Financing of nano risk studies

Financing of nano risk studies

By AVICENN Team – Last Modified June 2022

A small proportion of nano research budgets focus on risks

By the very admission of scientists involved in toxicology and ecotoxicology studies, correctly assessing the health and environmental risks of nanomaterials is prohibitively expensive. In January 2012, Mark Wiesner, Director of BELT (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 carry out all the necessary experiments^« 1With Prevalence of Nanomaterials Rising, Panel Urges Review of Risks, New York Times, Jan. 25, 2012. In 2009, researchers had estimated the cost of toxicity studies to be carried out for already existing nanomaterials at a minimum of 250 million dollars, or even 1,18 billion dollars depending on the degree of precaution adopted, requiring between 34 and 53 years of research. 'studies²The Impact of Toxicity Testing Costs on Nanomaterial Regulation, About. Science. Technology., 2009, 43 (9).

What is the share of funding for studies on the health and environmental risks of nanotechnologies in the public budgets devoted to research in nanosciences and nanotechnologies? 5% in 2010 in the United States, 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 it list of these projects carried out in May 2012 by the Institute of Technology Assessment of the Austrian Academy of Sciences or the more detailed document “Compendium of Projects in the European NanoSafety Cluster”, February 2012 and another carried out 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 (see also Euronano Forum 2015 - Joint Seminar on nanosafety: Prosafe, Nanoreg, Siinn, Oecd, Nanodefine and Nanovalid, June 2015). What today?

Roger Lenglet, in his “Nanotoxic” 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 advisers and highlight the challenges of their competitiveness" : the investigative journalist had thus collected the comments of a lobbysite "who roams the corridors of Brussels for a French firm" which summed up their argument as follows: "Anything you take away from us to give to prevention will set Europe back against international competitors".

And in France ? As part of the recovery plan, 10% of the 80 million euros allocated to nanotechnology projects would have been devoted to the study of the social and health dimensions of nanotechnology⁴Interministerial press release presenting the government's "commitments" on the follow-up to be made to the public debate, 13 February 2012, without specifying the projects concerned, the studies carried out and the results obtained.
In February 2012, the Fillon government undertook to develop public research in the fields of toxicology, ecotoxicology and metrology and to expand research on the benefits and risks, taking into account the whole life cycle and reducing the uncertaintdes… without, however, specifying the financial resources that will be devoted to it.

In April 2012, the Academy of Technologies had recommended that 5 to 10% of the budgets of all research projects on nanoparticles financed by public authorities and local authorities be devoted to the study of risks and the means of preventing them.⁵See recommendation n°8 of the report Risks related to manufactured nanoparticles, Academy of Technologies, April 2012.

According to the High Council for Public Health (HCSP), « since 2005, the 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. see Overall assessment of National Health-Environment Plans (2004-2019), HCSP, March 2022 (p. 231) It provides guidance on the content of searches: "The most discussed aspects are the main sources of contamination (produced by the industrial sector and present in food products, etc.), exposure and impact on human health as well as that of aquatic organisms (fish, crustaceans, phytoplankton , molluscs), 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 subject ».

These are the most recent figures available to us but which deserve to be substantiated and compared with the budgets devoted to R&D for the purposes of industrial applications.

The percentages quoted above are often criticized for their weakness: 3 or 5% is little in proportion⁷Two researchers from Denmark, Steffen Foss Hansen and David Gee, two researchers from Denmark, have again recently recommended devoting between 5 and 15% of research and development 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 resulting applications. see 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, Sep 2014. But in absolute value, the figure of 3% still represented the modest sum of 90 million dollars in the United States alone for the year 2010 and 102 million public 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 it list of these projects carried out in May 2012 by the Institute of Technology Assessment of the Austrian Academy of Sciences or the more detailed document “Compendium of Projects in the European NanoSafety Cluster”, February 2012 and another carried out 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 (see 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 around 200 million euros⁹Researchers create nanosafety research strategy for the EU, FIOH, June 20, 2013.
Fixing percentages in relation to public support for nanotechnology research and development is not necessarily the most relevant way to proceed – and this, especially since this support is questionable.

