Human Practices work aims to ensure that scientific projects are responsible and good for the world. Simultaneously, Human Practices work isn’t something apart from science – it is, or should be, considered part of the research process itself.
But if Human Practices are part of the scientific research process, what would it mean to ask whether our Human Practices work is itself responsible and good for the world? Our team asked this novel question, and doing so resulted in us completely reconceptualizing our approach to the relationship between science, society, and how we thought about what it means to be responsible scientists committed to improving the world in which we all live. Once we adopted that new understanding, findings that previously had little value in our Human Practices work took on a new kind of salience and prompted us to integrate civic engagement in our team’s efforts to be responsible scientists and do good for the world. Here, we explain how our Human Practices work led us on a journey from the science lab to the political lobby.
Our Shift from an Industry-Focused Project to a Community-Focused Project
Throughout the entire process, reflection on our Human Practices work led to various moments of having to rethink the design and objectives of our project. Inspired by the current surge in investment in semiconductor manufacturing, our initial idea focused on using synthetic biology to improve worker safety by developing safer and more effective strategies for wastewater treatment at manufacturing facilities. However, as a result of our discussions with industry leaders at existing local semiconductor manufacturing facilities (fabs), we realized that the need for (and interest in) synthetic biology solutions aiming at worker safety were relatively low. Moreover, our analysis of public concerns about the development of the proposed Micron fab in Upstate New York (which is slated to be the largest of its kind), coupled with our expert interview with a representative from the NYS Sierra Club, Dr. Donald J. Hughes, part of the Atlantic Chapter of Northern and Central New York Sierra Club, clearly demonstrated that there was a high level of community concern about the very real health and environmental problems that could result from use and disposal of the toxic chemicals that are necessary for semiconductor manufacturing processes.
As a result of our Human Practices work, we came to understand how important it was for us to focus on ways we might help protect public health and contribute to more environmentally sustainable wastewater treatment practices. Because we place high value on ensuring that our work is directed by a concern for doing as much good as we are capable of doing, while respecting the concerns of those who are affected by both the problems we are addressing and the solutions we are developing, our project’s focus and development shifted from an industry-focused approach to thinking about better manufacturing processes to a community-and-environmental-focused approach to thinking about mitigating wastewater pollution that increases in semiconductor manufacturing in New York State will inevitably create.
While our Human Practices work had substantial impacts on our thinking about the design and development of our device, we came to realize that our work could not be limited to mere efforts to inform lab design and development, nor would it be enough to simply inform the public about the challenges posed by semiconductor manufacturing and our potential solutions. In order to affirm our goal of responsible and positive scientific research, we had to fundamentally rethink our approach to both the laboratory and to Human Practices work itself.
Taking the Community-Focused Perspective Seriously: The Civic Science Approach
For a framework for reconceptualizing what it might mean to hold our Human Practices work to the same standards of ethics and responsibility that we wanted our lab work judged by, we turned to the Civic Science Approach. The Civic Science Approach was introduced in the mid-1990s by Dr. Neal Lane, Director of the National Science Foundation at the time. Lane’s basic idea was that the relationship between science and public policy should move beyond twin assumptions of the “deficit approach” that 1. public policy is principally hampered by the public’s ignorance of science, and 2. that scientists’ principal social responsibilities concern (the unidirectional) effort to improve scientific literacy. While public outreach and information are an important component of our human practices work, Lane’s Civic Science Approach holds that scientists have responsibilities as scientists to engage actively in policy and politics; not merely as producers of new knowledge and technology, but as active participants in public discourse and the political process. (Clark 2001) Christopherson et. al, sums up the “civic science imperative” when they state that “[W]e need more than scientific information. We need to engage in, and support, the messy, complex work of civic discourse and negotiation” (Christopherson 48)
Re-examining our Human Practices Findings within the Civic Science Approach Framework
In attempting to understand what kind of containment system might be most suitable for our device, Dr. David Resnik, chief bioethicist at the National Institutes of Health and National Institute for Environmental Health Science, advised us to search the U.S. Environmental Protection Agency (EPA) for relevant policy and legislation. However, given the federalist system in the U.S., we were told we had to investigate New York State Laws separately, since state regulations may vary from federal ones. This was useful advice at the time since it led us to better understand the policies and regulations that might affect our policy. We had also used the EPA to collect data on semiconductor fab toxic releases. But having shifted to the Civic Science Approach, some things we learned in the process that were not particularly helpful from the perspective of the scientific design of the project emerged as highly salient from the perspective of the Civic Science Approach.
For example, despite what we learned in our stakeholders analysis, such as the fact that concerns about exposure to, or environmental release of PFAS chemicals were regularly among those concerns being voiced by the communities in which semiconductor manufacturing development is being planned; the data we were collecting from the EPA on toxic chemical releases from U.S. semiconductor manufacturers showed no evidence of PFAS in these facilities’ inventories. [LINK TO TRI REPORT] This is the case even despite the fact that, according to the Semiconductor Industry Association itself, PFAS chemicals are “ubiquitous” throughout the manufacturing process (Semiconductor Industry Association 4). In investigating the lack of reported chemical releases, we learned that PFAS chemicals have only been added to the EPA’s list of reportable chemical types in the last five years, and only a limited number (189) of PFAS are currently reportable under U.S. Federal regulations (EPA 2024).
