An Open Letter to the International Nanotechnology Community At Large

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Civil Society-Labor Coalition Rejects Fundamentally Flawed DuPont-ED Proposed Framework

Urges All Parties To Reject The Public Relations Campaign

April 12, 2007

To All Interested Parties:

We, the undersigned, submit this open letter to the international 
nanotechnology community at large.  We are a coalition of public 
interest, non-profit and labor organizations that actively work on 
nanotechnology issues, including workplace safety, consumer health, 
environmental welfare, and broader societal impacts.

DuPont Chemical Company (DuPont) and Environmental Defense (ED) 
jointly have proposed a voluntary “risk assessment” framework for 
nanotechnology.  These groups intend to circulate their proposed 
framework both in the U.S. and abroad for consideration and/or 
adoption by various relevant oversight organizations, including the 
U.S. Environmental Protection Agency (EPA).

We reject outright the proposed voluntary framework as fundamentally 
flawed.  We strongly object to any process in which broad public 
participation in government oversight of nanotech policy is usurped 
by industry and its allies. We made the decision not to engage in 
this process out of well-grounded concerns that our participation - 
even our skeptical participation - would be used to legitimize the 
proposed framework as a starting point or ending point for discussing 
nanotechnology policy, oversight and risk analysis.  The history of 
other voluntary regulation proposals is bleak; voluntary regulations 
have often been used to delay or weaken rigorous regulation and 
should be seen as a tactic to delay needed regulation and forestall 
public involvement.

Nanotechnology’s rapid commercialization requires focused 
environmental, health and safety research, meaningful and open 
discussion of broader societal impacts, and urgent oversight action.  
Unfortunately, the DuPont-ED proposal is, at best, a public relations 
campaign that detracts from urgent worldwide oversight priorities for 
nanotechnology; at worst, the initiative could result in highly 
reckless policy and a precedent of abdicating policy decisions to 
industry by those entrusted with protecting our people, communities, 
and land.  We strongly urge all who have an interest in 
nanotechnology’s future to reject this proposed framework.  Respect 
for adequate worker safety, people’s health, and environmental 
protection demands nothing less.

Respectfully submitted,

American Federation of Labor and Congress of Industrial Organizations
Beyond Pesticides
Brazilian Research Network in Nanotechnology, Society and Environment
Center for Environmental Health
Center for Food Safety
Corporate Watch
Edmonds Institute
ETC Group
Friends of the Earth Australia
Friends of the Earth Europe
Friends of the Earth United States
Greenpeace
Institute for Agriculture and Trade Policy
International Center for Technology Assessment
International Union of Food, Agricultural, Hotel, Restaurant, 
Catering, Tobacco and Allied Workers’ Associations
Natural Resources Defense Council
Sciencecorps
Silicon Valley Toxics Coalition
Third World Network
United Steelworkers of America

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