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RIVM Takes Critical Look at EUON

The Dutch National Institute for Public Health and the Environment (RIVM) published a brochure entitled “The European Union Observatory for Nanomaterials:  A step forward?” on November 30, 2017.  RIVM concludes that the European Union (EU) Observatory for Nanomaterials (EUON) will have a limited contribution to reducing the uncertainty regarding the safety of nanomaterials.  Although several EU Member States, including the Netherlands, supported a mandatory EU-wide registration system for nanomaterials, the European Commission (EC) created the EUON.  RIVM explores the consequences of this decision for the available knowledge regarding the use and safety of nanomaterials.  According to RIVM, for the Dutch government to protect humans and the environment, it is important to know which products contain nanomaterials and what the potential risks of these materials are for public health and the environment.  While the EUON contributes to this knowledge by collecting the available information in one central location, the quality of the information is also important.  RIVM states that one of the sources of information is the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) regulation, but notes that “this risk assessment framework is not yet sufficiently suitable for nanomaterials.”  In addition, according to RIVM, the information is limited to broad categories of products and articles, and brand names are not specified.  RIVM concludes that “it will remain difficult for consumers, as well as others, to judge whether they are actually using a ‘nanoproduct’ and what the potential health consequences are of such use.  Accordingly, even though the EUON maintains a separate web portal for consumers, it appears most relevant for experts, competent authorities, and industry.”

©2017 Bergeson & Campbell, P.C.

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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

Owner of Bergeson & Campbell, P.C. (B&C®), 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...

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Carla Hutton, Bergeson Campbell PC, global regulatory attorney, public health activists lawyer, metals industry legal counsel, Toxic Substances Control Act law
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 initiatives. These tasks have proven invaluable to many clients, keeping them aware and abreast of developing issues so that they can respond in kind and prepare for the future of their business.

Ms. Hutton brings a wealth of experience and judgment to her work in federal, state, and international chemical regulatory and legislative issues, including green chemistry, nanotechnology, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the Toxic Substances Control Act (TSCA), Proposition 65, and the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) program.

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