What recommendations for nanos in the workplace?

What are the recommendations for safeguarding occupational health when using nanos?

By the AVICENN team – Last modification October 2023

The implementation of precautionary / preventive measures has been recommended by many stakeholders based on the strong uncertainties and concerns about the dangers of nanomaterials for workers’ health.

Assessing exposure to nanos in the workplace

The first recommendation is to carry out a rigorous assessment of occupational exposure to nanos – both globally (no one is able to say today how many workers are exposed to nanomaterials at the national, European or international level) and within each companiy.

At national level

The identification and quantification of workers potentially exposed to nanomaterials is currently very difficult to assess, due to lack of up to date data¹See our “Who is exposed to nanomaterials in the workplace?” fact sheet.

In order to address the lack of knowledge in the field, AVICENN advocates, among other measures, for the automatic enrollment of companies in EpiNano as soon as they submit an r-nano declaration for the nanomaterials covered by this system (carbon nanotubes, titanium dioxide nanoparticles, silica nanoparticles, and/or carbon black at this stage). This would require the relevant companies to conduct a survey of exposed workers.

More generally, the DGT of the Ministry of Labor should make more use of the r-nano register, add the actual products containing the nanos declared in the register and make it public as soon as possible, so that all workers can consult it. We are very far from this today, with only a few organizations such as INRS and Santé publique France being able to request access to some of the data. At the very least, it would be necessary for the DREETS, occupational physicians, CARSATs, regional health insurance funds and all occupational health players and preventionists to have access to this information in order to have a precise map of nanoproducts and occupational exposure to nanoparticles.

At company level

Progress in nanometrology now allow for a more precise quantification of workers’ exposure to nanomaterials. While these advancements are relatively recent and still require refinement, methods and analytical tools now exist to monitor the presence of nanomaterials in the air and can already be implemented. Most of these methods involve the expertise of one or more specialists²In the case of nanomaterials, quantifying exposures via the usual criteria (mass/chemical composition) is inappropriate and other metrics should be measured (particle size distribution, particle number and surface concentration). In companies, it is necessary to deploy these different metrics that allow the characterization of nanos but these techniques do not allow the identification of the chemical composition and the morphology of the particles. A laboratory can be used for chemical analyses, in order to know their chemical composition, their crystalline structure or their surface charge . In France, organizations such as INRS, CEA, INERIS, and LNE can currently provide support to companies and workers’ unions on this matter.

Portable instruments, relatively simple to use and less expensive than sophisticated equipment, exist and allow qualitative data such as particle number concentrations to be obtained:

• The Mini Particle Sampler MPS®, an instrument for the characterization of nano and microparticles in ambient air proposed by INERIS and ECOMESURE since 2014.
• The NANOBADGE (now PARTICLEVER sample) available since the beginning of 2015 by the company NANO INSPECT (now PARTICLEVER) and the Nanosafety Platform of CEA-LITEN in Grenoble: the sample is taken in a cassette integrated on a compact and autonomous sampler, which can be carried by the operators or positioned in a fixed station; the cassette is then extracted from the sampler and analyzed.
• The DiSCmini, marketed by Testo AG, is a portable and individual instrument that allows the real-time measurement of the number concentration and average diameter of particles.
• More generally: OPC (optical particle counter), CNC (condensations nucleus counter), SMPS (scanning mobility particle sizer), ELPI (electric low pressure impactor).

Analyzing the data collected with these portable tools, as well as interpreting the results, requires specialized and outsourced expertise. Despite being less expensive than existing large equipment, the overall cost of using these tools is still relatively high for small and medium-sized enterprises (SMEs), small businesses, artisans, etc.

