United States Government Accountability Office

GAO Testimony 

Before the Subcommittee on Science, 

Technology, and Innovation, Committee 

on Commerce, Science, and 

Transportation, U.S. Senate 

NANOTECHNOLOGY

Accuracy of Data on 

Federally Funded 

Environmental, Health, and 

Safety Research Could Be 

Improved 

Statement of Robert A. Robinson, Managing Director 

Natural Resources and Environment 

For Release on Delivery

Expected at 2:30 p.m. EDT

Thursday, April 24, 2008

 

GAO-08-709T 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

April 24, 2008

NANOTECHNOLOGY

Accuracy of Data on Federally Funded 

Environmental, Health, and Safety Research Could Be 

Highlights of GAO-08-709T, a testimony Improved

before the Subcommittee on Science, 

Technology, and Innovation, Committee 

on Commerce, Science, and 

Transportation, U.S. Senate 

In March 2008, GAO issued a report

entitled Nanotechnology: Better 

Guidance Is Needed to Ensure 

Accurate Reporting of Federal 

Research Focused on 

Environmental, Health, and 

Safety Risks (GAO-08-402). In this

report, GAO reviewed the National

Nanotechnology Initiative (NNI), a 

multiagency effort administered by

the Office of Science and 

Technology Policy (OSTP). The 

NNI coordinates the 

nanotechnology-related activities 

of 25 federal agencies that fund

nanoscale research or have a stake

in the results. A key research area

funded by some agencies related to

studying the potential

environmental, health, and safety

(EHS) risks that may result from 

exposure to nanoscale materials. 

For this testimony statement, GAO 

was asked to summarize the 

findings of its March 2008 report, 

focusing on (1) the extent to which 

selected agencies conducted EHS 

research in fiscal year 2006; (2) the 

reasonableness of the agencies’ and 

the NNI’s processes to identify and 

prioritize EHS research; and (3) the 

effectiveness of the agencies’ and 

the NNI’s process to coordinate 

EHS research. 

What GAO Recommends

In its March 2008 report, GAO 

recommended better guidance to 

improve the accuracy of data 

reported by the NNI. Although

OSTP asserted that it provides 

extensive guidance, it agreed to

review how the agencies respond 

to the current guidance. GAO is

making no new recommendations 

in this statement. 

In fiscal year 2006, federal agencies devoted $37.7 million—or 3 percent of the 

$1.3 billion total nanotechnology research funding—to research that was 

primarily focused on the EHS risks of nanotechnology, according to the NNI. 

However, about 20 percent of this total cannot actually be attributed to this 

purpose. GAO found that 22 of the 119 projects identified as EHS in fiscal year

2006 were not primarily related to understanding the extent to which 

nanotechnology may pose an EHS risk. Instead, many of these projects were 

focused on how to use nanotechnology to remediate environmental damage or 

detect hazards not related to nanotechnology. GAO determined that this 

mischaracterization is rooted in the current reporting structure that does not 

allow these types of projects to be easily categorized and the lack of guidance

for agencies on how to apportion research funding across multiple topics,

when appropriate. In addition to the EHS funding reported by the NNI, federal 

agencies conduct other research that is not captured in the EHS totals. This 

research was not captured by the NNI because either the research was funded 

by an agency not considered to be a research agency or because the primary 

purpose of the research was not to study EHS risks. 

Federal agencies and the NNI, at the time of GAO’s review, were in the 

process of identifying and prioritizing EHS risk research needs and the overall 

process they were using appeared reasonable. For example, identification and

prioritization of EHS research needs was being done by the agencies and the 

NNI collaboratively. The NNI also was engaged in an iterative prioritization 

effort through its Nanotechnology Environmental and Health Implications 

(NEHI) working group. Through this process, NEHI identified five general 

research categories as a priority for federally funded research. GAO found 

that most of the research projects that were underway in fiscal year 2006 were 

generally consistent with agency and NEHI priorities. NEHI released its new 

EHS research strategy on February 13, 2008. 

Agency and NNI processes to coordinate activities related to potential EHS 

risks of nanotechnology have been generally effective. The NEHI working 

group has convened frequent meetings that have helped agencies identify 

opportunities to collaborate on EHS risk issues, such as joint sponsorship of 

research and workshops to advance knowledge and facilitate informationsharing among the agencies. NEHI also has incorporated several practices 

that GAO has previously identified as key to enhancing and sustaining 

interagency collaborative efforts, such as defining a common outcome and 

leveraging resources. Finally, all agency officials GAO spoke with expressed 

satisfaction with the coordination and collaboration on EHS risk research that

has occurred through NEHI. They cited several factors they believe contribute 

to the group’s effectiveness, including the stability of the working group 

membership and the expertise and dedication of its members. Furthermore, 

according to these officials, this stability, combined with common research 

needs and general excitement about the new science, has resulted in a 

collegial, productive working environment. 

