What are the recommendations for reconciling nanos and occupational health?

What are the recommendations for reconciling nanos and occupational health?

By the AVICENN team – Last modification December 2022

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

Assessing exposure to nanotechnology in the workplace

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

At the national level

The identification and quantification of workers potentially exposed to nanomaterials is currently very difficult to achieve, due to the lack of updated dataSee¹our “Who is exposed to nanomaterials in the workplace?” fact sheet.

In order to make up for the lack of knowledge in this area, AVICENN advocates, among other things, to make the registration of companies in EpiNano as soon as they complete a declaration r-nano for the nanomaterials covered by this device (carbon nanotubes, titanium dioxide nanoparticles, silica nanoparticles and/or carbon black at this stage). The companies concerned would thus be required to carry out a census of exposed workers.

More generally, the r-nano The DGT of the Ministry of Labour should make more use of this register, include the 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 the INRS and Santé publique France being able to request access to certain data! At the very least, it would be necessary for the DREETS, occupational physicians, CARSATs, regional health insurance funds and all occupational health actors and preventionists to have access to this information in order to have a precise map of nanoproducts and occupational exposure to nanoparticles.

At the company level

Advances in nanometrology now make it possible to better quantify the exposure of workers to nanomaterials. Although these advances are recent and still need to be refined, methods and analytical tools now exist to monitor the presence of nanomaterials in the air and can already be deployed. Most of them require the use of an expert(s)²In 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 to characterize nanos but these techniques do not allow to know the chemical composition and the morphology of the particles. The use of a laboratory allows to realize chemical analyses, in order to know their chemical composition, their crystalline structure or their surface charge . In France, INRS, CEA, INERIS and LNE can now support companies and employee unions in this area.

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 PARTICLELEVER sample) offered 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 (scnanning mobility particle sizer), ELPI (electric low pressure impactor).

The analysis of the data collected with these portable tools, as well as the interpretation of the results, requires a specialized and outsourced expertise.
In the end, the overall cost of using these tools, although lower than for the large equipment existing until now, is still not affordable for SMEs, VSEs, craftsmen, etc.

Other questions: Are these tools reliable? Have any companies already purchased them? What is the initial feedback on the strengths and limitations of these instruments? How to choose among the different models offered?
The INRS receives this type of questioning, particularly from retirement and occupational health insurance funds (CARSAT) and occupational health services. In 2015Cf.³Laboratory 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% . The INRS invites users to critically observe the data that are derived from it, addressing in particular the issue of data processing and interpretation.
Other devices are expected to be released⁵At 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.

Minimize worker exposure

General measures

The general risk prevention approach implemented for hazardous chemicals must be applied to nanomaterials. These are:

• at best, toeliminate nanomaterials and to substitute them, if necessary, with non – or at least less – dangerous materialsNote⁶in passing the discrepancy of such a recommendation with the policies of encouraging the acceleration of the commercialization of nanomaterials…

• failing that, to reduce exposure to the lowest possible level (according to the ALARA principle), keeping the number of workers potentially exposed to nanomaterials as well as the duration and level of exposure to a minimum.

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

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

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

• prevent 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 a vacuum⁸As 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 (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
  • storing 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

• Directly protect exposed workers:
  • filtering masks⁹The INRS has conducted a study on the performance of respiratory protection masks for workers exposed to nanomaterials the results published in February 2019 confirm the effectiveness of the masks tested (half-masks, full-face masks, half-masks and hoods) but nevertheless highlight a very strong degradation of respiratory protection if the mask is poorly fitted or if the breathing rate increasesRespirators, 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 has 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’.

Pregnant women must be particularly protected from any exposure to nanomaterialsSee¹¹in particular:
–¹²the studies on the passage of nanomaterials through the placental barrier that we have compiled here
–¹³the elements of alert concerning the reprotoxicity of nanomaterials, including the harmful effects on embryonic development (reprotoxicity) compiled there.

VLEP 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, the Anses unveiled its recommendations for ELVs to strengthen risk prevention for workers exposed to TiO2 nanoparticles by inhalation: an ELV-8h of 0.80 ^µg/m3 and a pragmatic TLV-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)¹⁴For 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 TLVs in the United States are :

• 0.3 mg/m3 for titanium dioxide (TiO₂) nanoparticles (that of “ultrafine” TiO₂ (< 100 nm)¹⁵Cf. 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 nanofibers¹⁶Cf. NIOSH (USA), Occupational Exposure to Carbon Nanotubes and Nanofibers, Current Intelligence Bulletin, 65, April 2013
• 0.9 ^μg/m3 for silver nanoparticles¹⁷Cf. NIOSH, Health Effects of Occupational Exposure to Silver Nanomaterials, Current Intelligence Bulletin 70, May 2021

The 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 the Anses, which is currently lower than for agents classified as category 1A or 1B carcinogens at the European level and difficult to detect today by measuring instruments¹⁸Cf. 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 no specific effect values¹⁹Cf. 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 nanotubes²⁰Cf. Sweden: protecting workers from potentially hazardous carbon nanotubes in manufacturing, OSHA Europe, November 2, 2019.