One avenue to explore: devote part of the research tax credit risk studies? For France alone, its amount is around 5 billion euros per year for contested effectiveness¹⁰cf. An overhaul of the research tax credit ?, Senate, July 2012; Research Tax Credit: mismanagement, {SCIENCES²}, July 18, 2013 and the report of the Court of Auditors on The evolution and the conditions of control of the tax credit in favor of research, September 2013. The Center for Environmental Information and Action for Health (CEIAS), association law 1901, even proposes that "the money from the Research Tax Credit, which is state money, is used in its entirety by companies to assess the short and long-term toxicity of new materials".

Should taxpayers pay?

A certain number of actors consider that the funding of research on the risks associated with manufactured nanomaterials should not be done mainly with public funds since the nanoproducts on the market already allow private companies to reap profits. So there is " privatization of profits " and " cost socialization as summarized, in economic terms, by Christian Gollier, President of the Toulouse School of Economics during the Colloquium “How to debate new technologies? » organized on November 8, 2011 by the Center for Strategic Analysis¹¹FRANCE: Feedback on the proposals of the Center for Strategic Analysis on the governance of nanotechnologies, Veillenanos.fr, November 15, 2011.

Controversies over the financial participation of private companies

Would co-financing between public and industrial bodies be the solution? Not everyone agrees, as evidenced by the recent controversy surrounding the announcement in May 2012 of the partnership between the German Ministry of the Environment, the Federal Institute for Occupational Safety and Health (BAuA) and the chemical industry giant BASF around a study on the effects of nanoparticles on health. BASF, which would contribute up to 3,5 million euros to the financing of the study, is also one of the main producers of nanomaterials; there are therefore doubts about the impartiality and objectivity of future results.

In Europe, number of research projects on nano risks benefiting from public euros within the framework of the European framework programs for several years also receive financing from private partners without the question of conflicts of interest having been raised in their regard. With the notable exception of 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 counted among its members L'Oréal and BASF... users or manufacturers of nanomaterials, they have been criticized both on their protocol and on the objectivity of their study.

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

According to French researchers involved in this process, "a structuring of research requiring a close network between the academic world and the industrial world" is necessary and "the participation of industrialists is essential to develop research more quickly facilitating the manufacture of nano-products taking into account the risks"¹³"Towards a shared concept of risk assessment for humans and the environment for an eco-design of nanoproducts", JY Bottero, J. Rose, M. Auffan, A. Masion, J. Labille, J. Boszckowski, presentation at the day “Views on nanotechnology: challenges, debates, perspectives”, Institute for Risk Management, October 18, 2011.

It is true that the studies on the toxicity of engineered nanomaterials carried out so far are criticized to relate only to nanomaterials synthesized in the laboratory.
It remains to be ensured that the involvement of manufacturers does not lead to too marked an orientation of projects and their results.s¹⁴The 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.. One can wonder, for example, about the financing from public funds of the “Economic and Workforce Development” section of the Labex Serenade mentioned above, aiming in particular to promote training for the marketing of nano-products.

More generally, the expectations of manufacturers in return for their investment in research on the health and environmental safety of nanos have been publicly summarized by two American researchers in nanomedicine interviewed by the American National Science Foundation (NSF): in addition to safer materials and new applications, among the expected rewards are easier access to the market and new intellectual property rights¹⁵Nanotechnology long-term impacts and research directions: 2000-2020, André Nel et David Grainger, WTEC, 2010. With what redistribution of economic income between private and public partners? And what sharing of knowledge?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 polarize research more than long term public values”. Handbook for CSOs on European research, Citizen Science Foundation (FSC), 2010

Towards self-financing by companies? With what safeguards?