Some questions remain: Are these tools reliable? Have they been already purchased by companies? What is the initial feedback on the strengths and limitations of these instruments? How to choose among the different models on offer?
The INRS (National Institute for Research and Safety) has addressed such inquiries, particularly from retirement and occupational health insurance funds (CARSAT) and occupational health services. In 2015³Cf. Laboratory study of DiSCmini performance for different aerosols in the range of 15 to 400 nm, INRS, 2015, and again in 2021, the institute tested the DiSCmini: the results show that it tends to overestimate the concentration and underestimate the diameter of particles⁴Cf. Real-time measurement of individual exposure to nanoparticles in aerosol form: performance and application example of the DiSCmini, Bau S et al, INRS, Hygiène et sécurité du travail, No. 262, March 2021: this instrument tends to overestimate the concentration by 30 to 100% and underestimate the diameter of the particles by 20 to 30% . INRS invites users to critically observe the data that are derived from the tools, in particular the issue of data processing and interpretation.
Other devices are expected to be introduced in the future⁵At the international level, several teams are working on this type of project; see in particular Miniature nanoparticle sensors for exposure measurement and TEM sampling, Fierz M et al, 4th International Conference on Safe Production and Use of Nanomaterials (Nanosafe 2014), Journal of Physics: Conference Series, 617, 2015.

Minimizing worker’s exposure

General measures

The general approach to preventing risks associated with hazardous chemicals should also apply to nanomaterials. This involves:

• ideally, to eliminate nanomaterials and to substitute them, if necessary, with non – or at least less – dangerous materials⁶Note in passing the discrepancy of such a recommendation with the policies encouraging the acceleration of the commercialization of nanomaterials….

• Alternatively, reducing exposure to the lowest possible level (according to the ALARA principle), minimizing the number of workers potentially exposed to nanomaterials, as well as the duration and level of exposure.

To this end, various measures must be strictly applied⁷(for more details, refer to the INRS publications):

• limiting certain critical operations (decanting, weighing, sampling, etc.)

• visually identifying the work areas where nanomaterials are stored/handled and limit access to workers who have received specific training on nanomaterials

• preventing the emission of nanomaterials into the air:
  • handle nanomaterials as liquid suspensions, gels, pellets or incorporated into matrices rather than as powders (which are more volatile, with a greater propensity to diffuse into the air)
  • work in enclosed systems⁸As early as 2009, the European Parliament had specifically asked the Commission to study the need to revise the legislation on worker protection with regard to, among other things, the use of nanomaterials only in closed systems or in any other way that guarantees the non-exposure of workers as long as it is not possible to reliably detect and control exposure: cf. European Parliament resolution of 24 April 2009 on regulatory aspects of nanomaterials (Article 15)
  • capture pollutants at the source (using glove boxes, chemical fume hoods and other means of aspiration adapted to the use of nanoparticles)
  • filter the air in the workplace with very high efficiency fiber filters
  • clean surfaces with wet cloths and special vacuums
  • store nanomaterials:
    • in completely sealed, closed and labelled tanks or double packaging
    • and in a cool, well-ventilated area, out of direct sunlight and away from sources of heat or ignition and flammable materials
  • install double changing rooms, adjacent to the work area, to separate street clothes from work clothes
  • limit waste, treat it specifically

• protecting exposed workers effectively:
  • filtering masks⁹INRS has conducted a study on the performance of respiratory protection masks for workers exposed to nanomaterials the results published in February 2019 confirmed the effectiveness of the masks tested (half-masks, full-face masks, half-masks and hoods) but nevertheless highlighted a very strong degradation of respiratory protection if the mask is poorly fitted or if the breathing rate increases, respirators, goggles with side protection, gloves, shoe covers, coveralls without cuffs and made of non-woven membrane (cotton is not recommended)
  • beware, however: the possibility of nanoparticles passing through certain types of nitrile or latex gloves as well as through polyethylene suits was established by research teams (Erest) from the Ecole de technologie supérieure de Montréal and by the IRSST (Canada), contradicting the results of researchers from the Commissariat à l’énergie atomique (CEA) in Grenoble who had not found any passage of nanoparticles through the nitrile membranes of protective gloves¹⁰See in particular:
    – Measurement of the effectiveness of protective gloves against nanoparticles under conditions simulating their use in the workplace, IRSST, February 14, 2018
    – “Development of methods for measuring the barrier properties of polymeric and textile membranes against nanoparticles in liquid media – Application to protective clothing and gloves” in Restitution of the national research program environment health work: Chemical substances and nanoparticles: models for the study of exposure and health effects: summary in the Participant packet (p.15) and online slide show, November 2013.
    – Research is underway in Canada: see the page dedicated to the research project “Measuring the effectiveness of protective gloves against nanoparticles under conditions simulating their use in the workplace” The first results show variable effectiveness depending on the glove model (two nitrile models showed poor effectiveness, one of which should not be used when handling nanoparticles in aqueous solution): cf. “Measurement of the effectiveness of protective gloves against nanoparticles under conditions simulating their use in the workplace” IRSST, October 2016
    – The European Commission asked the European Committee for Standardization (CEN) to give its opinion on new standardization requirements for various PPE – gloves, protective footwear, filters and masks, non-woven clothing – against solid nanoparticles. The CEN Technical Committee 162 WG 3 must revise the work program ‘Protective clothing against chemicals, infectious agents, and radioactive contamination’, which corresponds to the protection against particles in nano format, as well as the work program on ‘Air filters for general air cleanliness’.

