Position of Industriall European Trade Union on Nanotechnology and Nanomaterials
industriAll 34/2013
Position of industriAll European Trade Union on nanotechnology and nanomaterials
(Document adopted by the 3rd Meeting of the industriAll Europe Executive Committee
Luxembourg,26-27 November 2013)
Chemical innovations play a central role in shaping the future, making significant contributions towards people’s basic needs in relation to health and food products, household, energy efficiency and the environment, clothing and communication. Nanotechnology also plays a crucial role, especially in innovations linked to resource and energy-saving technologies and mobility, as well as for the development of new materials and their many applications. These applications include climate and resource protection or improved medical diagnosis for example.
As a key-enabling technology, nanotechnology is expected to clearly influence the labour market of the 21st century, with the creation, development and preservation of jobs in Europe. Nanotechnology indeed offers great potential for growth and jobs. Continuous improvement of workers’ competences and skills therefore plays a key role.
SMEs and start up companies play a key role in the innovation process in the field of nanotechnology. Often, they occupy a specific niche in the value chain between basic research, applied research, product and application development. Their function therefore varies between direct providers, suppliers or service providers and individuals producing components for large companies or offering tailored system solutions or services. The support and acceptance of these companies are essential for such businesses to remain located Europe.
The social acceptance of this new technology is an important prerequisite for their success. Taking advantage of the opportunities of nanotechnology while at the same time examining the risks and minimising them, may be the way forward. We need an open social dialogue about the future opportunities, awareness of the possible risks and the safe handling and use of nanomaterials. Everyone must deal responsibly with nanotechnology and enter into dialogue, including on the issue of skills.
However, given the lack of knowledge about the risks associated with nanomaterials, industriAll Europe still thinks that their use in the various industries should be supported by real and proven value and benefit to the end-users.
In addition, an extensive program of public and private research must be coordinated at European level to increase knowledge on nanomaterials, their properties and potential risks to the health of workers and consumers, and to the environment. In particular, significant progress must be made to develop appropriate methods in toxicology and ecotoxicology to improve progress in scientific analysis of these risks. This must be part of the program priorities of European and national research. It is therefore clear that the concept of the protection of human health and the environment needs to be integrated into research and development programmes.
To fully unfold the innovation potential of nanotechnology and benefit from the opportunities it presents, as for any new technology the risks must be managed carefully. The social and societal acceptance of this innovative technology is an essential prerequisite for its success. All stakeholders (producers, workers and end-users, etc.) should handle nanotechnology responsibly and engage in a dialogue based on their respective competences. The risk assessment and labelling of nanomaterials should be based on the REACH and the CLP regulations. Before reaching a sufficient knowledge of the properties of nanomaterials, however, the precautionary principle should be applied.
Safe handling and responsible use
In Europe, the chemical, rubber, glass, plastics, nanoelectronics industries, etc. are obliged to manage their organisation responsibly. All chemical products must be safe in their handling. Chemicals must not harm people or the environment and must be safe to use. This applies to any product produced or marketed by the chemical industry and other industry players, including nanomaterials.
The chemical industry, as is the case with all other sectors, is obliged by law to set up risk management. This is done by means of the organisation and technical implementation of occupational health and safety measures as well as measures to warrant product safety. IndustriAll Europe believes that safety research should develop preventive exposure scenarios to help design better health and safety measures at work. Exposure scenarios should describe the procedures relating to the production, processing and use of a material and assess the emissions expected, their duration and frequency, as well as the risk management measures required for the safe handling of the material.
OHS stakeholders such as the relevant authorities, statutory accident insurers, scientists and companies are obliged to ensure the safe handling of chemical substances and therefore of nanomaterials. Workers representatives should monitor the compliance with regulations relating to health and safety and accident prevention in the company. Protective measures must be reviewed regularly for effective protection from the possible dangers of nano-scale particles. If the toxic effect cannot be assessed with certainty, protective measures must be designed to be suitable to protect from potential dangers. Technical protective measures are implemented preferably. Personal protective measures are only to be applied if no technical measures are available.
In all industries, all partners in the value chain should ensure the safe handling of nanomaterials. A clear set of methods and procedures along the entire value chain and an established information flow are therefore required. Information to the workers in particular is necessary and must be improved on risks at the workplace.
The primary task of the chemical industry is to deliver the central basic data for a toxicological and eco-toxicological assessment of the nanomaterials. The assessments of the intended applications must also be implemented in cooperation with the users. This is mainly done via the safety datasheets, but also with information in technical leaflets, scientific publications, as well as during congresses, specialists conferences or forums, where findings from safety research are being disseminated. Feedback and the exchange of best practice should play an essential role in the establishment of effective preventive measures.
Product responsibility must apply from research to disposal
When it comes to nanomaterials and other products, companies must examine in the development phase, how their new products can be produced and used safely. The examinations must be completed by the time of market introduction and notes on the safe use must have been produced. Additionally, companies must specify how to dispose of the products professionally. Products harmful to health or the environment must be banned from entering the market.
The European Commission confirmed the pioneering importance of nanotechnology. In order to ensure a high level of protection of human health and the environment while maintaining current and future opportunities for technological development and further growth in this cutting-edge sector, the focus now has to be placed on prevention and protection. Concrete steps have to be developed to implement them in a practical way. It is therefore also necessary to assess the safety of nanomaterials case by case until the current lack of measurable impacts is remedied to, in order to ensure the development of the industry.
It is important for the nanotechnology industry and for the new investments that the playing field for the future is clear both at European and international levels. The opening of some articles of REACH which is not desirable from an industry point of view now may later become reasonable and necessary if adequate levels of health and environment protection are not reached by the formulation of the annexes and guidance or by other legislative ways. In this respect, we have to point out that the report of the Commission confirms that “REACH also calls upon the Commission to review the registration of low-tonnage substances[i].
IndustriAll Europe is committed to engaging in a dialogue with organisations involved in the safe and responsible development and use of nanotechnology. For example, nanotechnology is a topic that the European sectoral social dialogue could discuss and it would make sense for the European social partners for the chemical industry, and downstream users industries, to consider how to broach this topic jointly.
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[i] industriAll Europe position on the REACH Review – June 2013