When hearing a legal case, in decision making on the board of a major bank or company, and in parliaments around the world, it's accepted practice to declare any potential conflicts of interest, and to absent yourself from taking part in decision making if one occurs. Not so with governments' involvement in nanotechnology. World-wide, governments are at once key nanotechnology proponents, major funders, risk assessors, regulators and public 'educators'. This conflict of interest is undermining efforts to initiate public 'dialogue' and is compromising the credibility of government-sponsored nanotechnology education programs.
All too often governments fail to declare their interest and significant financial investment in supporting nanotechnology industry expansion and in promoting public acceptance of it. More and more government-sponsored 'dialogue' or 'stakeholder engagement' activities are cropping up, some ostensibly to develop policy on nanotechnology issues.
However many 'dialogue' activities are hampered by government's reluctance to engage with critical viewpoints. There are consistent efforts to shut down discussion about whether or not an informed public would want to see nanotechnology development at all, or perhaps only within certain sectors on certain terms. These problems are visible in the upcoming Australian “Nanodialogue on Nanotechnology and Food Regulation".
The promotional brochure says that “The Nanodialogue will focus on discussions between key players involved in nanotechnology, food and food packaging, and their regulation, to develop models and or principles to feed into policy development.” The dialogue is organised jointly by the Australian Department of Innovation, Industry, Science and Research (through the Australian Office of Nanotechnology), Monash University Law, and the Australian Food and Grocery Council, the peak food industry body. This immediately gave Friends of the Earth cause for concern – if this is supposed to be a multi-stakeholder forum for “key players” to develop policy, why are community groups not represented on the organising group? If the organisers weren’t prepared to invite a community group to be part of the organising group that chose the day’s agenda, speaker and participants, what does that say about their interest in listening to community views on policy?
There is no explanation of how the outputs of the “Nanodialogue on Nanotechnology and Food Regulation” will be used in policy development, or to what extent the government is actually willing to act on community views in this area. In our view this is one of the most important aspects of any participation activity (eg see our “Best practice principles to underpin public participation and dialogue activities”).
The need to have equal representation of stakeholders in organising any meaningful ‘dialogue’ is underscored by the bias apparent in speakers, agenda and invitees when this does not take place. “Nanodialogue” speakers include the public awareness manager for the Australian Office of Nanotechnology, a scientist from CSIRO and a speaker from industry. No community representative or critic of nanotechnology’s use in food has been invited to speak. Public interest issues associated with nanotechnology in food besides those of scientific risk are not acknowledged in the agenda. Questions around ethics, corporate control, the public’s right to choose, implications for food sovereignty and other broader challenges are ignored. The key issue – that just as with genetically engineered foods, many people simply might not want nanotechnology used in food – is also ignored. The list of invited participants is also problematic. Key community ‘stakeholders’ with a demonstrated interested in nanotechnology and/ or food regulation were not invited. A letter to the workshop’s organisers detailing our concerns regarding the “Nanodialogue” can be accessed here. If these concerns are not addressed Friends of the Earth is unlikely to attend the workshop.
[Post script 24/3: Given that the organisers have agreed to our request to speak at the dialogue on broader public interest issues associated with nanofoods, and some of the excluded community groups are now permitted to attend, FoEA have agreed to attend the dialogue. There has still been no commitment from the organisers that in future government-backed 'stakeholder dialogues' and 'public engagement' exercises will be organised with the participation of critical nanotechnology stakeholders as well as nanotechnology proponents.]
Unfortunately, the flaws in the “Nanodialogue on Nanotechnology and Food Regulation” are very similar to problems associated with last year’s “Social inclusion and engagement workshop”, also organised by the Australian Office of Nanotechnology. That workshop also excluded key stakeholders, was poorly structured and also appeared tokenistic.
We were particularly worried that the workshop and associated activities was more about promoting public acceptance of decisions that have already been taken (ie for government to strongly invest in and promote the nanotechnology industry's expansion) rather than establishing a genuine mechanism to hear from the public what it would like – or not like – to see happen regarding nanotechnology.
Friends of the Earth Australia were wary that our participation in such a flawed workshop would help legitimise it and that our participation would be cited as evidence that we had had the opportunity to have our voice ‘heard’. For these reasons we declined our invitation to attend, as did another environment group, the National Toxics Network. Our letter to Minister Carr explaining these concerns can be accessed here.
We are extremely concerned that government efforts to promote uncritical acceptance of nanotechnology is extending into high schools. The nanotechnology ‘education’ programme launched last year was funded and developed by government and industry, in conjunction with academics and educators, but once again with no involvement from community groups or nanotechnology critics. The absence of community involvement in designing or developing the curriculum is reflected in its content: risk issues are barely mentioned and broader challenges associated with nanotechnology development are addressed in a cursory way. The experiment inviting students to assess the benefits of nano sunscreens is particularly striking.
Despite the promotion of nano sunscreen benefits, nowhere are the students given an accurate understanding of the emerging evidence of new health risks posed by nano sunscreens, including their action as photo-catalysts that promote accelerated oxidative damage, or the greater chances of skin penetration by nanoparticles. It is hard to see where the promotion of genuine scientific inquiry is in this module; its purpose is clearly to promote nanotechnology acceptance among young students.
Friends of the Earth is concerned that in Australia, as appears to be happening with many other governments world-wide, the Australian Office of Nanotechnology wants observers to believe that the government cares about the range of viewpoints on nanotechnology, that it regards as legitimate non-science based concerns regarding new technologies, and that it wants to involve the public in decision making about this technology that is predicted to transform our world. Unfortunately its actions and ‘dialogue’ activities to date suggest to us that none of this is the case and that its primary purpose in this area is to promote uncritical public acceptance of nanotechnology.