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European Trade Union says Precaution needed for Nanomaterials

Jennifer Sass

Posted June 26, 2008

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Today, the headline blares to the world: "The European Trade Union Confederation (ETUC) adopted a first resolution on nanotechnologies and nanomaterials at its recent Executive Committee meeting. The key demand: the precautionary principle must apply to nanotechnologies.". What does this mean? ETUC identifies some gaping regulatory loopholes that nanomaterials would fall through under REACH (Registration, Evaluation, and Authorization of Chemicals), the progressive, precautionary European chemical policy that entered into force in June 2007.

REACH loophole #1: There is no clear guidance for how to evaluate nanomaterials under REACH. ETUC calls for the "no data, no market" principle of REACH to apply to nanomaterials, and we agree!

REACH loophole #2: Materials manufactured or imported under 1 metric tonne per year don't need to be registered under REACH. Yeow! Many nanomaterials will fall through this hole because of their incredibly miniscule mass. Without registration requirements, no safety data would be required. ETUC calls for closure of this loophole, and we agree!

REACH loophole #3: Materials manufactured or imported under 10 metric tonnes per year aren't required to provide a chemical safety report. This means no safety data, no risk assessment, and where risk is identified there would be no requirements for risk management measures. ETUC says all nanomaterials registered under REACH should be accompanied by a chemical safety report, and, guess what? We agree!

In addition, ETUC calls for more health and safety research of nanomaterials, and more workplace protections. See the full ETUC proposal on their website. Go ETUC! 

Back in the good ole' U.S. of A. we are still trying to get our government to regulate any toxic chemical in a precautionary manner. When will we get a, "no data, no market" approach to chemicals? Soon, I hope!

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Richard DenisonJun 27 2008 07:16 PM

Jen: Thanks for drawing attention to this excellent critique by ETUC of how the EU's REACH needs to be enhanced to address the specific concerns of nanomaterials.

While REACH does not specifically address nanomaterials, however, it is far better even as is than the US regulatory system. A couple examples: While REACH's tonnage thresholds clearly need to be lowered for nanomaterials, they are much lower than those in the US used to track chemicals.

Actual data (albeit not necessarily enough data) will be required upfront on all nanomaterials that meet the registration threshold, whether the material is considered "new" or "existing."

In contrast, in the US, nanomaterials deemed by EPA to be "existing" will have no data required, while those deemed "new" will only have whatever data EPA decides to require, which will be done on a case-by-case basis, and typically with no public accounting of EPA's decision-making process and with the identity of the nanomaterial and its producer also eligible to be withheld from the public by claiming that information to be confidential.

On our nanoblog ( I'm in the middle of a series of posts exploring the severe limitations of EPA's authority to address nanomaterials under TSCA.

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