To view the full product, including the scope 

and methodology, click on GAO-08-709T. 

For more information, contact Ms. Anu Mittal 

at (202) 512-3841 or mittala@gao.gov. 
Mr. Chairman and Members of the Subcommittee: 

I am pleased to be here today to participate in your hearing on the future 

direction of the National Nanotechnology Initiative (NNI). As you know, 

the NNI was established in 2001 as a federal, multiagency effort intended 

to accelerate the discovery, development, and deployment of nanoscale 

science, engineering, and technology to achieve economic benefits, 

enhance the quality of life, and promote national security. One of the key 

roles of the NNI is to coordinate the nanotechnology-related activities of 

25 federal agencies. These agencies include both those that fund nanoscale 

research as well as those that have a stake in the outcome of this research, 

such as agencies that regulate products containing nanomaterials. While 

the NNI is designed to facilitate intergovernmental cooperation and 

identify goals and priorities for nanotechnology research, it is not a 

research program. It has no funding or authority to dictate the 

nanotechnology research agenda for participating agencies or to ensure 

that adequate resources are available to achieve specific goals. Instead, 

participating agencies develop and fund their own nanotechnology 

research agendas, and in fiscal year 2006, 13 of the 25 agencies

participating in the NNI allocated a total of about $1.3 billion from their 

appropriated budgets to nanotechnology research and development 

activities. Of this total in fiscal year 2006, the NNI reported that $37.7 

million (or about 3 percent of the total) was used to fund research to study 

the potential environmental, health, and safety (EHS) risks that might 

result from exposure during the manufacture, use, and disposal or recycle 

of nanoscale materials. As you know, while the use of nanoscale materials 

holds much promise, the small size and unique properties of these 

materials raise questions about their potential EHS risks, and research is 

needed to fill current gaps in scientific information about their risks. 

At the request of the full committee and members of the Congressional 

Nanotechnology Caucus, we just completed a report that is being released

today on the NNI’s and federal agencies’ efforts to study the potential 

environmental, health, and safety risks of nanotechnology.1

 My testimony 

is based on the findings of this review and will cover the following three 

areas: (1) the extent to which selected research and regulatory agencies 

conducted research in fiscal year 2006 that primarily was focused on the 

 1

GAO, Nanotechnology: Better Guidance Is Needed to Ensure Accurate Reporting of 

Federal Research Focused on Environmental, Health, and Safety Risks, GAO-08-402

(Washington, D.C.: Mar. 31, 2008). 

Page 1 GAO-08-709T 
potential EHS risks of nanotechnology; (2) the reasonableness of the 

processes that agencies and the NNI use to identify and prioritize federal 

research on the potential EHS risks of nanotechnology; and (3) the 

effectiveness of the processes that agencies and the NNI use to coordinate

their research. For our review, we collected data from five federal 

agencies that provided 96 percent of fiscal year 2006 funding for EHS 

research—the Environmental Protection Agency (EPA), the National 

Institutes of Health (NIH), the National Institute for Occupational Safety

and Health (NIOSH), the National Institute of Standards and Technology 

(NIST), and the National Science Foundation (NSF). We also contacted 

three regulatory agencies—the U.S. Consumer Product Safety Commission 

(CPSC), the Food and Drug Administration (FDA), and the Occupational 

Safety and Health Administration (OSHA)—that do not have specific 

research budgets to determine whether they conducted any research on 

their own relative to potential EHS risks. We conducted this performance 

audit from June 2007 to February 2008 in accordance with generally 

accepted government auditing standards. Those standards require that we

plan and perform the audit to obtain sufficient, appropriate evidence to 

provide a reasonable basis for our finding and conclusions based on our 

audit objectives. We believe that the evidence obtained provides a 

reasonable basis for our findings and conclusions based on our audit 

objectives. 

In summary we found the following:

• About 20 percent of the over $37 million in fiscal year 2006 research 

expenditures that the NNI reported as being primarily focused on the EHS 

risks of nanotechnology cannot actually be attributed to this purpose. We 

found that 22 of the 119 projects identified as EHS-related by EPA, NIH, 

NIOSH, NIST, and NSF in fiscal year 2006 were not primarily related to 

understanding the extent to which nanotechnology poses an EHS risk. 

