The Dutch National Institute for Public Health and the Environment (RIVM) have published a report on “Interpretation and implications of the European Commission Recommendation on the definition of nanomaterial”. The recommendation states that the proposed size limits for nanoparticles should be between 1 and 100 nm and that at least 50 % of the number of particles should be in this size range.
RIVM are concerned that the 50 % particle number threshold has no scientific basis but has the advantage that the threshold can be determined by the median without knowing the details of the size distribution.
The authors, however, do state that the practicality of the definition depends on accurate and reproducible measurement of the key elements and, where necessary, this should be performed with more than one analytical method. Adequate methods are currently available for pristine nanomaterials but not necessarily in all relevant matrices.
Standardised measurement methods are being developed and appropriate methods should be available in the future. This view coincides very much with the views of the Government Chemist and work is currently being undertaken at LGC in this area. The enforcement of any nanomaterials regulation will depend on validated, appropriate measurement procedures.
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