On the 12th of November 2008 the Royal Commission’s study of “Novel Materials in the Environment: the case of nanotechnology” was released. The report, while long and detailed, makes shocking reading.

Most importantly it clearly points out how little we know about almost all important health and environmental aspects of nanomaterials. Products containing nanomaterials are appearing in the market place in an ever increasing number, but the collection of environmental and health data lags massively behind. Furthermore the Commission notes that it is currently very difficult to evaluate how safe or how dangerous nanomaterials are.

According to the report, scientists readily admit we remain ignorant about many aspects of the environmental fate and toxicology of nanomaterials. We also have extremely limited understanding regarding exposure levels, as well as little indication whether effects are occurring or will in future occur in the wider environment. Despite being used in hundreds of commercially available products, there is little or no knowledge of nanomaterials’ life cycles or ultimate fate in the environment. Additionally, current test procedures for assessing the risks posed by manufactured nanomaterials to the environment, non-human organisms and human beings are inadequate. The report concludes that it may years or even decades, before they are available.

As a result, the report suggests that we urgently need to ask “Would we know if nanomaterials were causing damage?” in a wider context. Clearly, the answer is no.

A number of ‘popular’ nanomaterials were singled out for special concern by the report. These were fullerenes, nanosilver and carbon nanotubes. The report pointed out that they are likely to persist in the environment and may be bioavailable. Fullerenes in particular are are highly energy intensive to produce and most of it ends up in landfill (only 10% is useable).

Scientists have demonstrated that carbon fullerenes can penetrate intact skin. There is consequently a serious risk that using fullerene-containing cosmetics will cause harm.

Investigation by Friends of the Earth has found that cosmetics sold in Australia – including by Sircuit, Dr Brandt and N.V. Perricone M.D. – are now advertised as containing fullerenes. Yet the national cosmetics regulator NICNAS appears to asleep at the wheel. It has failed to require the product manufacturers to conduct new safety tests of these high risk ingredients.

Friends of the Earth highlighted the serious toxic risks of fullerenes over 2 years ago in our report Nanomaterials, sunscreens and cosmetics: Small ingredients, big risks. It is about time these high risk cosmetics were taken off the market.

The report has also called for “urgent regulation” to manage the serious toxic risks posed by nanomaterials now in commercial use. However regulation is complicated by what the report calls the “condition of ubiquity” – nanomaterials are contained within products, may be hard to identify and are available worldwide. This means, that even if regulation exists or was enacted, nanomaterials may slip through the regulatory net, because they may not be detected by the regulators or escape regulation because they originate in a country with less stringent regulations.

The overall tone of the report is measured and sober. Given that it describes an extensive body of evidence that many nanoparticles pose serious toxicity risks, many of its conclusions could have been stronger. All the same, Friends of the Earth Australia welcomes following recommendations:

“We recommend that in any revisions to existing regulations, the relevant authorities should focus specifically on the properties and functionalities of nanomaterials, rather than size. Since these properties and functionalities will often differ substantially from those of the bulk material, strict chemical equivalence does not preclude the need for a separate risk assessment.
We recommend that, as REACH is adapted to meet the challenges presented by nanomaterials, particular attention should be given to the issue of weight thresholds. In view of the persistent uncertainties involved, a precautionary approach should be adopted when determining new, lower thresholds for nanomaterials.

We recommend that Defra should make nanomaterials reporting mandatory.

We recommend that the Government impose an additional legal duty on companies to report at the earliest opportunity to the competent authorities any reasonable suspicion that a material presents a risk to people or the environment. Compliance with this requirement should offer duty holders a degree of immunity from criminal liability, should problems associated with the nanomaterials arise in future.

We recommend the enhancement of in situ monitoring and surveillance methods to provide early warnings of unexpected effects of novel materials and to permit timely remedial action.

We recommend that it is desirable to move beyond one-off public engagement ‘projects’ to recognize the importance of continual ‘social intelligence’ gathering and the provision of ongoing opportunities for public and expert refection and debate. We see these functions as crucial if, as a society, we are to proceed to develop new technologies in the face of many unknowns.”

To quote Professor Susan Owens, of the University of Cambridge, said: “If we don’t do anything and we leave it, then things manifest themselves in 10 to 15 years’ time. By then the technology is so embedded in society it’s very difficult to deal with it.”1

To summarize the report in two sentences: At least some nanomaterials are likely to kill people in the future. Only by introducing rigorous safety systems, including widespread monitoring and intensive research, can threats posed by nanomaterials be identified and countered, the Royal Commission concluded.

Rye Senjen, November 2008

1 From : http://www.timesonline.co.uk/tol/news/environment/article5134227.ece