Richard Denison, Ph.D., is a Senior Scientist.

Just when you thought it might never emerge, the National Nanotechnology Initiative’s (NNI) Strategy for Nanotechnology-Related Environmental, Health and Safety Research [2.2 MB PDF] finally hit the streets last week.

It’s got good, bad and ugly. The good news is that here, at last, is a report from NNI that actually reads more like a strategy and less like yet another laundry list of research needs. The bad news is that key elements of a full strategy are still nowhere to be found.

As a depiction of what the NNI’s research agencies have been up to, the report advances publicly available information considerably. For the first time, NNI has provided a detailed, if somewhat dated, list of projects – 246 in all – completed or in progress during FY2006. For each project there is even a handy hyperlink to a more detailed abstract of the project. That’s good to see, and took a lot of work to compile, no doubt.

But here’s the bad news: No dollar figures are provided for the individual projects, only aggregated funding estimates for broad categories of research – despite the maddening fact that NNI obviously must have had such raw data in order to provide the aggregated totals. And the list of projects includes ones that are clearly not directly relevant to understanding risk; for just one example, see project A2-4 Diffraction Studies of Glasses, Liquids, and Nanoclusters.

Even NNI admits its tally includes tangential projects, though the disclaimer is buried in the fine print and far removed from the dollar figures, which are displayed prominently in the Executive Summary and NNI’s press release. This obfuscation is hardly a way to quell the longstanding suspicion that NNI routinely over-counts what it is spending on risk-relevant research.

The report usefully describes the state of research efforts under each of its 25 research priorities, identifying which aspects are getting ample attention and which are not. A good start, but that’s essentially where it stops. A real strategy would take it the next step, by indicating how much more actually needs to be spent in each area to address the identified deficiencies or gaps, how the funding will be provided, and who will take responsibility for ensuring the work gets done.

Indeed, NNI seems so averse to putting someone in charge that it can’t even bring itself to identify lead agencies for each major research area, instead designating them as merely “coordinating agencies.” There’s no indication as to how decisions will get made or how funding will be allocated or shifted to research areas not currently receiving enough, other than the usual lip service paid to the need for a “coordinated interagency approach.”

Now for the ugly. A disturbing sentence appears in the report’s description of its strategy implementation framework (on page 46): "Gaps identified in the research that supports regulatory decision making should not be addressed at the cost of broad-based fundamental research – to do so would ultimately undercut the U.S. nanotechnology initiative as a whole."

In other words, NNI says it’s okay with them if gaps persist on the risk questions, if filling them would mean taking money away from research to advance nanotechnology. This is another clear indication of the lower priority NNI actually gives to the risk side of the equation, and of the growing conflict of interest between the promotional and oversight roles NNI has been charged with.

These shortcomings in NNI’s new strategy reinforce how essential it is to have an independent, expert body – the National Academy of Sciences – step in, not only to review the strategy report (that’s soon to get underway), but also to help craft an effective federal nano risk research strategy and oversee its implementation. Happily, Congress has requested just that, calling on the U.S. Environmental Protection Agency to contract, by March 21^st, with NAS for this much-needed more extended involvement.