Thanks for that update, Dave. It's good to know that the proposed legislation don't seem to extend to MEMS devices. Perhaps this legislative effort will end up like the radiated-food stuff did several years back, which was that lawmaking was ahead of a technology which had yet to settle or to come into a common mode of usage. So the legislative process was being attempted too early on the adoption curve. Sounds like the same thing is happening here.
@Alex: Looking at the EPA documents which Ann linked to, I didn't get the sense that MEMS devices would be likely to fall under the proposed regulations. It seems like EPA is primarily looking at nanomaterials such as fullerenes and nanotubes. I agree that any regulations made in the absence of good information have the potential do more harm than good. On the other hand, the basic physics (let alone the biological activity!) of these materials is only partially understood at this point, so it makes sense to proceed with a certain amount of caution. OSHA has a page with links to many resources on the health effects of nanomaterials.
This is definitely one area where legislation could forestall innovation. As well, regulating nanomaterials as chemicals makes no sense in the case of MEMS devices. Under these proposed regulations, MEMS sensors could conceivably fall under these laws. Not a good idea, or one that makes any sense.
Good points Chuck and Ann. You have to wonder whether the regulatory agencies have the expertise to develop reasonable regulations. RoHS received considerable criticism for not providing sufficient science behind its materials bans. The RoHS folks have made adjustments going forward to respond to scientific challenges.
I can't imagine how this is going work with nanomaterial.
Chuck, I think you're right. I've seen the same pattern elsewhere to varying degrees, depending on the nature of the technology and its degree of comprehensibility or incomprehensibility to the average non-technical person. In nanomaterials it's been especially problematic because they're especially difficult to comprehend, rather like the early SoCs were to many average folks.
I agree, Ann. The different entities each have their own communities to satisfy. It will be interesting to see how this turns out. There will also likely be political aspects to this since this is an election year.
Like so many other areas of technology today, this is a case of a technology developing too quickly for researchers and governing agencies to study it and come to any conclusions. We're seeing the same thing in the auto industry, where the pace of electronic development is exceeding the ability of governing agencies to understand the implications.
Dave, thanks for your comments and those links. I think you are totally right on. Much of the research I saw has to do with simply classifying and describing various different types of nanomaterials, and none with their effects. That pattern tells me that a field of study is in its infancy. I find that pretty scary, and am still amazed at how fast these technologies were allowed to grow without being studied first. The concern about their effects is by no means new: I read about it when I was covering this topic a decade ago for a different publication, and as usual, commercial interests trumped safety interests.
Thanks, Rob, for weighing in with your expertise on related legislation. I think one of the problems here is that the subject potentially either bridges, or falls between the cracks of, some different interests and expertise areas: health, environmental and technological. That's why we're seeing FDA, EPA and NGOs involved, and that will make the legislative and regulatory situation a lot more complex.
Nanomaterials are extremely widespread at present, Beth, and they're by no means monolithic in shape, size or constitution. They're in food and cosmetics, where much of the consumer-level concern is, but also in a lot of materials being produced in factories, like the industrial chemicals and medical devices mentioned in the article, so there's also concern about worker exposure. In fact, a coalition of consumer safety and environmental groups sued the FDA in December over possible risks from nanomaterials:
During the reporting of this story, I was reminded of the parallel issues surrounding the maintenance and repair of carbon fiber composites in aircraft, most especially the absence of repair databases and procedures and the difficulty of determining whether damage has even occurred. But in the case of aircraft composites, much of the information is either gettable or available, since composites use in aircraft is not entirely new. In the case of nanomaterials, practically everything is new and very little is known about their effects on human health.
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