The European Environmental Bureau (EEB) has released a statement about the definition of nanomaterials that has been adopted (mentioned in my Oct. 18, 2011 posting) from the Oct. 19, 2011 news item on Nanowerk,
The European Environmental Bureau (EEB) is deeply disappointed by the European Commission’s decision released yesterday to use a narrow definition for the term “nanomaterial”, indicating that industry lobbying has won over the Commission’s own scientific advisors. EEB did however welcome the fact that a recommendation was adopted and hopes this will clear the way for the EU to actually start regulating on this.
The EEB echoed one of Dr. Andrew Maynard’s concerns (here’s Andrew’s concern from my Oct. 18, 2011 posting),
The threshold of 50% of a material’s number distribution comprising of particles with one or more external dimension between 1 nm – 100 nm. This is a laudable attempt to handle materials comprised of particles of different sizes. But it is unclear where the scientific basis for the 50% threshold lies, how this applies to aggregates and agglomerates, and how diameter is defined (there is no absolute measure of particle diameter – it depends on how it is defined and measured).
Here’s what the EEB had to say (from the Oct. 19, 2011 news item),
It is completely unclear from the Commission’s publication how the threshold was multiplied by 50 from the original 1% when scientists had in fact called for a 0.15% threshold.
One of Andrew’s commenters provides some insight (Note: It is quite technical) from the comments to Andrew’s Oct. 18, 2011 posting,
The 50% benchmark appears not to be arbitrary: SWNTs are p-FETs when exposed to oxygen and n-FETs otherwise. It has been proven possible to protect half of an SWNT from oxygen exposure, while exposing the other half to oxygen, so this control measure seems to one of flammability risk mitigation. (excerpted from LaVerne Poussaint, October 18, 2011 at 5:34 pm)
I’ve included Poussaint’s comment as it provides what I consider a fascinating insight into just how complex this conversation can get.
[mod]
To elaborate:
In addition to flammability factoring and nanovirus ranges, that 50% delimiter might also indicate LD50, LC50, LCT50 nano reference values
or standard nano tracking analysis (NTA) device calibrations
or controlling for heat and natural environmental biodegradation pollution[organic NP sedimentation occurs at 50% ]
where 50% is used as coefficient in humidity (RH) factor
or the EC’s 50% delineation might reflect oxidative stress paradigms [often tested at 50% variables]
Aggregation is particle-size dependent which most relevant to interaction, reactivity, catalytic assessments [as transpires in, for example, carbon oxidation and nano- aggregation into larger NPs]
For further clarification, see figure 1:
http://secure.awma.org/journal/pdfs/2010/7/10.3155-1047-3289.60.7.770.pdf
which illustrates:
“4-nm particle has 50% of its atoms on the surface, whereas a 30-nm particle has only 5% of its atoms on the surface.”
ISSN:1047-3289 J. Air & Waste Manage. Assoc. 60:770–781
DOI:10.3155/1047-3289.60.7.770
—
Quintessentially, size does matter. It is not the only thing, but it is the principal thing. Getting the size parametres right refines target screening, and further ensures surface interaction accuracy.
[Affirmed in my TINC blog post http://www.nanopaprika.eu/profiles/blogs/surely-size-matters%5D
Moreover, the “health effects of NP exposure are NOT directly related to particle MASS”
See IRST R599 Sec 4.1:
http://www.irsst.qc.ca/media/documents/pubirsst/r-599.pdf
and
Particle size distribution reveals the … “MOST useful information for evaluating NP exposure” … and “most difficult, expensive, and time-consuming,” but also provides MOST VITAL total particle concentration and surface area distribution information:
http://www.mass.gov/dep/toxics/stypes/tsai_meas.pdf
[So, all of the many murky discussions re micro/macro bulk materials do nothing but obfuscate regulatory matters in this regard as it renders dirty data, data detritus; micro reg is already in place and is, nevertheless, a different argument for a different day].
The metamodern fields of high-resolution spectroscopy, photonics, and quantum optics would not be making the bleeding-edge advances that they are today were the distinctive femtochemistry and attophysics disciplines so out-of-scale and their research so far out of alignment.
—
The EEB protests that the parametres are too NARROW [claiming industry lobby influence], while CEFIC says the measures are too BROAD;
FOE is alarmed by EC’s “capitulation” to industry while industry itself is altogether displeased and perturbed.
The EC has made substantive strides from the helm and is now steering towards a more promising course.
No matter what revisions it would have adopted, there would be kvetching. But, where there is no law, confusion reigns.
{And I suspect that some prefer it that way}.
To them I say, “Man up”. This is the industry that you’ve chosen. Quit the collective crying and get down to the business of compliance, re-direct your lobbying funds to investment in the very best nanometrologic instrumentation, refine your cross-species computational protocols, revisit your liability exposure portfolios, prepare for possible product recall or moratoria, and increase your employees’ health care compensation plans for assurance sake.
To the municipalities, I say, the quicker that these pioneering companies are given all that they need to make the above happen and meet the mark, the quicker will be the return, for science, for industry, for society, for the future unknown.
Either way, on the front-end or the back, someone will have to pay, and it should not be the un-suspecting public.
To the anti-nano posse, I say, “Get real, or get out of the way”. Nano is a science. You won’t stop its stride; it will not die, even if a select few nanotech companies are killed off.
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