Most of the Nanomaterials that come into direct contact with consumers and workers are produced in quantities exceeding 1 tonne per annum. The so called REACH regulations (relating to chemical hazards) have a reporting threshold of 1 tonne. EC considers therefore, that most of the potential hazards presented by Nanomaterials will fall within the scope of REACH. They do acknowledge however, that substances can be registered in the non-nano-form without reference to there being any nano-form in production/sale. If, in the opinion of the producer, the nano-form is hazardous, and has not been included in registration of a bulk form of the same substance, then the REACH agency (ECHA) should be informed.
They also consider that REACH should be modified to accommodate any new thinking on nanomaterial risk assessment: where current evaluations systems seem to be inadequate.
EC will establish a web site with references to all relevant information sources, including registries on a national or sector level, where they exist.
Evidence from:
http://europa.eu/rapid/press-release_MEMO-12-732_en.htm?locale=en
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2012:0572:FIN:en:PDF
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=SWD:2012:0288:FIN:EN:PDF
Comment
While it is reassuring that most accessible Nanomaterials ought to be mentioned in REACH registration, it is far from clear that the appropriate risk-based decisions will result. The implementation of the nanomaterial web site should allow insurers to make more complete risk assessments.
In our view, the APA scale developed for Radar subscribers remains the most useful tool with which insurers may develop expertise/experience in this field.