These 22 projects, funded by NSF and NIOSH, accounted for about $7 

million of the $37 million that the NNI reported as being primarily focused 

on EHS risks. The focus of many of these projects was to explore how 

nanotechnology could be used to remediate environmental damage or to 

detect a variety of hazards unrelated to nanotechnology. We determined 

that this mischaracterization was the result of the current reporting 

structure that does not allow these types of projects to be easily 

categorized in another more appropriate category, and also the lack of 

guidance for agencies on how to apportion research funding across 

multiple topics, when appropriate. To address this issue, we 

recommended that the Office of Science and Technology Policy (OSTP), in 

consultation with the NNI and the Office of Management and Budget 

Page 2 GAO-08-709T 
(OMB), provide better guidance to agencies regarding how to report 

research that is primarily focused on understanding or addressing the EHS 

risks of nanotechnology. In commenting on this report, OSTP asserted that 

it already provides extensive guidance, but it agreed to review the manner 

in which agencies respond to the current guidance. 

• In addition to the EHS funding totals reported by the NNI, we found that 

federal agencies conduct other EHS research that is not captured in the 

NNI totals. This research was not captured by the NNI because either the 

research was funded by an agency not generally considered to be a 

research agency or because the primary purpose of the research was not 

to study EHS risks. Because the agencies that conduct this research do not 

systematically track it as EHS-related research, we could not establish the 

exact amount of federal funding that is being devoted to this additional 

EHS research. 

• Federal agencies and the NNI were, at the time of our review, in the 

process of identifying and prioritizing EHS risk research needs; overall, we 

believe that the process they were using was reasonable. For example, 

identification and prioritization of EHS research needs was being done by 

the agencies and the NNI collaboratively. The NNI was also engaged in an 

iterative prioritization effort through its Nanotechnology Environmental 

and Health Implications (NEHI) working group. As a result of this effort, 

NEHI had identified five general research categories that should be the 

focus of federal research efforts and five specific research priorities under 

each general category. Our analysis of the 97 research projects that were 

underway in fiscal year 2006 that were primarily related to studying EHS 

risks found that the focus of these projects was generally consistent with 

agency priorities as well as NEHI’s five general research categories. 

However, we did find that, while agency funded research addressed each 

of the five general research categories, it focused on the priority needs 

within each category to varying degrees. As our report was in production,

NEHI released a new EHS research strategy on February 13, 2008, which is 

intended to provide a framework to help ensure that the highest priority 

EHS research needs are met. 

• Agency and NNI processes to coordinate activities related to potential 

EHS risks of nanotechnology have been generally effective. The NEHI 

working group has convened frequent meetings that have helped agencies 

identify opportunities to collaborate on EHS risk issues, such as joint 

sponsorship of research and workshops to advance knowledge and 

facilitate information-sharing among the agencies. These types of 

exchanges, according to most agency officials we spoke with, have helped 

advance knowledge and facilitated information-sharing among the 

Page 3 GAO-08-709T 
agencies. In addition, NEHI has incorporated several practices that we 

have previously identified as key to enhancing and sustaining interagency 

collaborative efforts, such as defining a common outcome and leveraging 

resources, but it had not, at the time of our review, completed its 

overarching strategy to help better align agencies’ EHS research efforts. 

Finally, all agency officials we spoke with expressed satisfaction with the 

coordination and collaboration on EHS risk research that has occurred 

through NEHI. They cited several factors they believe contribute to the 

group’s effectiveness, including the stability of the working group 

membership and the expertise and dedication of its members. 

Furthermore, according to these officials, this stability, combined with 

common research needs and general excitement about the new science, 

has resulted in a collegial, productive working environment. 

Nanotechnology encompasses a wide range of innovations based on the 

understanding and control of matter at the scale of nanometers—the 

equivalent of one-billionth of a meter. To illustrate, a sheet of paper is 

about 100,000 nanometers thick and a human hair is about 80,000 

nanometers wide. At the nanoscale level, materials may exhibit electrical, 

biological, and other properties that differ significantly from the properties 

the same materials exhibit at a larger scale. Exploiting these differences in

nanoscale materials has led to a range of commercial uses and holds the 

promise for innovations in virtually every industry from aerospace and 

energy to health care and agriculture. In 2006, an estimated $50 billion in

products worldwide incorporated nanotechnology and this figure has been 

projected to grow to $2.6 trillion by 2014. One research institute estimates 

that over 500 consumer products already available to consumers may 

contain nanoscale materials. 

