I was trying to reference the song, Amazing Grace, in my headline but I’m beginning to think I should be talking about invisibility cloaks. Still, glory halleluiah! I do believe I have found some information about the Canadian nanomaterial reporting plan/scheme/inventory that was announced in Jan. 2009 and which I’ve discussed elsewhere in this blog (most recently here).
The information is in the latest report (No. 20, Feb. 2010) from the OECD’s (Organization for Economic Cooperation and Development) Working Party on Manufactured Nanomaterials. (Thanks to this news item on Nanowerk for the pointer.)
From page 29 of the Feb. 2010 OECD report [editorial notes in square brackets] ETA July 25, 2011: This is a more complete citation for the report, CURRENT DEVELOPMENTS/ACTIVITIES ON THE SAFETY OF MANUFACTURED NANOMATERIALS Tour de Table at the 6th Meeting of the Working Party on Manufactured Nanomaterials, Paris, France 28-30 October 2009, published February 2010,
Following decisions made at the multi-stakeholder workshop held in September 2007 [and announced by the Project Emerging Nanotechnologies based in Washington, DC in Jan. 2009],
Environment Canada and Health Canada are pursuing a mandatory information gathering survey, under the authority of Section 71 of CEPA 1999. The objective of this survey is to gather use pattern information, including volumes and sectors of use, and any relevant toxicological data already available for nanomaterials in commerce during 2008.
With further details on page 31,
Based on the discussions at the multi-stakeholder workshop (September 2007), Environment Canada and Health Canada are pursuing a mandatory survey under the authority of Section 71 of the Canadian Environmental Protection Act, 1999. The information gathering effort will focus on obtaining information on nanomaterials from industry and on building a knowledge base to inform risk assessment and management approaches.
Respondents will be required to submit information on:
• Identification of nanomaterials imported or manufactures in excess of 1 kg during the calendar year 2008;
• Includes research and development materials
• Basic use patterns including volumes, sectors of use, types of products
• Any physical-chemical property or toxicological data available.
• Available stewardship practices
This answers some of the questions I had at the time of the announcement but raises still more. For example, have businesses been keeping records that will allow them to access the details being requested by Environment Canada and Health Canada two years after the fact? What type of measurements are going to be used, i.e., nanoscale or macroscale? Will this be annual or semi-annual, or one-time only (as originally announced in Jan. 2009)?
The report also notes that Industry Canada has identified (as of August 2009) some 630 companies (including both domestic and US-headquartered ones) which are somehow involved in nanotechnology in final goods production, or R & D (research and development) activities, intellectual property services, and intermediate and primary production of nanomaterials. From page 31 of the report,
Of the 630 companies identified, 437 of the 630 companies are intermediate or final goods companies.
Key nanotechnology application areas are healthcare, equipment & tools, structural materials (nanoenabled products), and electronics. Of these, pharmaceuticals and the treatment of disease or illness are very important applications for both intermediate and final goods companies, while electronic components are an important application area particularly for intermediate companies. Provinces with strong involvement in nanotechnology currently are Ontario, Quebec, Alberta and British Columbia.
In collaboration with Environment Canada, in February 2009 Industry Canada collected data on the number of consumer products on the Canadian market that incorporated nanotechnology-based components or technologies. These were estimated at over 1600 products, with 68% being imported into Canada from more than 11 different countries. Products ranged from “stronger, more durable, lighter” sports equipment, to stain & wrinkle-free pants, antimicrobial clothing and appliances, to cosmetics, sunscreens and drugs.
Over 1600 ‘nano’ products are being imported into Canada? They know this because, from the report, p. 31,
In collaboration with Environment Canada, in February 2009 Industry Canada collected data on the number of consumer products on the Canadian market that incorporated nanotechnology-based components or technologies.
This data collection seems a bit odd given that Environment Canada’s definition of nanomaterials that need to be reported specifically excludes nano titanium dioxide which is a very popular nano material. (I have more about definitions in section following in this post.) Plus, I wonder where else this information about the number of products with nanomaterials is available and how many Canadians know about it?
What astounds me is how much work is being done—in secret (to all intents and purposes). There is some very encouraging news (research, international collaboration, etc.) in this report and, of course, there are issues but that’s to be expected. Still, it’s this secrecy (deliberate or not) that’s most disturbing.