Special attention should be given to protecting pregnant women from any exposure to nanomaterials.¹¹See in particular:
-the studies on the passage of nanomaterials through the placental barrier that we have compiled here
-the elements of alert concerning the reprotoxicity of nanomaterials, including the harmful effects on embryonic development (reprotoxicity) compiled there.

OELV nano

In France, there is no specific occupational exposure limit value (OELV) for nanomaterials, but work is being carried out, in particular on TiO2 and carbon black:

• In a December 2020 report made public in March 2021, Anses unveiled its recommendations for OELVs to strengthen risk prevention for workers exposed to TiO2 nanoparticles by inhalation: an OELV-8h of 0.80 µg/m³ and a pragmatic STELV-15 min of 4 µg/m³.
• INRS, Nanostructured carbon black: towards an occupational exposure limit value, March 2020
• INRS, Nanoscale titanium dioxide: de la nécessité d’une valeur limite d’exposition professionnelle, Hygiène et sécurité du travail, n°242, NT 36, March 2016.

Some limit values have been established abroad for certain nanomaterials (since 2007 in the United Kingdom, since 2011 in the United States* and since 2013 in Germany)¹²For more details see :
– Comparison to nanoparticle-related limit values, Nano Inspect, page accessed June 15, 2015
– Workshop report: Strategies for setting occupational exposure limits for engineered nanomaterials, Gordon SC et al, Regulatory Toxicology and Pharmacology, 68(3): 305-311, April 2014.

* As an illustration, the recommended OELVs in the United States are :

• 0.3 mg/m³ for titanium dioxide (TiO₂) nanoparticles (that of “ultrafine” TiO₂ (< 100 nm)¹³Cf. NIOSH (United States), Occupational Exposure to Titanium Dioxide, Current Intelligence Bulletin, 63, 2011 (the TLV for TiO₂ “fine” being 2.4 mg/m3)
• 1µg/m³ for carbon nanotubes (CNT) and carbon nanofibers¹⁴Cf. NIOSH (USA), Occupational Exposure to Carbon Nanotubes and Nanofibers, Current Intelligence Bulletin, 65, April 2013
• 0.9 μg/m³ for silver nanoparticles¹⁵Cf. NIOSH, Health Effects of Occupational Exposure to Silver Nanomaterials, Current Intelligence Bulletin 70, May 2021

INRS also considers that the values proposed by NIOSH (National Institute for Occupational Safety and Health) are more relevant, particularly with regard to titanium dioxide. The institute questions the very low value proposed by Anses, which is currently lower than the ones for agents classified as category 1A or 1B carcinogens at the European level and difficult to detect today by measuring instruments¹⁶Cf. the intervention of Myriam Ricaud in the seminar “Nanomaterials: what risks for health? What prevention?” organized by the Présance Paca-Corse in June 2022.

In 2014, the European Commission also mentioned exposure limit values for nanoparticles and values with no specific effect¹⁷Cf. Guidance on the protection of the health and safety of workers from the potential risks related to nanomaterials at work, Guidance for employers and health and safety practitioners, European Commission, November 2014 (p.31).