The National Nanotechnology Initiative (NNI) was established in 2001 as a 

federal, multiagency effort intended to accelerate the discovery, 

development, and deployment of nanoscale science, engineering, and 

technology to achieve economic benefits, enhance the quality of life, and 

promote national security. Management of the NNI falls under the purview 

of the National Science and Technology Council (NSTC) that coordinates 

science and technology policy across the federal government. The NSTC is

managed by the Director of the Office of Science and Technology Policy 

(OSTP), who also serves as the Science Advisor to the President. The 

NSTC’s Committee on Technology established the Nanoscale Science, 

Engineering, and Technology (NSET) subcommittee to help coordinate, 

plan, and implement the NNI’s activities across participating agencies. In 

2003, the NSET subcommittee further established a Nanotechnology 

Background 

Page 4 GAO-08-709T 
Environmental and Health Implications (NEHI) working group.2

 The 

purpose of the NEHI working group, composed of representatives from 16 

research and regulatory agencies, is to, among other things, coordinate 

agency efforts related to EHS risks of nanotechnology. Similar to the NNI, 

the NEHI working group has no authority to mandate research priorities 

or to ensure that agencies adequately fund particular research. 

In December 2003, Congress enacted legislation to establish a National 

Nanotechnology Program to coordinate federal nanotechnology research 

and development.3

 Among other things, the act directs the NSTC to 

establish goals and priorities for the program and to set up program 

component areas that reflect those goals and priorities. To implement 

these requirements, the NSTC has established a process to categorize 

research projects and activities undertaken by the various federal agencies 

into seven areas. Six of the seven focus on the discovery, development, 

and deployment of nanotechnology, while the seventh relates to the 

societal dimensions of nanotechnology that include issues such as the 

EHS risks of nanotechnology. 

As part of the annual federal budget process, agencies also report their 

research funding for each area to OMB. The NNI’s annual Supplement to 

the President’s Budget, prepared by the NSTC, includes EHS research 

figures from the agencies and a general description of the research 

conducted by the agencies in each of the areas. For reporting purposes, 

the NSET subcommittee has defined EHS research as efforts whose 

primary purpose is to understand and address potential risks to health and 

to the environment posed by nanotechnology. Eight of the 13 agencies that 

funded nanotechnology research in fiscal year 2006 reported having 

devoted some of those resources to research that had a primary focus on 

potential EHS risks. 

Under the NNI, each agency funds research and development projects that

support its own mission as well as the NNI’s goals. While agencies share 

information on their nanotechnology-related research goals with the NSET 

subcommittee and NEHI working group, each agency retains control over 

 2

As of December 2007, a total of four working groups exist within the NSET subcommittee: 

(1) Global Issues in Nanotechnology; (2) Nanotechnology Environmental and Health 

Implications; (3) Nanomanufacturing, Industry Liaison, and Innovation; and (4) 

Nanotechnology Public Engagement and Communications. 

3

The 21st Century Nanotechnology Research and Development Act, Pub. L. 108-153 (2003). 

Page 5 GAO-08-709T 
its decisions on the specific projects to fund. While the NNI was designed 

to facilitate intergovernmental cooperation and identify goals and 

priorities for nanotechnology research, it is not a research program. It has 

no funding or authority to dictate the nanotechnology research agenda for

participating agencies. 

The NNI used its fiscal year 2000 strategic plan and its subsequent updates 

to delineate a strategy to support long-term nanoscale research and 

development, among other things. A key component of the 2000 plan was 

the identification of nine specific research and development areas—

known as “grand challenges”—that highlighted federal research on 

applications of nanotechnology with the potential to realize significant 

economic, governmental, and societal benefits. 

In 2004, the NNI updated its strategic plan and described its goals as well 

as the investment strategy by which those goals were to be achieved. 

Consistent with the 21st Century Nanotechnology Research and 

Development Act, the NNI reorganized its major subject categories of 

research and development investment into program component areas 

(PCA) that cut across the interests and needs of the participating agencies. 

These seven areas replaced the nine grand challenges that the agencies 

had used to categorize their nanotechnology research. Six of the areas 

focus on the discovery, development, and deployment of nanotechnology. 

The seventh, societal dimensions, consists of two topics—research on 

environmental, health, and safety; and education and research on ethical, 

legal, and other societal aspects of nanotechnology. 

