relieves public finances of the administrative burdens generated by SVHCs. The result would be a significant financial gain for the government, through the transfer of management costs on the one hand, but also through the massive savings expected from the reduction of public health and environmental management costs. Manufacturers of SVHCs would be subject to a minimum fee, which would increase over time, to provide incentives and resources for the research, development and implementation of non- or less hazardous alternative substances or technologies. Proceeds from the fee would go to a “SVHC solutions” fund, administered by a government agency.”.
• Although contrary to the rule of non-allocation required by our principle of budgetary universality, such a mechanism has been put in place for plant protection products through the general tax on polluting activities (TGAP).
• During the presidential campaign, the candidate François Hollande declared that “the citizen alert organizations (associations, NGOs, …) must trigger in-depth studies done through contradictory expertise not suspected of instrumentalization by pressure groups “¹⁹François Hollande: Regulation of technologies and organization of expertise, Votons pour la Science, 2012.
• In October 2012, Gilles-Eric Séralini, professor of molecular biology and member of the Committee for Independent Research and Information on Genetic Engineering (CRIIGEN) defended this idea at the National Assembly: he pleaded in favor of setting up long studies, conducted by researchers in a transparent and public way, independent of companies… which does not depend, as we often hear, exclusively on public funding. Indeed, it is “difficult for the State to finance studies on all commercial products that are put on the market”²⁰FRANCE: Faire financer les évaluations des risques des nanoparticules par les entreprises qui les commercialisent?, Veillenanos.fr, 11 October 2012.
• In September 2013, the French High Council for Public Health (HCSP) recommended a stable, long-term mechanism for nanoparticles (a parafiscal tax, for example, on the production and import volumes of nanoparticles, including nanoproducts – or another dedicated funding method) to finance research and methodological development on exposure and the identification of their dangerous potential, following the example of what has been put in place for radio frequency waves²¹Evaluation of the second national environmental health plan, HCSP, September 2013.
• In its April 2014 report, ANSES recommended “the implementation of financial incentive mechanisms similar to those implemented for other themes (electromagnetic fields, for example)”: since 2011 for radiofrequencies, manufacturers have been contributing, through a tax, to a fund intended for research on the health effects of waves²²As part of the implementation of the commitments of the Grenelle Environment Forum and the round table “Radio frequencies, health and the environment”, the finance law for 2011 has instituted a permanent financing of research (2 M€ per year) and exposure measurements on radio frequencies through a tax on relay antennas. It allows the French National Health Safety Agency (Anses) to fund research that meets the challenges posed by radiofrequencies and responds to a strong expectation of citizens, and an essential condition for collective and shared acceptance of these technologies. Cf. http://www.developpement-durable.gouv.fr/IMG/pdf/2011-01-27_DP_PNSE2.pdf.
• As the Court of Auditors pointed out in September 2016²³Cf. L’efficience des dépenses fiscales relatives au développement durable, Cour des Comptes, September 2016, “the ‘greening’ of taxation requires the internalization of external costs related to environmental damage”. The concern not to increase the burden of compulsory levies must be weighed against the indirect costs that will be caused by the future health and environmental problems caused by the large-scale dissemination of nanomaterials and their residues in the environment.
• Will a stable, long-term mechanism (a “nano-safety” savings account proportional to the production and import volumes of nanoparticles by companies), similar to what has been set up for radio waves or plant protection products, actually be put in place? The idea was revived by AVICENN during the 4th meeting of the “Labeling and Restriction of Consumer Products Containing Nanomaterials” working group in November 2016: it remains to be seen how long this idea will take to make its way into political decisions…
• In March 2017, at a nano and health dialogue committee ANSES also referred to the National Toxicology Program (NTP) supported by several American federal agencies, aimed at mobilizing public funding for large-scale health studies of public interest on subjects marked by a lack of scientific knowledge. Its mission is to evaluate agents (chemical, biological, physical) of public health importance, through the development and implementation of innovative tools in toxicology and molecular biology.
• In July 2018, the idea a of a mandatory tax to fund independent public research was again promoted by Marion Nestle of New York University.