Regulating UncertaintyNanotechnology/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 PollutionTwenty-seventh ReportNovel 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:

CFCsMercuryLead etc..etc

How persistent are nanomaterials?Could they accumulate, e.g. in sediments?

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