PCAs are intended to provide a means by which the NSET subcommittee, 

OSTP, OMB, Congress, and others may be informed of the relative federal

investment in these key areas. PCAs also provide a structure by which the 

agencies that fund research can better direct and coordinate their 

activities. In response to increased concerns about the potential EHS risks 

of nanotechnology, the NSET subcommittee and the agencies agreed in 

fiscal year 2005 to separately report their research funding for each of the 

two components of the societal dimensions PCA. The December 2007 

update of the NNI’s strategic plan reaffirmed the program’s goals, 

identified steps to accomplish those goals, and formally divided the 

societal dimensions PCA into two PCAs—”environment, health, and 

safety” and “education and societal dimensions.” 

Beginning with the development of the fiscal year 2005 federal budget, 

agencies have worked with OMB to identify funding for nanoscale 

research that would be reflected in the NNI’s annual Supplement to the 

Page 6 GAO-08-709T 
President’s Budget. OMB analysts reviewed aggregated, rather than 

project-level, data on research funding for each PCA to help ensure 

consistent reporting across the agencies. Agencies also relied on 

definitions of the PCAs developed by the NSET subcommittee to 

determine the appropriate area in which to report research funding. 

Neither NSET nor OMB provided guidance on whether or how to 

apportion funding for a single research project to more than one PCA, if 

appropriate. However, representatives from both NSET and OMB stressed 

that the agencies were not to report each research dollar more than once.

About 18 percent of the total research dollars reported by the agencies as 

being primarily focused on the study of nanotechnology-related EHS risks 

in fiscal year 2006 cannot actually be attributed to this purpose. 

Specifically, we found that 22 of the 119 projects funded by five federal 

agencies were not primarily related to studying EHS risks. These 22 

projects accounted for about $7 million of the total that the NNI reported 

as supporting research primarily focused on EHS risks. Almost all of these 

projects—20 out of 22—were funded by NSF, with the two additional 

projects funded by NIOSH. We found that the primary purpose of many of

these 22 projects was to explore ways to use nanotechnology to remediate 

environmental damage or to identify environmental, chemical, or 

biological hazards not related to nanotechnology. For example, some NSFfunded research explored the use of nanotechnology to improve water or 

gaseous filtration systems. Table 1 shows our analysis of the 

nanotechnology research projects reported as being primarily focused on

EHS risks. 

Almost One-Fifth of 

Reported EHS 

Research Projects 

Were Not Primarily 

Focused on Studying 

the EHS Risks of 

Nanotechnology 

Page 7 GAO-08-709T 
Table 1: GAO Analysis of the Number and Dollar Value of Nanotechnology Research Projects Reported by Selected Agencies 

as Being Primarily Focused on Environmental, Health, and Safety Risks, Fiscal Year 2006 

(Dollars in millions) 

Projects reported by agencies as being

primarily focused on EHS 

Projects determined by GAO to 

be primarily focused on EHS 

Projects determined by GAO not to 

be primarily focused on EHS 

Agency Number Dollar ValueaNumber Dollar Value Number Dollar value

EPA 10 $3.6 10 $3.6 0 $0

NIH 18 $5.6 18 $5.6 0 $0

NIOSH 23 $4.3 21 $4.2 2 $0.1

NIST 2 $2.4 2 $2.4 0 $0

NSF 66 $21.1 46 $14.7 20 $6.4

Total 119 $37 97 $30.5 22 $6.5

Source: GAO analysis of agency obligations data. 

a

Figures differ slightly from those reported by the NNI in the Supplement to the President’s FY2008 

Budget due to rounding error or modifications made to the project-level data after they were reported

by agencies to the NNI. 

We found that the miscategorization of these 22 projects resulted largely 

from a reporting structure for nanotechnology research that does not 

easily allow agencies to recognize projects that use nanotechnology to 

improve the environment or enhance the detection of environmental 

contaminants, and from the limited guidance available to the agencies on 

how to consistently report EHS research. From fiscal years 2001 to 2004, 

the NSET subcommittee categorized federal research and development 

activities into nine categories, known as “grand challenges,” that included 

one focused on “nanoscale processes for environmental improvement.” 

Agencies initiated work on many of these 22 projects under the grand 

challenges categorization scheme. Starting in fiscal year 2005, NSET 

adopted a new categorization scheme, based on PCAs, for agencies to 

report their nanotechnology research. The new scheme eliminated the 

research category of environmental improvement applications and asked 

agencies to report research designed to address or understand the risks 

associated with nanotechnology as part of the societal dimensions PCA. 