In December 2022, the researcher Araceli Sánchez Jiménez, member of the Spanish Institute of Occupational Safety and Health (INSST), recalled the need to establish ELVs for nanomaterials to protect the health of workers²¹Cf. 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.

Do not forget the “outside” workers…

– On the production site

Exposure of temporary workers and subcontractors should also be minimized²²See 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 that the emergency teams, firemen²³Cf. ENSOSP, Les nanomatériaux : enjeux, risques et éléments de réflexion sur la réponse opérationnelle des sapeurs-pompiers, 2010etc. are well 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, …)

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

• cleaning,maintenance andupkeep of premises and equipment (including filters)
• the collection, the transport, the treatment (recycling) and/orwaste disposal that should be treated as hazardous waste²⁴See 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 from their entry into the company to their exit (whether finished or semi-finished products or waste)²⁵See 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 controlled²⁶See 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 aware today: the (many) workers downstream of the production chain, exposed to nanomaterials without knowing it…

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

Painters and masons, hairdressers, health professionals, farmers, among others, handle products containing nanomaterials without their knowledge – due to the lack ofproduct labeling and information on safety data sheets(SDS) – and therefore without adequate protection!

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

Inform and train workers and their management

Raising awareness of risks

Although it does not include specific considerations for nanomaterials, the 1989 European framework directive on occupational safety and health²⁷See 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 However, it 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 and potentially significant.

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

• State control services (DREAL, DREETS, …)
• professional branches and federations
• 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 outside companies and temporary workers
• laboratory or department managers
• occupational physicians
• at the end of the chain, masons, hairdressers, farmers, bakers, etc.

The INRS, the DREETS, the CARSAT, the most involved trade unions (CFDT in particular) and AVICENN can help in this awareness work.

(Theoretically) useful information materials

Several documents can be consulted to try to learn more about the presence of nanos in the products handled by workers.

• Safety Data Sheets ( SDS ) very rarely contain specific information on the nanometric nature of the materials manufactured as well as on the risks associated with their use and the recommended means of prevention. Since 2021, SDSs must provide specific information on nanoforms (physicochemical characteristics and risks), but this is still far from being the caseSee²⁸our 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, is another important information medium in which the necessary information on the risks associated with nanomaterials handled in the company should be included.

One simple measure that could be put in place as a first step to remedy this information deficit would be to oblige the last actors 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 nanos risks is not minimized by various means. Even more than for other occupational risks, workers, even when informed, may tend to minimize nanoscale risks, due to their invisibility, to which is added the pressure to produce results (the famous “publish or perish” of the research world; or productivity objectives at the industrial level), field practices, the weight of habits, considerations of comfort, overconfidence, etc., all of which are parameters likely to limit the application of safety rules by professionals, even when they are well informed.

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)²⁹Cf. Scientists versus Regulators: Precaution, Novelty & Regulatory Oversight as Predictors of Perceived Risks of Engineered Nanomaterials, Beaudrie CEH et al, PLOS one, September 2014in Europe³⁰Cf. Great deeds or great risks? Scientists’ social representations of nanotechnology, Bertoldo R et al, Journal of Risk Research, 2015 but also in France³¹At 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, in the latter case, the “control” of risks stops at the laboratory doors! The risks related to the products that come out of them are not controlled, exposing workers who use or repair them and/or consumers, without them being aware of it.
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 safety³²Cf. 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 health over the long term

Medical surveillance of “nano” workers is necessary on the long term…

The need to set up a specific health monitoring system for workers exposed to nanomaterials has been pointed out for many years³³See 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 feared, and may take many years to appear, worker health surveillance must be conducted over the long term, including after workers 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 workers are exposed to nanomaterials.

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 Taiwan³⁴Cf. 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 Korea³⁵Cf. 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? As things stand, nothing is less certain.

… to be backed up by a follow-up of their exposure to nanomaterials

In companies where nanomaterials are handled, monitoring of worker 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)³⁶Cf. NIOSH, Interim guidance for medical screening and hazard surveillance for workers potentially exposed to engineered nanoparticles, Current Intelligence Bulletin, 60, 2009.

Combined with the conduct of these medical examinations over the long term, such registries would:

• evaluate the medium- and long-term impact of manufactured nanoparticles on workers’ health (epidemiological studies); this is a matter of filling a gap, because 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
• toadapt 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 (EPC and PPE). It is important to record the level of exposure by job and process in order to conduct further epidemiological studies³⁷Cf. 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 thus demanded 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.”³⁸See 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 establishment of an exposure registry and health surveillance system for workers in contact with manufactured nanoparticles³⁹Cf. Health Council of the Netherlands, Working with nanoparticles: exposure registry and health monitoring, December 2012.

Since 2014 in France, the EpiNano scheme aims to conduct epidemiological surveillance of workers potentially exposed to the most common nanomaterials. To date, very few companies have unfortunately agreed to participate in the scheme and the few that have taken part do not necessarily go all the way.

Favouring 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. So be careful…

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.