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Challenges of Regulation and Risk Assessment of Nanomaterials

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2. REGULATORY DEVELOPMENTS<br />

2.1. Summary record<br />

One objective <strong>of</strong> the ENPRA project is to provide results which contribute to nanomaterials' safety<br />

within the EU (as well as globally). In order to focus <strong>and</strong> maximize the impact <strong>of</strong> their work, ENPRA<br />

partners, as well as other scientists <strong>and</strong> stakeholders attending the annual workshops, need to have a<br />

clear view <strong>of</strong> the regulatory l<strong>and</strong>scape in which their work will be considered, <strong>and</strong> need to be<br />

acquainted <strong>of</strong> recent developments in the regulatory framework. Thus, the first session <strong>of</strong> this 2 nd<br />

ENPRA workshop was devoted to present <strong>and</strong> update on the state <strong>of</strong> the art <strong>and</strong> developments in the<br />

legislation <strong>and</strong> regulatory context in the EU <strong>and</strong> the world in relation to nanomaterials.<br />

A. Kobe from DG Environment set the scene by presenting an EU perspective <strong>of</strong> nanomaterials in the<br />

regulatory framework. He made a review <strong>of</strong> the past <strong>and</strong> recent EU developments starting from the<br />

Commission Communication 'Towards a European Strategy for Nanotechnology' (2004) with some<br />

emphasis on the Communication on 'Regulatory Aspects' (2008). He also explained the conclusions<br />

from the Competent Authorities Sub-group on <strong>Nanomaterials</strong> regarding REACH <strong>and</strong> the Classification<br />

<strong>and</strong> Labelling regulation. He summarised the Resolution <strong>of</strong> the European Parliament on Regulatory<br />

aspects <strong>of</strong> <strong>Nanomaterials</strong> <strong>and</strong> explained the status <strong>of</strong> expected key deliverables by the Commission<br />

during 2011, i.e. Finalisation <strong>of</strong> the REACH Implementation Projects on <strong>Nanomaterials</strong> (RIP-oN)<br />

concerning Substance Identity, Information Requirements <strong>and</strong> Chemical Safety <strong>Assessment</strong>; the 2nd<br />

regulatory review <strong>of</strong> nanomaterials; the review concerning '<strong>Nanomaterials</strong> in REACH registration<br />

dossiers <strong>and</strong> adequacy <strong>of</strong> available information'; a report on nanomaterial types <strong>and</strong> uses on the<br />

market <strong>and</strong> the definition <strong>of</strong> the term 'nanomaterial'. He also touched on the very important work<br />

going on in parallel in the research sphere <strong>and</strong> in international organisations such as OECD Working<br />

party on Manufactured <strong>Nanomaterials</strong> (WPMN).<br />

B. Quinn from ECHA presented work following a request by the Commission with regard to the<br />

compilation <strong>of</strong> an inventory based on nanomaterials in REACH registrations & CLP notifications. She<br />

explained that in the context <strong>of</strong> REACH, nanomaterials can be considered as substances on their own<br />

or as forms <strong>of</strong> substances. The results will be a part <strong>of</strong> the Commission response to the European<br />

Parliament on Regulatory Aspects <strong>of</strong> <strong>Nanomaterials</strong>. After explaining the approach for screening the<br />

large database <strong>of</strong> registrations <strong>and</strong> notifications currently held at ECHA, the presenter explained that<br />

this work will give an indication <strong>of</strong> how registrants <strong>and</strong> notifiers have identified nanomaterials in their<br />

dossiers <strong>and</strong> consequently applied REACH <strong>and</strong> CLP. Furthermore, it will show how registrations or<br />

notifications <strong>of</strong> nanomaterials can be found in the database. In addition this screening will also be<br />

used to identify 50-60 registration dossiers that include information on nanomaterials for a JRC-ENV<br />

project for assessing the adequacy <strong>of</strong> information included on nanomaterials in a selected number <strong>of</strong><br />

REACH registration dossiers. Detailed results <strong>of</strong> these activities should be available towards the end<br />

<strong>of</strong> 2011.<br />

There is concern regarding nanomaterials in food <strong>and</strong> feed that depends on their particular intrinsic<br />

characteristics, the lack <strong>of</strong> in vivo toxicity data <strong>and</strong> in vitro validated tests <strong>and</strong> the limited practical<br />

experience on risk assessment in this area. Furthermore, there are many uncertainties are associated<br />

with measurement <strong>of</strong> nanomaterials in various matrices, limited experience with testing<br />

nanomaterials, a lack <strong>of</strong> information on long term oral exposure, <strong>and</strong> there is the possibility that<br />

bioaccumulating <strong>and</strong> persistent nanomaterials end up in the food/feed chain. D. Carl<strong>and</strong>er presented<br />

the Guidance on the risk assessment <strong>of</strong> the application <strong>of</strong> nanoscience <strong>and</strong> nanotechnologies in the<br />

food <strong>and</strong> feed chain prepared by the EFSA scientific committee, following a 2009 request by the<br />

5

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