The new scheme shifted the focus from applications-oriented research to 

research focused on the EHS implications of nanotechnology. However, 

the new scheme had no way for agencies to categorize environmentally 

focused research that was underway. As a result, NSF and NIOSH 

characterized these projects as EHS focused for lack of a more closely 

related category to place them in, according to program managers. 

Furthermore, neither NSET nor OMB provided agencies guidance on how 

to apportion the dollars for a single project to more than one program 

Page 8 GAO-08-709T 
component area, when appropriate. This is especially significant for broad, 

multiphase research projects, such as NSF’s support to develop networks 

of research facilities. Of the five agencies we reviewed, only NSF 

apportioned funds for a single project to more than one PCA. 

In addition to research reported to the NNI as being primarily focused on

the EHS risks of nanotechnology, some agencies conduct research that is

not reflected in the EHS totals provided by the NNI either because they are 

not considered federal research agencies or because the primary purpose 

of the research was not to study EHS risks. For example, some agencies 

conduct research that results in information highly relevant to EHS risks 

but that was not primarily directed at understanding or addressing those 

risks and therefore is not captured in the EHS total. This type of research 

provides information that is needed to understand and measure 

nanomaterials to ensure safe handling and protection against potential 

health or environmental hazards; however, such research is captured 

under other PCAs, such as instrumentation, metrology, and standards. 

Because the agencies that conduct this research do not systematically 

track it as EHS-related, we could not establish the exact amount of federal 

funding that is being devoted to this additional EHS research. 

All eight agencies in our review have processes in place to identify and 

prioritize the research they need related to the potential EHS risks of 

nanotechnology. Most agencies have developed task forces or designated

individuals to specifically consider nanotechnology issues and identify 

priorities, although the scope and exact purpose of these activities differ 

by agency. Once identified, agencies communicate their EHS research 

priorities to the public and to the research community in a variety of ways, 

including publication in agency documents that specifically address 

nanotechnology issues, agency strategic plans or budget documents, 

agency Web sites, and presentations at public conferences or workshops. 

We determined that each agency’s nanotechnology research priorities 

generally reflected its mission. For example, the priorities identified by

FDA and CPSC are largely focused on the detection and safety of 

nanoparticles in the commercial products they regulate. On the other 

hand, EHS research priorities identified by NSF reflect its broader mission

to advance science in general, and include a more diverse range of 

priorities, such as the safety and transport of nanomaterials in the 

environment, and the safety of nanomaterials in the workplace. 

Processes to Identify 

and Prioritize Needed 

EHS Research Appear 

Reasonable and Are 

Ongoing but a 

Comprehensive 

Research Strategy 

Has Not Yet Been 

Developed 

Page 9 GAO-08-709T 
In addition to the efforts of individual agencies, the NSET subcommittee 

has engaged in an iterative prioritization process through its NEHI 

working group. Beginning in 2006, NEHI identified but did not prioritize 

five broad research categories and 75 more specific subcategories of needs 

where additional information was considered necessary to further 

evaluate the potential EHS risks of nanotechnology. NEHI obtained public

input on its 2006 report and released another report in August 2007, in 

which it distilled the previous list of 75 unprioritized specific research 

needs into a set of five prioritized needs for each of the five general 

research categories. The NEHI working group has used these initial steps 

to identify the gaps between the needs and priorities it has identified and 

the research that agencies have underway. NEHI issued a report 

summarizing the results of this analysis in February 2008. 

Although a comprehensive research strategy for EHS research had not 

been finalized at the time of our review, the prioritization processes taking 

place within individual agencies and the NNI appeared to be reasonable.

Numerous agency officials said their agency’s EHS research priorities 

were generally reflected both in the NEHI working group’s 2006 research

needs and 2007 research prioritization reports. Our comparison of agency

nanotechnology priorities to the NNI’s priorities corroborated these 

statements. Specifically, we found that all but one of the research 

priorities identified by individual agencies could be linked to one or more 

of the five general research categories. According to agency officials, the

alignment of agency priorities with the general research categories is 

particularly beneficial to the regulatory agencies, such as CPSC and OSHA, 

which do not conduct their own research, but rely instead on research 

agencies for data to inform their regulatory decisions. 