Because we knew from our discussion with Dr. Resnik that state-level regulations may be different, we decided that we needed to find out if New York State PFAS monitoring and reporting regulations might be more stringent. We discovered, however, that New York State has absolutely no monitoring or reporting requirements for PFAS discharge to surface water at all in any existing state regulation.
From the perspective of the Civic Science Approach, a number of our Human Practices findings that had originally had limited value for the design and development of our device, now appeared to us conjointly to take on a significance that we, as a team committed to making sure that our work is responsible and good for the world, could not ignore.
These findings include:
- There is a complete lack of data about PFAS use and discharge from semiconductor fabs in the existing U.S. federal regulatory system.
- There are currently no state regulations requiring PFAS monitoring or reporting requirements for PFAS discharge to water in New York State.
- The semiconductor manufacturing industry regards PFAS chemicals as necessary to and ubiquitous in the manufacturing process, (SIA (b) 2023) while opposing efforts to expand mandatory PFAS reporting requirements (SIA (a) 2023)
- The community that will be most closely affected by the development of new semiconductor fabs in New York State and scientific experts working with environmental protection groups have substantial concerns about the increased presence and use of PFAS as a result of the planned massive increase in semiconductor manufacturing.
- There are well-known and well-established negative environmental and health concerns associated with these so-called “forever chemicals”.
Civic Engagement in Our Human Practices Work
We reflected on what these findings mean from the perspective of Lane’s conception of researchers with ethical responsibilities to “engage in, and support, the messy, complex work of civic discourse and negotiation,” as participants in public discourse and the political process. Taking the Civic Science Approach meant for us that, if our project was to be ethical and responsible, we needed to actively engage in the political process in an effort to improve the entire system in which our device is meant to be developed and utilized. Therefore, we launched a project to promote civic engagement in the democratic process as a means to address the lack of PFAS monitoring and reporting in New York. We took this route because our Human Practices work highlighted this as an urgent and potentially serious problem facing New York State’s future experience with semiconductor manufacturing, and because our own attempt to determine a responsible and effective target demonstrated how such regulatory gaps prevent researchers from obtaining information that could be valuable for determining research agendas or designing new mitigation technologies.
We identified a bill pending in the New York State Legislature, “PFAS Discharge Disclosure Act” S227B. This bill had passed in the NYS Senate but was defeated in our second legislative house, the NYS Assembly, and thus sent back to committee in the Senate. After reviewing this bill and deciding that it would address many of the issues that were raised in our research process, we reached out to a professional NYS environmental lobbyist for advice on what sort of activities could be most effective in supporting that bill. After the lobbyist explained the process for passing environmental legislation in New York and the various strategies available to us, we all agreed that a direct mailing campaign to the widest range of state representatives was the most desirable and, in a campus community that includes individuals from across different areas of the state, most feasible plan of action.
Our civic engagement project involved a campus-wide event in which people were invited to learn about both PFAS and The PFA Discharge Disclosure Act. We chose to launch the civic engagement project in concert with a planned iGEM tie-dye fundraiser, held in collaboration with another campus academic club, because we wanted to ensure that our civic engagement project would reach a large campus audience.
At the event, we distributed flyers containing information about semiconductor manufacturing and our team’s approach , and we discussed the merits of the bill with participants and the process of how such bills become laws. We invited the participants to review the bill and helped each participant locate their respective voting district and state representatives, if they did not know them. We provided pre-drafted letters of support addressed to every state representative so that, if the participants agreed to help support the bill, they could either use that letter as a model or simply sign it on the spot. To make the process as easy as possible, we even provided stamped envelopes and agreed to mail the letters on behalf of the participants, if they wanted. We explained to them how this letter urges the representatives to revisit the PFAS Discharge Disclosure Act and that their endorsement would hopefully bring the community’s concern about PFAS to the legislators’ attention.
Conducting this civic engagement project was a genuine learning experience for us and our community, and, we think, represents a small but important step towards aligning our iGEM project with Neal’s conception of Civic Science.
References
1. Addition of Certain PFAS to the TRI by the National Defense Authorization Act. (2024). Retrieved from https://www.epa.gov/toxics-release-inventory-tri-program/addition-certain-pfas-tri-national-defense-authorization-act
2. Christopherson, E. G., Scheufele, D. A., & Smith, B. (2018). The Civic Science Imperative. Stanford Social Innovation Review.
3. CLARK, F., & ILLMAN, D. L. (2001). Dimensions of civic science. Science Communication, 23(1). doi:10.1177/1075547001023001002
4. Hendricks, R. (2024). Society Civic Science Initiative: Advancing Collective Support for Civic Science Activities. American Society of Plant Biologists.
5. N.Y. Senate Bill S227B “PFAS discharge disclosure act”, 2023-2024 Legislative Session (N.Y. 2024) https://www.nysenate.gov/legislation/bills/2023/S227/amendment/B#:~:text=2023%2DS227A%20%2D%20Summary,in%20any%20discharges%20from%20outfalls
6. SIA (a). Comments of the Semiconductor Industry Association (SIA) To the Environmental Protection Agency (EPA). (2023). Semiconductor Industry Association.
7. SIA (b). Semiconductor PFAS Consortium Articles Working Group. (2023). PFAS-Containing Articles Used in Semiconductor Manufacturing.