Filed under: EU Information, Nanomaterials | Tags: measurements, nanotechnology
The European Union’s Joint Research Centre (JRC) had published a new report “Towards a review of the EC Recommendation for a definition of the term “nanomaterial”: Part 2: Assessment of collected information concerning the experience with the definition”, which highlights the debate surrounding the proposed EU definition of a nanomaterial, which has been highlighted previously on this blog. It follows on from an earlier report which collated information surrounding the definition and potential enforcement and monitoring tools.
The problems associated with the proposed definition of a nanoparticle – 50% of particles in a population must have one dimension in the range 1nm to 100nm – have always been the lack of validated methods which laboratories can use in order to monitor this. Indeed, introducing a draft definition with no associated measurement methods, compounded by the introduction of nanomaterial registers in some EU Member States, is really doing things back to front.
The concern about analytical measurement methods – and the report also highlights the difficulties in determining the uncertainty of nanoparticle measurements – also leads the authors to a conclusion that analytical techniques may not be capable of assessing whether over 50% of particles fit within the size limits. This leads them to pose the question as to whether the definition would be easier to monitor if the 50% limit were to be based upon mass fraction rather than number of particles. This would certainly be an improvement and, as nobody really wants a definition enshrined in EU law that can not be monitored or enforced, should be given very serious consideration.
The report also addresses the thorny issue of aggregated and agglomerated particles, and the difficulty of counting particles which have aggregated. It is to be hoped that the excellent and practical recommendations made in this report are taken on board in Brussels before the final nanoparticle definition is agreed and published.
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