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

• This is an idea proposed in October 2009 by the association Consumption Housing and Living Environment (CLCV)¹⁷“the setting up of a fund supplemented by manufacturers in the sector, without them being able to intervene in the choice, design and conduct of the studies thus financed”, See Nanotechnologies: for innovation governance, CLCV, Actor's notebook produced for the national public debate on nanotechnology 2009-2010.. In April 2012, twelve European NGOs – including the Environment Health Network for France – called for the establishment of such a self-financing mechanism for the management of risks associated with manufactured nanomaterials, in accordance with the polluter-pays principle, to relieve taxpayers and make manufacturers responsible¹⁸View letter that they sent to the ministers of the environment or prime ministers of European states: "The concept in question is a self-financing mechanism, at no cost to the government, which makes the polluter-pays principle operational by internalizing the external costs management of SVHCs (NDRL: substances of very high concern, including nanomaterials and endocrine disruptors), encourages manufacturers to design and adopt alternative solutions while providing the resources necessary to support them, and relieves public finances 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. SVHC manufacturers would be subject to a minimum fee, which would increase over time, to provide incentives and resources for research, development and implementation of safe or less hazardous alternative substances or technologies. The proceeds of the tax would be paid into an “SVHC solutions” fund, administered by a government agency..
• Although contrary to the rule of non-assignment desired by our principle of budgetary universality, such a mechanism has been put in place for phytosanitary products through the general tax on polluting activities (TGAP).
• During the presidential campaign, candidate François Hollande declared that “citizen alerts (associations, NGOs, etc.) must trigger in-depth studies carried out by contradictory expertise and not suspected of being exploited by pressure groups”¹⁹François Hollande: Regulation of technologies and organization of expertise, Vote for 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 in the National Assembly: he pleaded in favor of the implementation of long studies, carried out by researchers in a transparent and public manner, independent of companies... which does not mean, as one can hear it often, exclusively on public funding. In fact he is "difficult for the State to finance studies on all the commercial products that are put on the market"²⁰FRANCE: Have the companies that market them finance the risk assessment of nanoparticles?, Veillenanos.fr, October 11, 2012.
• In September 2013, the High Council for Public Health (HCSP) had recommended for the case of nanoparticles a long-term stable mechanism (a parafiscal tax for example on the volumes of production and import of nanoparticles, including in nanoproducts – or another dedicated funding modality) to finance research and methodological development on exposures and the identification of their dangerous potential, similar to what has been put in place for radiofrequency waves²¹Evaluation of the second national environmental health plan, HCSP, September 2013.
• In its April 2014 report, ANSES recommended "the establishment of financial incentive mechanisms similar to those implemented for other topics (electromagnetic fields for example)": since 2011 for radio frequencies, manufacturers abound, through a tax, a fund intended for research on the health effects of waves²²As part of the implementation of the commitments of the Grenelle Environnement and the round table "Radiofrequencies, health and the environment", the finance law for 2011 instituted long-term funding for research (€2 million per year) and measures of exposure to radio frequencies thanks to a tax on relay antennas. It allows the National Health Security Agency (ANSES) to finance research commensurate with the challenges posed by radiofrequencies and to respond to strong expectations from fellow citizens, and an essential condition for collective and shared acceptance of these technologies. see http://www.developpement-durable.gouv.fr/IMG/pdf/2011-01-27_DP_PNSE2.pdf.
• As the Court of Auditors pointed out in September 2016²³cf. The efficiency of tax expenditures relating to sustainable development, Court of Auditors, September 2016, “the “greening” of taxation requires the internalization of the external costs linked to the damage caused to the environment””. The concern not to increase the burden of compulsory levies must be weighed against the indirect costs that will be caused by future health and environmental problems caused by the large-scale dissemination of nanomaterials and their residues in the environment.
• A stable, long-term mechanism (a "nano-safety" savings account proportional to the volumes of production and import of nanoparticles by companies), similar to what has been put in place for radiofrequency waves or phytosanitary measures actually be put in place? The idea was relaunched by AVICENN during the 4th meeting of the working group "labeling and restriction of consumer products containing nanomaterials" in November 2016: it remains to be seen how long it will take to make its way to decisions. policies…
• In March 2017, during a nano and health dialogue committee, ANSES also referred to the National Toxicology Program (NTP) supported by several US federal agencies, aimed at mobilizing public funding for large-scale health studies in the public interest on subjects marked by a lack of scientific knowledge. Its main mission is to assess agents (chemical, biological, physical) of importance in public health, through the development and implementation of innovative tools in toxicology and molecular biology.
• In July 2018, the idea was toa mandatory tax to fund independent public research was again promoted by Marion Nestle of New York University.