Regulating Uncertainty Nanotechnology/LCA Workshop, Chicago 5 / 6 November 2009 Professor Roland Clift Centre for Environmental Strategy University of Surrey President of the International Society for Industrial Ecology

SOURCE: Royal Commission on Environmental Pollution Twenty-seventh Report Novel Materials in the Environment: The Case of nanotechnology

What is routine? ( or would be if only we had the data…) Energy use in manufacturing vs Use ( including distributed production with transport of reagents) Emissions of species with known ( if not quantified) toxicity

A tangential view of “top down” and “bottom up” production : Brittle fracture cannot produce nano-sized products Processes like “nano –milling” are actually doing something else, using plastic rather than brittle processes. Therefore “top down” processes will never be energy-efficient. What are the thermodynamic limits on energy consumption in making nano particles?

Methodological Issues 1: Attributional vs Consequential Are we concerned with -describing the supply chain and the associated impacts and risks? or -Asking “what if we produce this product rather than any other”? Scale matters : total or marginal? If comparative, comparing what with what?

The Attributional vs Consequential decision conventionally affects Inventory Analysis ( e.g. biofuels) but for scarce abiotic resources it is also an impact issue

Assessing resource depletion We need to distinguish between A. Relatively abundant metals ; e.g. Fe, Al and “localised” metals; e.g. PGM B. Mined metals; e.g.Fe, Al and “co-products” or “hitch-hikers” Where are In, Te…………..?

Methodological Issues 2: Is LCA - an expert tool to guide technology management? - an approach to structuring information to inform participatory deliberation?

THE PRODUCT DEVELOPMENT PROCESS Phase 0: Phase 1: Phase 2: Phase 3: Phase 4: Phase 5 Idea Feasibility Proof of Scale-up Pre- Commercial Commercial concept

THE PRODUCT DEVELOPMENT PROCESS Phase 0: Phase 1: Phase 2: Phase 3: Phase 4: Phase 5 Idea Feasibility Proof of Scale-up Pre- Commercial Commercial concept 1. Conventional use of DFE: detailed design

THE PRODUCT DEVELOPMENT PROCESS Phase 0: Phase 1: Phase 2: Phase 3: Phase 4: Phase 5 Idea Feasibility Proof of Scale-up Pre- Commercial Commercial concept 2. Strategic use of LCA

If we are serious about deliberative decision making, then we must stop thinking of LCA as an expert tool - which probably means not using the conventional “mid-points”……

Human health and ecotoxicology remain the biggest uncertainty for both LCIA and regulation hoping that epidemiological information will never become available ( except indirectly from industries like carbon black and formed silica) Hazard is likely to be related to function….

A further problem : - are we accumulating materials in the environment and building up future problems? We have done it before: CFCs Mercury Lead etc..etc How persistent are nanomaterials? Could they accumulate, e.g. in sediments?

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Using words to bury a problem is ok just until it is uncovered