One of the most important functions of language is the ability to describe reality in increasing degrees of precision. For example, what many of us would simply call “red” can be vermilion, carmine, crimson or scarlet to a painter. Similar levels of accuracy also exist for what most people would still simply call “nanomaterials”. To continue with our colour metaphor, this helps us to identify red. But what if we need to be more precise than that?
The EU definition originally adopted in 2011 describes a nanomaterial as a material at the nanoscale i.e. smaller than 100 nanometres (to put this in context, our red blood cells typically measure 7-8 nanometres).
Just as an artist does not treat all shades of a colour the same way, assessing the behaviour of substances at the nanoscale requires a greater degree of precision than that allowed for by the term “nanomaterial” as defined by the EU. This is because talking about a specific “nanomaterial” only tells us about its elemental composition and size; however, at the nanoscale, that substance can adopt more than one different form (i.e. a nanoform), and, most importantly, those nanoforms can behave differently in terms of their physico-chemical properties. If we just call them all a nanomaterial, we’re erasing those differences.
Why is this important? The EU REACH Regulation lays out the requirements that companies have to meet to lawfully place their chemicals on the market, including the registration of any substance produced, imported or used in a quantity above one tonne/year, as well as a Safety Data Sheet (SDS) which must be provided to every customer with the first delivery of a chemical. This way, the customer can prepare accordingly and put in place adequate worker protection procedures, as well as environment protection measures where needed.
Remember what we just said about different nanoforms of a chemical having different properties and behaviours? SDS are where those differences come into play. Let’s take for example nanosilver, one of the most studied substances at the nanoscale, which is used in a variety of applications including medicine, textile, and cosmetics: to talk about nanosilver simply tells us that we’re looking at the chemical element silver, at a size smaller than 100 nanometres. Nanosilver, however, comes in different nanoforms that have different properties. This means that, while one form of nanosilver can be used as an effective anti-microbial agent, another one may be used in tagging and imaging applications, and both will be associated with different (if any) toxicities: it seems obvious that we would not treat them in the same way.
To go back to our artistic metaphor, imagine you’re a contemporary Rubens working on the portrait of Emperor Maximilian, and want to add some rich red velvet in the background; you know that different shades will create very different effects and that crimson will be much better than vermilion. Now imagine that your paint delivery arrives, and the can only says “Red”. It could be crimson, it could be vermilion, it could be yet another shade. You’re probably not going to risk ruining your work, so you’ll decide to stay away from the colour red altogether and paint that background grey.
If we apply this to nanoforms, the impact can be damaging: if the language we use does not allow us to capture their differences in terms of hazard profiles, we risk ending up with a blanket approach that attributes to all nanoforms of a same substance the risk profile of the most hazardous of them, misleading us into avoiding or even banning them altogether. This in turn can hamper the development and use of novel materials, missing out on the opportunities they afford.
The EU regulatory framework recognizes the need for this language evolution: the REACH amendment which came into force in 2020 introduced the use of the term “nanoform” in SDS, and established that information specifically addressing different nanoforms must be submitted to the European Chemicals Agency (ECHA) as part of the registration dossier (although sets of nanoforms with similar exposure, hazard, and risk profiles can be covered by one set of information if those similarities are strong enough).
As also explained in the NIA position paper we published earlier this year, this is a welcome development: the increased granularity in the information collected on nanoforms supports safe manufacturing; helps build up the knowledge base to identify the safest and most efficient forms of a substance to be used in products; and continuously improves the transparency required to gain end-user trust and foster confidence in nanotechnology. And the timing could not be better: with the momentum generated by the adoption of the Green Deal, and barely a decade away from the Sustainable Development Goals deadline, the potential of nanotechnology is one we should absolutely strive to fulfil.
As always with language evolution, change will be gradual. However, it is important that we start thinking in terms of nanoforms whenever referring to hazard profiles description: nanoforms and their sets are the future of industrial development at the nanoscale, and when discussing them we should make sure we are capturing them in all their nuances.
Nanotechnology Industries Association (NIA)
NIA nanoforms position paper
Chiara Venturini joined the Nanotechnology Industry Association (NIA) as Director General in 2021. She has been working in Brussels-based membership associations for over a decade, focusing on environmental issues and chemicals management for sectors as diverse as fuel cells and hydrogen, ceramics, digital and ICT. Her expertise also includes sustainability, supply chain management, and trade. Connect with me on LinkedIn.
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