In addition, we found that the primary purposes of agency projects 

underway in fiscal year 2006 were generally consistent with both agency 

priorities and the NEHI working group’s research categories. Of these 97 

projects, 43 were focused on Nanomaterials and Human Health, including 

all 18 of the projects funded by NIH. EPA and NSF funded all 25 projects 

related to Nanomaterials and the Environment. These two general 

research categories accounted for 70 percent of all projects focused on 

EHS risks. 

Furthermore, we determined that, while agency-funded research 

addressed each of the five general research categories, it focused on the 

priority needs within each category to varying degrees. Specifically, we 

found that the two highest-priority needs in each category were addressed 

only slightly more frequently than the two lowest-priority needs. 

Page 10 GAO-08-709T 
Moreover, although the NEHI working group considered the five specific 

research priorities related to human health equally important, 19 of the 43 

projects focused on a single priority—”research to determine the 

mechanisms of interaction between nanomaterials and the body at the 

molecular, cellular, and tissular levels.” Table 2 shows a summary of 

projects by agency and specific NEHI research priority. 

Table 2: Research Primarily Focused on the Environmental, Health, and Safety Risks of Nanotechnology by Agency and 

Specific Nanotechnology Environmental and Health Implications Working Group Research Priority 

 EPA NIH NIOSH NIST NSF Total

Instrumentation, Metrology, and Analytical Methods 0 0 1 2 8 11

1. Develop methods to detect nanomaterials in biological matrices, the environment, 

and the workplace 1 7 8

2. Understand how chemical and physical modifications affect the properties of 

nanomaterials 0

3. Develop methods for standardizing assessment of particle size, size distribution, 

shape, structure, and surface area 1 1 2

4. Develop certified reference materials for chemical and physical characterization of 

nanomaterials 0

5. Develop methods to characterize a nanomaterial’s spatio-chemical composition, 

purity, and heterogeneity 1 1

Nanomaterials and Human Health 4 18 10 0 11 43

1. Develop methods to quantify and characterize exposure to nanomaterials and 

characterize nanomaterials in biological matricesa

1 1 4 2 8

2. Understand the absorption and transport of nanomaterials throughout the human

bodya

1 1 2 4

3. Establish the relationship between the properties of nanomaterials and uptake via 

the respiratory or digestive tracts or through the eyes or skin, and assess body 

burdena

5 3 1 9

4. Determine the mechanisms of interaction between nanomaterials and the body at 

the molecular, cellular, and tissular levelsa

1 10 3 5 19

5. Identify or develop appropriate in vitro and in vivo assays/models to predict in vivo 

human responses to nanomaterials exposurea

1 1 1 3

Nanomaterials and the Environment 5 0 0 0 20 25

1. Understand the effects of engineered nanomaterials in individuals of a species and 

the applicability of testing schemes to measure effects 1 2 3

2. Understand environmental exposures through identification of principle sources of 

exposure and exposure routes 1 1

3. Evaluate abiotic and ecosystem-wide effects 6 6

4. Determine factors affecting the environmental transport of nanomaterials 2 9 11

5. Understand the transformation of nanomaterials under different environmental 

conditions 2 2 4

Page 11 GAO-08-709T 
 EPA NIH NIOSH NIST NSF Total

Health and Environmental Exposure Assessment 0 0 3 0 2 5

1. Characterize exposures among workers 2 1 3

2. Identify population groups and environments exposed to engineered nanoscale 

materials 0

3. Characterize exposure to the general population from industrial processes and 

industrial and consumer products containing nanomaterials 0

4. Characterize health of exposed populations and environments 0

5. Understand workplace processes and factors that determine exposure to 

nanomaterials 1 1 2

Risk Management Methods 1 0 7 0 5 13

1. Understand and develop best workplace practices, processes, and environmental 

exposure controls 4 2 6

2. Examine product or material life cycle to inform risk reduction decisions 1 1 2

3. Develop risk characterization information to determine and classify nanomaterials 

based on physical or chemical properties 1 2 3

4. Develop nanomaterial-use and safety-incident trend information to help focus risk 

management efforts 0

5. Develop specific risk communication approaches and materials 2 2

Total 10 18 21 2 46 97

Source: GAO analysis of agency data. 

a

Priorities given equal weight. 

Agency and NNI processes to coordinate research and other activities 

related to the potential EHS risks of nanotechnology have been generally 

effective, and have resulted in numerous interagency collaborations. All 

eight agencies in our review have collaborated on multiple occasions with 

other NEHI-member agencies on activities related to the EHS risks of 

nanotechnology. These EHS-related activities are consistent with the 

expressed goals of the larger NNI—to promote the integration of federal 

efforts through communication, coordination, and collaboration. The 

NEHI working group is at the center of this effort. 