In November 2019, the European Agency for Safety and Health at Work awarded the 2018-2019 Healthy Workplaces Good Practice Award to Atlas Copco Industrial Technique, a Swedish manufacturing company that has taken a precautionary approach to minimizing worker exposure to carbon nanotubes¹⁸Cf. Sweden: protecting workers from potentially hazardous carbon nanotubes in manufacturing, OSHA Europe, November 2, 2019.

In December 2022, the researcher Araceli Sánchez Jiménez, a member of the Spanish Institute of Occupational Safety and Health (INSST), recalled the need to establish OELVs for nanomaterials to protect the health of workers¹⁹Cf. Controlling exposure to nanomaterials, Dr Araceli Sánchez (INSST), EUON, December 2022.

However, professionals point out that exposure limit values are not necessarily relevant for the consideration of immune responses and carcinogenesis, as very low doses can be as toxic as high doses.

Don’t forget “external: workers…

– On the production site

Exposure of temporary workers and subcontractors should also be minimized²⁰See in particular: CFDT, Nanotechnologies, L’exigence d’un développement responsable, November 2013
See more generally, on the lesser protection of the health of temporary workers and subcontractors:
– Occupational health: “We are facing a form of organized crime,” Le Nouvel Economiste, December 2012
– Temporary work: the lost bet of a real medical follow-up, Santé & Travail n° 073 – January 2011
– Working can seriously damage your health, Subcontracting risks, endangering others, attacks on dignity, physical and moral violence, occupational cancers, Annie Thébaud-Mony, La Découverte, 2008
– Safety at work: subcontractors are the forgotten ones of a minimalist reform, CGT CHU Toulouse, April 12, 2015.

In the event of an accident or fire, in addition to the workers present, it is also necessary for the emergency teams, firemen²¹Cf. ENSOSP, Les nanomatériaux : enjeux, risques et éléments de réflexion sur la réponse opérationnelle des sapeurs-pompiers, 2010, etc. to be informed of the presence of nanomaterials on the site and well protected.

The above precautions were defined primarily to minimize the exposure of workers specifically handling nanomaterials, mainly during the steps of:

• laboratory research
• production of nanomaterials (laboratories, chemical industry workshops, start-ups)
• transformation or integration of nanomaterials in products (research labs, cosmetics, plastics, paints, coatings, …).

Nevertheless, they must also be applied to peripheral activities, which should not be neglected, including:

• cleaning, maintenance and upkeep of premises and equipment (including filters)
• collection, transport, treatment (recycling) and/or disposal of waste that should be treated as hazardous waste²²See in particular INRS, De la production au traitement des déchets de nanomatériaux manufacturés, May 2019 (as well as everything that has been in contact with nanomaterials: packaging, ventilation system filters, vacuum cleaner bags, respiratory protection equipment, suits, etc.).

The Dutch trade union confederation (FNV) recommended in 2011 to evaluate the life cycle of nanomaterials from their entry into the company to their exit (whether finished or semi-finished products or waste)²³See Working safely with engineered nanomaterials and nanoproducts – A guide for employers and employees, Netherlands Trade Union Confederation (FNV), Netherlands, August 2012. (The first version dates from May 2011).

The German Institute for Occupational Safety and Health had already warned in 2007 that interface points in the production process must be controlled²⁴See Guidance for handling and use of nanomaterials at the workplace, German Federal Institute for Occupational Safety and Health (BAuA), 2007 (an update was published in 2012, but available in German only here) as well as the handling areas.

Finally, it is necessary to identify and eliminate other potential sources of nanomaterial emissions on all sites where nanomaterials are used / manufactured / stored.

– Downstream of the production chain

One of the weakest links is still not sufficiently known today: the (many) workers downstream of the production chain, unwittingly exposed to nanomaterials…

• … during their application / installation / use (e.g. cements, paints, dyes, cosmetics, nanocoatings)
• … during machining (cutting, sanding, drilling, polishing, etc.) and/or repair of products containing them (automotive, construction, etc.).