As for the report, I do think the section about ‘Information on any public/stakeholder consultation’ deserves a big black mark. From page 36,
6 Information on any public/ stakeholder consultation
None to report. [emphasis mine]
There was a ‘stakeholder’ consultation in 2007, (from page 30)
A. The first multi-stakeholder workshop was hosted by Environment Canada and Health Canada (September 2007) brought together representatives from government, industry, public interest groups, and academia to obtain feedback on a proposed regulatory approach for nanomaterials under the Canadian Environmental Protection Act, 1999. In response to this workshop, the government is pursuing a mandatory information gathering survey under the authority of the Canadian Environmental Protection Act, 1999.
Who were these multi-stakeholders? As well, you’ll note there’s been absolutely no public consultation or even public outreach nor are there any plans for either, according to this report.
Meanwhile, Health Canada chugs forward with its own nanotechnology plans.
Health Canada’s public consultation and proposed nano portal
As I’ve noted previously, Health Canada is requesting submissions and comments (is this public consultation?) for an interim policy (already adopted) on definitions for nanomaterials. From the interim policy statement web page,
The key objectives of this policy statement are to:
1. Establish a working means of identifying nanomaterials;
2. Assist Health Canada to collect information and establish internal inventories [emphasis mine] regarding products, materials, substances, ingredients, devices, systems or structures that are, contain, or make use of nanomaterials;
3. Support communications about nanomaterials with the broader community of interested stakeholders; and,
4. Support the administration of the legislative and regulatory frameworks under the authority of Health Canada and to help further the development of policy, guidance and programs applicable to nanomaterials.
Here’s the definition that Health Canada (from the web page) is using,
Health Canada considers any manufactured product, material, substance, ingredient, device, system or structure to be nanomaterial if:
1. It is at or within the nanoscale in at least one spatial dimension, or;
2. It is smaller or larger than the nanoscale in all spatial dimensions and exhibits one or more nanoscale phenomena.
For the purposes of this definition:
* The term “nanoscale” means 1 to 100 nanometres, inclusive;
* The term “nanoscale phenomena” means properties of the product, material, substance, ingredient, device, system or structure which are attributable to its size and distinguishable from the chemical or physical properties of individual atoms, individual molecules and bulk material; and,
* The term “manufactured” includes engineering processes and control of matter and processes at the nanoscale.
So a company is required to report about its nanomaterial use from 2008 using this definition (for which they are still receiving comments and submissions) or the definition in use by Environment Canada since 2007? From my April 2, 2010 posting,
If you manufacture in or import into Canada a new substance, you may be required to notify information with respect to this substance pursuant to the Act and the Regulations. The Act requires that the prescribed information under the Regulations be submitted to the Minister of the Environment prior to exceeding specific regulatory triggers either through the manufacture or import of a new substance.
Substances listed on the DSL whose nanoscale forms do not have unique structures or molecular arrangements are considered existing. Existing nanomaterials are not subject to the Regulations and do not require notification. For example, titanium dioxide [emphasis mine] (CAS No. 13463-67-7) is listed on the DSL and since its nanoscale form does not have unique structures or molecular arrangements, it is not subject to the Regulations.
Notice it’s not necessary to mention titanium dioxide to Environment Canada but it seems you have to mention it to Health Canada, possibly as part of the joint nanomaterial reporting inventory/plan/scheme where details (of a sort) seem to be available only in a report by an international agency?
As for the Health Canada ‘definitions for nanomaterials’ public consultation (?), how was this promoted? Did they just put up a website and hope that interested parties would find it? I ask this because Health Canada is apparently going to launching a ‘nanoportal’ in Spring 2010. From the report, p. 29,
Health Canada is leading the development of the “Nanoportal” website which will act as a gateway to the latest information on nanotechnology. The target launch date for the Nanoportal is anticipated to be Spring, 2010.
Is this going to be as well promoted as their public consultation on nanomaterial definitions? I hope the answer is no.
On the plus side, Health Canada’s Science Policy Directorate does invite questions. (I believe I will take them up on this offer. ETA April 12, 2010: I have emailed the Science Policy folks with my questions.) You can contact them yourself here,
Policy, Planning and Coordination Division
Science Policy Directorate
Strategic Policy Branch
1600 Scott Street – Tower B, Suite 410
Holland Cross, Address Locator: 3104A
You can also find their consultation document here in both HTML and PDF formats.