Coordination 

Processes Have 

Fostered Interagency 

Collaboration and 

Information-Sharing 

We found that regular NEHI working group meetings, augmented by 

informal discussions, have provided a venue for agencies to exchange 

information on a variety of topics associated with EHS risks, including 

their respective research needs and opportunities for collaborations. 

Interagency collaboration has taken many forms, including joint 

sponsorship of EHS-related research and workshops, the detailing of staff 

to other NEHI working group agencies, and various other general 

collaborations or memoranda of understanding. 

Page 12 GAO-08-709T 
Furthermore, the NEHI working group has adopted a number of practices 

GAO has previously identified as essential to helping enhance and sustain 

collaboration among federal agencies.

4

 For example, in 2005 NEHI clearly 

defined its purpose and objectives and delineated roles and 

responsibilities for group members. Furthermore, collaboration through 

multiagency grant announcements and jointly sponsored workshops has 

served as a mechanism to leverage limited resources to achieve increased

knowledge about potential EHS risks. 

Finally, all agency officials we spoke with expressed satisfaction with their 

agency’s participation in the NEHI working group, specifically, the 

coordination and collaboration on EHS risk research and other activities 

that have occurred as a result of their participation. Many officials 

described NEHI as unique among interagency efforts in terms of its 

effectiveness. Given limited resources, the development of ongoing 

relationships between agencies with different missions, but compatible 

nanotechnology research goals, is particularly important. NIH officials 

commented that their agency’s collaboration with NIST to develop 

standard reference materials for nanoparticles may not have occurred as 

readily had it not been for regular NEHI meetings and workshops. In 

addition, NEHI has effectively brought together research and regulatory 

agencies, which has enhanced planning and coordination. Many officials 

noted that participation in NEHI has frequently given regulators the 

opportunity to become aware of and involved with research projects at a 

very early point in their development, which has resulted in research that

better suits the needs of regulatory agencies. 

Many officials also cited the dedication of individual NEHI working group 

representatives, who participate in the working group in addition to their 

regular agency duties, as critical to the group’s overall effectiveness. A 

number of the members have served on the body for several years, 

providing stability and continuity that contributes to a collegial and 

productive working atmosphere. In addition, because nanotechnology is 

relatively new with many unknowns, these officials said the agencies are 

excited about advancing knowledge about nanomaterials and contributing 

to the informational needs of both regulatory and research agencies. 

Furthermore, according to some officials, there is a shared sense among 

NEHI representatives of the need to apply lessons learned from the 

 4

GAO, Results-Oriented Government: Practices That Can Help Enhance and Sustain

Collaboration among Federal Agencies, GAO-06-15 (Washington, D.C.: Oct. 21, 2005). 

Page 13 GAO-08-709T 
development of past technologies, such as genetically modified organisms, 

to help ensure the safe development and application of nanotechnology. 

In closing, Mr. Chairman, while nanotechnology is likely to affect many 

aspects of our daily lives in the future as novel drug delivery systems, 

improved energy storage capability, and stronger, lightweight materials are 

developed and made available, it is essential to consider the potential risks 

of this technology in concert with its potential benefits. Federal funding 

for studying the potential EHS risks of nanotechnology is critical to 

enhancing our understanding of these new materials, and we must have 

consistent, accurate, and complete information on the amount of agency 

funding that is being dedicated to this effort. However, this information is 

not currently available because the totals reported by the NNI include 

research that is more focused on uses for nanotechnology, rather than the 

risks it may pose. Furthermore, agencies currently have limited guidance 

on how to report projects with more than one research focus across 

program component areas, when appropriate. As a result, the inventory of 

projects designed to address these risks is inaccurate and cannot ensure 

that the highest-priority research needs are met. 

Mr. Chairman, this concludes my prepared statement. I would be happy to

respond to any questions that you and other Members may have. 

Contact points for our Offices of Congressional Relations and Public 

Affairs may be found on the last page of this testimony. For further 

information about this testimony, please contact Ms. Anu Mittal, at (202) 

512-3841 or at mittala@gao.gov. Individuals who contributed to this 

statement include Nancy Crothers, Elizabeth Erdmann, David Lutter, 

Rebecca Shea, and Cheryl Williams. 

GAO Contact and 

Staff 

Acknowledgment 

Page 14 GAO-08-709T (360954) 
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