Painters and builders, hairdressers, health professionals, farmers, among others, unknowingly handle products containing nanomaterials due to the lack of product labeling and information on safety data sheets (SDS) – and therefore without adequate protection.

They are therefore vulnerable and less trained, informed and protected than researchers and operators of companies directly involved in nano activities who have – theoretically at least – the necessary training, protocols and equipment.

Inform and train workers and their hierarchy

Raise awareness of risks

Although it does not include specific considerations for nanomaterials, the 1989 European framework directive on occupational safety and health²⁵See Council Directive 89/391/EEC on the introduction of measures to encourage improvements in the safety and health of workers at work, 12 June 1989 – Official Journal L 183 of 29/06/1989 p. 0001 – 0008, specifies that it is the employer’s responsibility to ensure the safety of workers, in particular through adequate and regularly updated information and training on safety, as well as specific instructions. These general provisions must be applied in concrete terms, particularly in the case of nanomaterials, since the risks associated with these substances are still poorly known but potentially significant.

There is still a great deal of awareness raising and information work to be done (and adapted) with the various stakeholders:

• State control services (DREAL, DREETS, …)
• professional branches and federations
• trade unions
• occupational health and safety preventionists in the company: HSE department of companies, members of social and economic committees (CSE) and works councils (CE), staff delegates (DP), health and safety referents, company or group occupational physician, company nurse, prevention physician in the public service, etc.
• operators in contact with nanomaterials
• persons responsible for cleaning, maintenance and upkeep of equipment and premises – including those from external companies and temporary workers
• laboratory or department managers
• occupational physicians
• those at the end of the chain, builders, hairdressers, farmers, bakers, etc.

INRS²⁶Each year, INRS organizes a training program “Caracterizing and preventing risks associated with nanomaterials”, the DREETS, CARSAT, the most involved trade unions (CFDT in particular) and AVICENN can help with this awareness raising effort.

The CEA of Grenoble has set up a training module specifically dedicated to nanomaterials’ risk management for its staff.

(Theoretically) useful documents

Several documents can be consulted to assess the presence of nanos in products handled by workers.

• Safety Data Sheets ( SDS ) very rarely contain specific information on the nanometric nature of the materials manufactured or on the risks associated with their use and the recommended means of prevention. Since 2021, SDS should provide specific information on nanoforms (physicochemical characteristics and risks), but this is still far from being the case²⁷See our sheet on nanos information in SDSs.

• The technical data sheet of the products can sometimes give some information but today only in terms of physico-chemical characteristics.

• The Single Document, a safety management tool, should include important necessary information on the risks associated with nanomaterials handled in the company.

One simple measure that could be put in place as a first step to remedy this information deficit would be to force the last stakeholders in the supply chain who complete a r-nano statement, to communicate to the professional users to whom they supply “nano substances”, in addition to the declaration number, information on the risks associated with nanomaterials.

Ensure that risks are not minimized

Beyond information alone, it is necessary to ensure that the perception of nano risks is not minimized in any way. Even more than for other occupational risks, workers, even when informed, may tend to minimize nano risks, due to the invisibility of the latter, compounded by the pressure to produce results (the famous “publish or perish” in the research world; or productivity goals at the industrial level), field practices, the weight of habits, comfort considerations, overconfidence, etc., which are all parameters that can limit the application of safety rules by professionals, even well-informed ones.

