May 25, 2022

Volume XII, Number 145

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EC Committee Statement on Emerging Health and Environmental Issues Includes Nanotechnology Organics and Conversion of Micro to Nano Plastics in the Environment

On January 21, 2022, the European Commission’s (EC) Scientific Committee on Health, Environmental and Emerging Risks (SCHEER) published a second statement on emerging health and environmental issues. SCHEER members have identified nine emerging issues in the non-food area as having a potential impact on human health and/or the environment in the future and have given them overall prioritization scores (*, 1, 2, or 3, where * is uncertain and three is high). The emerging issues identified include nanotechnology organics (prioritization score two) and the emerging risk of the conversion of micro to nano plastics in the environment (prioritization score three):

  • Nanotechnology organics: Organic substances are increasingly used in complex particulate formulations, including medical and agricultural applications that specifically make use of nanotechnology. This includes the combination of organic and inorganic substances, especially in medical developments, spurring growth in the development of new materials. SCHEER states that there is therefore a risk of incorrectly applied risk assessment and invalid assumptions, such as “it is organic/biological so it must be safe,” or “it is a nanomaterial so we know it cannot be absorbed.” According to the statement, organic nanoparticles can be considered borderline materials as they are organic in nature and have sizes in the nano-range (below one micrometer (μm)), and sometimes even below 100 nanometers (nm), the size indicated for nanomaterials/nanoparticles. Organic nanostructures behave like nanoparticles when intact, but change to organic biological behavior after dissociation at a potential target site. It is necessary that a clear distinction is made in the risk assessment between so-called hard solid (in)soluble nanomaterials (g., metal and metal oxides) and so-called “soft” nanomaterials composed of organic molecules, as they can have a totally different interaction/effect in biological systems.

  • Nanoplastics: According to SCHEER, the production, use, and disposal of plastic materials is “now ubiquitous.” Plastic polymers have not been considered substances of health concern because they are generally inert in nature and are unlikely to be absorbed in the body due to large molecular sizes. They are nevertheless highly persistent in the environment, where they may end up via a variety of disposal/emission routes. Gradual degradation of plastic materials over time is known to result in microplastics. SCHEER notes that these are, “in theory, likely to further degrade to nano-plastics.” SCHEER notes that this subject has been the focus of recent research and development and has been proposed as a topic of emerging environmental risk that needs further exploration.

The Commission Services will be invited to include these emerging issues in their policies and research agenda.

©2022 Bergeson & Campbell, P.C.National Law Review, Volume XII, Number 28
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About this Author

Lynn Bergeson, Campbell PC, Toxic Substances Control Act Attorney, federal insecticide lawyer, industrial biotechnology legal counsel, Food Drug Administration law
Managing Partner

Lynn L. Bergeson has earned an international reputation for her deep and expansive understanding of the Toxic Substances Control Act (TSCA), the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), European Union Registration, Evaluation, Authorization and Restriction of Chemicals (REACH), and especially how these regulatory programs pertain to nanotechnology, industrial biotechnology, synthetic biology, and other emerging transformative technologies. Her knowledge of and involvement in the policy process allows her to develop client-focused strategies whether...

202-557-3801
Carla Hutto, Bergeson Campbell PC environmental law regulatory analyst,Toxic Substances Control Act law attorney
Regulatory Analyst

Since 1996, Carla Hutton has monitored, researched, and written about regulatory and legislative issues that may potentially affect Bergeson & Campbell, P.C. (B&C®) clients. She is responsible for creating a number of monthly and quarterly regulatory updates for B&C's clients, as well as other documents, such as chemical-specific global assessments of regulatory developments and trends. She authors memoranda for B&C clients on regulatory and legislative developments, providing information that is focused, timely and applicable to client...

202-557-3809
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