Risk Analysis of Nanomaterials: Exposing Nanotechnology's Naked Emperor

Risk analysis (encompassing risk assessment, management, and communication) is touted internationally as the most appropriate approach for governing nanomaterials. In this article, we survey existing criticisms of risk assessment as a basis for regulatory decision making on emerging technologies, particularly highlighting its exclusion of key societal dimensions, its epistemological underdetermination, and its lack of democratic accountability. We then review the specific case of nanomaterials and identify six major barriers to the effective operation of both risk assessment and risk management. These include a lack of: nano-specific regulatory requirements, shared definitions, validated and accessible methods for safety testing, available scientific knowledge, reliable information on commercial use, and capacity for exposure mitigation. Finding the knowledge, standards, methods, tools, definitions, capacity, and political commitment all insufficient, we argue that risk analysis is a naked emperor for nanomaterial governance. We therefore suggest that additional concepts and approaches are essential for nanomaterials policy and regulation.