Surveys of nanoscience/nanotechnology researchers (chemists or physicists) show a low awareness of the risks associated with nanomaterials – both in the United States and Canada (unlike toxicologists, ecotoxicologists, biologists, or social scientists who are generally more cautious)²⁸Cf. Scientists versus Regulators: Precaution, Novelty & Regulatory Oversight as Predictors of Perceived Risks of Engineered Nanomaterials, Beaudrie CEH et al, PLOS one, September 2014 in Europe²⁹Cf. Great deeds or great risks? Scientists’ social representations of nanotechnology, Bertoldo R et al, Journal of Risk Research, 2015 but also in France³⁰At the CEA for example:
– “New risks”, environmental controversy and participatory democracy: the example of Grenoble’s opposition to nanotechnology, Liéval C, Revue géographique de l’est, 53(1-2), 2013
– The development of nanotechnologies in Grenoble: between a deterritorialized risk and an opposition with uncertain targets, what place for a consideration of the risks at the local scale?, Liéval C, presentation at the seminar “Nanomaterials in the environment and impacts on ecosystems and human health” organized by EnvitéRA, July 2012 for example: the risk related to nanomaterials is either minimized or considered as being “under control”. However, the “control” of risks stops at the laboratory doors. The risks related to the products that come out of the lab are not controlled, exposing unsuspecting workers and/or consumers who use or repair them.
This observation is also true in Southeast Asia, particularly in countries heavily involved in nanotechnology (Indonesia, Malaysia, the Philippines, Singapore, Thailand and Vietnam), where the question of risks and safety around nano is not yet considered an important issue by researchers who are too “enthusiastic” to deal with nano safety³¹Cf. Karim ME et al, Too enthusiastic to care for safety: Present status and recent developments of nanosafety in ASEAN countries, Technological Forecasting and Social Change, 92: 168-181, March 2015…

Record workers’ exposure and monitor their long-term health

Medical surveillance of “nano” workers is necessary over time…

The need to set up a specific health monitoring system for workers exposed to nanomaterials has been emphasized for many years³²See in particular:
– Weight of epidemiological evidence for titanium dioxide risk assessment: current state and further needs, Guseva Canu I et al, Journal of Exposure Science & Environmental Epidemiology, 2019
– Nanomaterials in the workplace, What are the issues for workers’ health, ETUI, May 2013
– Working with nanoparticles: exposure registry and health monitoring, Health Council of the Netherlands, December 2012
– Feasibility elements for an epidemiological surveillance system for workers exposed to intentionally produced nanomaterials, O. Boutou-Kempf (InVS), March 2011
– Exposure registries: overview and utility for nanomaterial workers, Schulte P.A. et al, Journal of Occupational and Environmental Medicine, 53 (6 Suppl.), 42-47, 2010
– Resolution on nanotechnologies and nanomaterials, European Trade Union Confederation (ETUC ), December 2010
– Medical surveillance of workers exposed to nanomaterials: lessons from the Keystone conference, Malard S. and Radauceanu A., Documents pour le médecin du travail, 124, 489-49, 2010
– The National Exposure Registry: history and lessons learned, Schultz M.G. et al, Journal of Environmental Health, 72 ( 7), 20-25, 2010
– Interim guidance for medical screening and hazard surveillance for workers potentially exposed to engineered nanoparticles, Current Intelligence Bulletin, NIOSH (USA), 60, 2009
– Issues in the development of epidemiologic studies of workers exposed to engineered nanoparticles, Schulte P.A. et al, Journal of Occupational and Environmental Medicine, 51 (3), 323-335, 2009
– Working group for the implementation of an epidemiological follow-up of workers exposed to nanomaterials and “Risques pour la santé des nanotechnologies” (Health risks of nanotechnologies) for the national public debate on nanotechnologies of 2009-2010, IReSP, 2009
– ISO/TR 12885 Nanotechnologies – Health and safety practices in occupational settings relevant to nanotechnologies, 2008
– Les nanomatériaux, Sécurité au travail, Afsset, May 2008
– Nanotechnologies, nanoparticles: what dangers? What are the risks? Comité de la Prévention et de la Précaution (CPP), Ministry of Ecology, May 2006.
Since adverse health effects on workers associated with nanomaterials are suspected, and may take many years to appear, workers’ health must be monitored over time, including after they have ceased to be exposed to nanomaterials. As in the case of asbestos, it is feared that pathologies may appear several years – or even decades – after being exposed.

Exposed workers (including temporary workers and subcontractors, students and trainees) should therefore be able to keep the results of their medical examinations, not only throughout their period of activity but also after their occupational exposure to nanomaterials has ended.
When the workers are women, it would be advisable, in addition to all the protective measures mentioned above, to extend this medical surveillance to their offspring, to verify the possible repercussions on the state of health of their child(ren).

