June 7, 2023

Volume XIII, Number 158


June 06, 2023

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June 04, 2023

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White House OSTP Extends Comment Period for RFI on NNI EHS Research Strategy

The White House Office of Science and Technology Policy (OSTP) has extended the comment period for its April 5, 2023, request for information (RFI) seeking public input in updating the National Nanotechnology Initiative (NNI) Environmental, Health, and Safety (EHS) Research Strategy. 88 Fed. Reg. 33174. OSTP is soliciting public input from a wide variety of stakeholders, including individuals, industry, academia, research laboratories, nonprofits, and think tanks. OSTP states that it is interested in public input to inform an updated nanotechnology EHS research strategy, “specifically a strategy that focuses on the use of science-based risk analysis and risk management to protect public health and the environment while also fostering the technological advancements that benefit society.” OSTP seeks responses to the following questions:

  1. What are the research accomplishments in the following six core research areas identified in the 2011 NNI EHS Strategy? The six core research areas are: (1) Nanomaterial Measurement Infrastructure; (2) Human Exposure Assessment; (3) Human Health; (4) Environment; (5) Risk Assessment and Risk Management Methods; and (6) Informatics and Modeling.

  • What research gaps remain in addressing the six NNI EHS core research areas listed in question 1?

  • The ethical, legal, and societal implications (ELSI) of nanotechnology are considered across the core research areas of the 2011 strategy. What additional ways could ELSI be more fully integrated throughout a refreshed NNI EHS research strategy?

  • What broad themes should the revised strategy adopt to integrate and connect the six research areas?

  • How should the updated NNI EHS research strategy reflect the evolution of nanotechnology beyond engineered nanomaterials to complex systems, structures, and devices?

  • The 2011 strategy focused on engineered nanomaterials and did not include incidental nanoscale materials such as nanoplastics and certain nanoscale particulate emissions such as those from 3D printing. If the updated strategy is revised to include some non-engineered or incidental nanomaterials, describe how to scope the strategy in a way that complements rather than being redundant with existing health and environmental research (e.g., by excluding the large body of existing research on air pollution, which can include nanoscale particles).

Comments are due on or before 5:00 p.m. (EDT) on June 16, 2023.

©2023 Bergeson & Campbell, P.C.National Law Review, Volume XIII, Number 145

About this Author

Lynn Bergeson, Campbell PC, Toxic Substances Control Act Attorney, federal insecticide lawyer, industrial biotechnology legal counsel, Food Drug Administration law
Managing Partner

Lynn L. Bergeson has earned an international reputation for her deep and expansive understanding of the Toxic Substances Control Act (TSCA), the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), European Union Registration, Evaluation, Authorization and Restriction of Chemicals (REACH), and especially how these regulatory programs pertain to nanotechnology, industrial biotechnology, synthetic biology, and other emerging transformative technologies. Her knowledge of and involvement in the policy process allows her to develop client-focused strategies whether...

Carla Hutto, Bergeson Campbell PC environmental law regulatory analyst,Toxic Substances Control Act law attorney
Regulatory Analyst

Since 1996, Carla Hutton has monitored, researched, and written about regulatory and legislative issues that may potentially affect Bergeson & Campbell, P.C. (B&C®) clients. She is responsible for creating a number of monthly and quarterly regulatory updates for B&C's clients, as well as other documents, such as chemical-specific global assessments of regulatory developments and trends. She authors memoranda for B&C clients on regulatory and legislative developments, providing information that is focused, timely and applicable to...