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NIA submits comments to EC’s Public Consultation on Risk Assessment of Nanotechnologies
Published: Tuesday 30 June 2009
The Nanotechnology Industries Association has submitted comments to the European Commission’s Public Consultation in preparation of a Scientific Hearing on Risk Assessment of Nanotechnologies.
The full set of comments includes:
‘Risk assessment of nanomaterials:
We [the NIA] agree with SCENIHR on their conclusion that ‘[t]he hypothesis that smaller means more reactive and thus more toxic cannot be substantiated by the published data. In this respect nanomaterials are similar to normal substances in that some may be toxic and some may not.’
We furthermore support the ‘case by case approach for the risk assessment of nanomaterials’, as recommended by SCENIHR.
We agree with the finding that ‘[f]or (partially) soluble nanomaterials the toxicity may be governed at least in part by the soluble species released from the nanomaterial.’
It is important to distinguish the linearly particle size dependent increase of surface area from the unique properties that are observable below a primary particle size of approximately 100 nm only. More research is needed, in order to characterise the transport properties of primary particles in biological systems, determine if agglomerates or aggregates can revert to primary particles in biological systems, and to ultimately shed light on SCENIHR’s suggestion that ‘[f]or low solubility or a slow release, the particulate nature of the substance may be relevant with regard to tissue distribution and local release of toxic species which should then be considered in the risk assessment of such nanomaterials.’
Definition:
SCENIHR recommends the introduction of an additional parameter to uniquely describe nanoscale properties by ‘extending the current definition based on physical size by the addition of a limit of the specific surface area to be above 60 m²/g of material volume (the value of 60 m²/g corresponds to the specific surface area of 100 nm solid spheres of unit density) [...].’ We do not support the addition of a limit of the specific surface area into the unique definition of nanomaterials, since it represents a direct dependence on particle size and contradicts SCENIHR’s conclusion that ‘[t]he hypothesis that smaller means more reactive and thus more toxic cannot be substantiated by the published data.’
Follow this these links to download the submitted NIA Comments (this version has been shortened and heavily abbreviated due to restrictions), to download the full NIA Comments (un-abbreviated and available from this website only), to find out more about the European Commission’s Public Consultation, or to register for the Scientific Hearing (to be held on the 10th September 2009).
Related Links:
The European Commission (DG Health and Consumers) has opened the registration for the Scientific Hearing on Risk Assessment of Nanotechnologies (to be held in Brussels, on the 10 September 2009; Venue: Centre de Conference A. Borschette, Rue Froissart 36, 1040 Brussels). (24th June 2009)
The European Commission has launched a Public Consultation to prepare for a one-day Scientific Hearing on Nanotechnology, which will take place on 10 September 2009 in Brussels. (20th April 2009)
The EC’s Scientific Committee on Emerging and Newly Identified Health Risks (SCENIHR) has published its opinion on the most recent developments in the risk assessment of nanomaterials. (18th February 2009)