Draft Position of industriAll European Trade Union
on nanotechnology and nanomaterials
Chemical innovations play a central role in shaping the future, making significant contributions
towards people’s basic needs in relation to health and food products, household, energy efficiency
and the environment, clothing and communication. Nanotechnology also plays a crucial role,
especially in innovations linked to resource and energy-saving technologies and mobility, as well
as for the development of new materials and their many applications. These applications include
climate and resource protection or improved medical diagnosis for example.
As a key-enabling technology, nanotechnology is expected to clearly influence the labour market of
the 21st century, with the creation, development and preservation of jobs in Europe.
Nanotechnology indeed offers great potential for growth and jobs. Competences and skills of
workers therefore play a key role.
SMEs and start up companies play a key role in the innovation process in the field of
nanotechnology. Often, they occupy a specific niche in the value chain between basic research,
applied research, product and application development. Their function therefore varies between
direct providers, suppliers or service providers and individuals producing components for large
companies or offering tailored system solutions or services. The support and acceptance of these
companies are essential for such businesses to remain located Europe.
The social acceptance of this new technology is an important prerequisite for their success. Taking
advantage of the opportunities of nanotechnology while at the same time examining the risks and
minimising them, may be the way forward. We need an open social dialogue about the future
opportunities, awareness of the possible risks and the safe handling and use of nanomaterials.
Everyone must deal responsibly with nanotechnology and enter into dialogue, including on the
issue of skills.
However, given the lack of knowledge about the risks associated with nanomaterials, industriAll
Europe still thinks that their use in the various industries should be supported by real and proven
value and benefit to the end-users. The opening of some articles of REACH which is not desirable
from an industry point of view now may later become reasonable and necessary if adequate levels
of health and environment protection are not reached by the formulation of the annexes and
guidance or by other legislative ways.1
In addition, an extensive program of public and private research must be coordinated at European
level to increase knowledge on nanomaterials, their properties and potential risks to the health of
workers and consumers, and to the environment. In particular, significant progress must be made
to develop appropriate methods in toxicology and ecotoxicology to improve progress in scientific
analysis of these risks. This must be part of the program priorities of European and national
research.
To fully unfold the innovation potential of nanotechnology and benefit from the opportunities it
presents, as for any new technology the risks must be managed carefully. The social and societal
acceptance of this innovative technology is an essential prerequisite for its success. All
stakeholders (producers, workers and end-users, etc.) should handle nanotechnology responsibly
and engage in a dialogue based on their respective competences. The risk assessment and
1
industriAll Europe position on the REACH Review – June 2013
labelling of nanomaterials should be based on the REACH and the CLP regulations. Before
reaching a sufficient knowledge of the properties of nanomaterials, however, the precautionary
principle should be applied.
Safe handling and responsible use
In Europe, the chemical, rubber, glass, plastics, nanoelectronics industries, etc. are obliged to
manage their organisation responsibly. All chemical products must be safe in their handling.
Chemicals must not harm people or the environment and must be safe to use. This applies to any
product produced or marketed by the chemical industry and other industry players, including
nanomaterials.
The chemical industry is obliged by law to set up risk management. This is done by means of the
organisation and technical implementation of occupational health and safety measures as well as
measures to warrant product safety. IndustriAll Europe believes that safety research should
develop preventive exposure scenarios to help design better health and safety measures at work.
Exposure scenarios should describe the procedures relating to the production, processing and use
of a material and assess the emissions expected, their duration and frequency, as well as the risk
management measures required for the safe handling of the material.
OHS stakeholders such as the relevant authorities, statutory accident insurers, scientists and
companies are obliged to ensure the safe handling of chemical substances and therefore of
nanomaterials. Workers representatives should monitor the compliance with regulations relating to
health and safety and accident prevention in the company. Protective measures must be reviewed
regularly for effective protection from the possible dangers of nano-scale particles. If the toxic
effect cannot be assessed with certainty, protective measures must be designed to be suitable to
protect from potential dangers. Technical protective measures are implemented preferably.
Personal protective measures are only to be applied if no technical measures are available.
In all industries, all partners in the value chain should ensure the safe handling of nanomaterials. A
clear set of methods and procedures along the entire value chain and an established information
flow are therefore required. Information to the workers in particular is necessary and must be
improved on risks at the workplace.
The primary task of the chemical industry is to deliver the central basic data for a toxicological and
eco-toxicological assessment of the nanomaterials. The assessments of the intended applications
must also be implemented in cooperation with the users. This is mainly done via the safety
datasheets, but also with information in technical leaflets, scientific publications, as well as during
congresses, specialists conferences or forums, where findings from safety research are being
disseminated.
Product responsibility must apply from research to disposal
When it comes to nanomaterials and other products, companies must examine in the development
phase, how their new products can be produced and used safely. The examinations must be
completed by the time of market introduction and notes on the safe use must have been produced.
Additionally, companies must specify how to dispose of the products professionally. Products
harmful to health or the environment must be banned from entering the market.
The European Commission confirmed the pioneering importance of nanotechnology. In order to
ensure a high level of protection of human health and the environment while maintaining current
and future opportunities for technological development and further growth in this cutting-edge
sector, the focus now has to be placed on prevention and protection. Concrete steps have to be
developed to implement them in a practical way. It is therefore also necessary to assess the safety
of nanomaterials case by case until the current lack of measurable impacts is remedied to, in order
to ensure the development of the industry. It is important for the nanotechnology industry and for
the new investments that the playing field for the future is clear both at European and international
levels.
IndustriAll Europe is committed to engaging in a dialogue with organisations involved in the safe
and responsible development and use of nanotechnology. For example, nanotechnology is a topic
that the European sectoral social dialogue could discuss and it would make sense for the
European social partners for the chemical industry, and downstream users industries, to consider
how to broach this topic jointly.
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