Studies with first results of medical follow-up are beginning to appear and confirm the concerns of the health services: they have been conducted in Taiwan³³Cf. Hui-Yi Liao et al., Six-month follow-up study of health markers of nanomaterials among workers handling engineered nanomaterials, Nanotoxicology, December 2013: a six-month study published in late 2013 found correlations between nanomaterial handling and markers of lung and cardiovascular disease, markers of inflammation and oxidative stress, and antioxidant enzymes and in Korea³⁴Cf. Lee JS et al, Health surveillance study of workers who manufacture multi-walled carbon nanotubes, Nanotoxicology, 2014.
More studies are being conducted in China, but they are rarely of good quality: many are biased, or do not detail exposure and/or working conditions.

Do occupational health services, occupational physicians, etc. have the means to ensure such monitoring? In the current state of affairs, nothing is less certain.

… In conjunction with monitoring their exposure to nanomaterials

In companies where nanomaterials are handled, monitoring of workers’ level of exposure to nanomaterials should also be carried out in parallel with the specific medical monitoring mentioned above.
As early as 2009, the creation of exposure registers for workers exposed to nanomaterials was promoted by the American Institute for Occupational Safety and Health (NIOSH)³⁵Cf. NIOSH, Interim guidance for medical screening and hazard surveillance for workers potentially exposed to engineered nanoparticles, Current Intelligence Bulletin, 60, 2009.

Combined with the implementation of these medical examinations over time, such registers could be used to:

• evaluate the medium- and long-term impact of manufactured nanoparticles on workers’ health (epidemiological studies): until now, the links between exposure and disease have not been properly established, due to a lack of data
• notify individuals of preventive measures or therapeutic advances that were not known at the time the registry was established
• adapt prevention and protection measures and means, in order to adjust them more precisely to the risks better identified thanks to epidemiological studies.

The exposure log should contain the name and physicochemical characteristics of the nanomaterial(s) handled, the type of activity, the dates, duration and intensity of exposure, as well as its frequency, and the collective and individual protective equipment used (CPE and PPE). It is important to record the level of exposure by job and process in order to conduct further epidemiological studies³⁶Cf. Aída Ponce Del Castillo (ETUI), Nanomaterials in the workplace, What are the issues for workers’ health, May 2013.
The exposure register should be kept within the company and be accessible to the health authorities, while respecting industrial and commercial confidentiality.
As with the medical record, each worker should have access to data concerning his or her personal exposure.

When will there be national registers of exposed workers?

Ideally, such registers should even be set up on a national scale. The European Trade Union Confederation (ETUC) has been demanding since 2010 that the Member States of the European Union “establish an inventory of workers exposed to nanoparticles in association with health surveillance programs. This inventory should contain information on the identity of exposed workers, the circumstances, duration and concentrations of exposure, and the protective measures used”³⁷See Resolution on nanotechnology and nanomaterials, European Trade Union Confederation (ETUC), December 2010.

In the Netherlands, in 2012, the Health Council (an independent scientific body that advises the government and parliament on public health issues) recommended the creation of an exposure register and health surveillance system for workers in contact with manufactured nanoparticles³⁸Cf. Health Council of the Netherlands, Working with nanoparticles: exposure registry and health monitoring, December 2012.

Started in 2014 in France, the EpiNano program aims to conduct epidemiological surveillance of workers potentially exposed to the most common nanomaterials. To date, very few companies have agreed to participate in the program and the few that have taken part do not necessarily complete the process.

Favoring a ‘safe by design’ nano approach?

The idea of “safe by design” of nanomaterials and/or nanotechnologies has been widely promoted by industrialists in recent months and has been developed for a number of years. It is presented as the key to the development of nanos. However, from theory to practice, there is a long way to go…

Continuing research efforts

Challenges include the development of independent risk research as well as the acceleration of the transmission of research results to the health services so that they can take the appropriate measures as soon as possible – whether it be the development or updating of regulations or information and protection measures.