What recommendations for reconciling nanos and occupational health?

What recommendations for reconciling nanos and occupational health?

By AVICENN Team – Last Modified December 2022

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

Assess exposure to nanos in the workplace

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

On a national level

The identification and quantification of workers potentially exposed to nanomaterials is currently very difficult to achieve, due to a lack of up-to-date data.¹See our file “Who is exposed to nanomaterials in the workplace? ».

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

More generally, the register r-nano should be further exploited by the DGT of the Ministry of Labor, include the products which contain the nanos declared in the register and made public as soon as possible, so that all workers can consult it – we are very far from this today, only a few organizations such as INRS and Public Health France can request access to certain data! At the very least, it would be necessary for the DREETS, the occupational physicians, the CARSATs, the regional health insurance funds and all the players and preventers in occupational health to also be able to access it in order to have a precise mapping of nano products and occupational exposure to nanos.

At company level

The advances in nanometrology now make it possible to better quantify the exposure of workers to nanomaterials; they are certainly recent and still need to be refined, but now methods and analysis tools exist to control the presence of nanomaterials in the air and can already be deployed. Most require the use of an (or even) expert(s)²In the case of nanomaterials, quantifying exposure using the usual criteria (chemical mass/composition) is inappropriate and other metrics should be measured (particle size distribution, particle number and surface concentration). In business, it is advisable to deploy these different metrics which make it possible to characterize nanos, but these techniques do not make it possible to know the chemical composition and the morphology of the particles. The use of a laboratory makes it possible to carry out chemical analyzes 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 on the subject.

Portable instruments, relatively easy to use and less expensive than sophisticated equipment, exist and provide qualitative data such as particle number concentrations, in particular:

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

The analysis of the data collected using these portable tools, like the interpretation of the results, requires specialized and outsourced expertise.
In the end, the overall cost of using these tools, although lower than for existing large equipment until now, remains unaffordable today for SMEs, VSEs, craftsmen, etc.

Other questions: Are these tools reliable? Have companies already bought them? What are the first feedbacks on the strengths and limitations of these instruments? How to choose among the different models offered?
INRS receives this type of questioning, in particular from pension and occupational health insurance funds (CARSAT) and occupational health services. In 2015³See Laboratory study of DiSCmini performance for different aerosols in a range of 15 to 400 nm, INRS, 2015, then again in 2021, the institute tested the DiSCmini: the results show that it tends to overestimate the concentration and underestimate the particle diameter⁴See Real-time measurement of individual exposure to nanoparticles in the form of aerosols: performance and example of application of the DiSCmini, Bau S et al., INRS, Industrial hygiene and safety, n°262, March 2021: this instrument tends to overestimate the concentration by 30 to 100% and to underestimate the diameter of the particles by 20 to 30% . INRS invites users to have a critical observation with regard to the resulting data, in particular by addressing the issue of data processing and interpretation.
Other devices should see the light of day⁵At the international level, several teams are working on this type of project; see notably 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 apply to nanomaterials. It's about :

• at best, toeliminate nanomaterials and to replace them, if necessary, with materials that are not – at least less – dangerous⁶Note in passing the discrepancy of such a recommendation with the policies encouraging the acceleration of the commercialization of nanomaterials...

• failing that, reduce exposure to the lowest possible level (according to 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 applied.⁷(for more details, refer to INRS publications) :

• limit certain critical operations (transfer, weighing, sampling, …)

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

• prevent the emission of nanomaterials into the open air :
  • manipulate nanomaterials in the form of liquid suspension, gel, pellets or incorporated into matrices rather than in the form of 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 the protection of workers with regard, in particular, to the use of nanomaterials only in closed systems or in any other way guaranteeing 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 the regulatory aspects of nanomaterials (section 15)
  • capture pollutants at source (glove boxes, chemical type hoods and other means of aspiration adapted to the use of nanoparticles)
  • filter the air workplaces with very high efficiency fiber filters
  • clean surfaces using damp cloths and special vacuum cleaners
  • storing nanomaterials:
    • in totally leak-proof tanks or double packaging, closed and labeled
    • et in cool, well-ventilated rooms, out of direct sunlight and away from any source of heat or ignition and flammable materials
  • install double locker rooms, adjacent to the work area to separate street clothes from work clothes
  • limit waste, treat it specifically

• directly protect exposed workers :
  • filter masks⁹INRS 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 masks, half masks and hoods) but nevertheless highlight a very strong deterioration in respiratory protection if the mask is poorly adjusted or if the rhythm respiratory increases, respirators, goggles with side protection, gloves, shoe covers, coveralls without cuffs and in non-woven membrane (cotton is not recommended)
  • be careful though : the possibility of passage of nanoparticles through certain types of nitrile or latex gloves as well as through polyethylene coveralls was established by research teams (Erest) from the Ecole de technologie supérieure in Montreal and by the IRSST (Canada), contradicting the results of researchers from the Atomic Energy Commission (CEA) in Grenoble who had no no passage of nanoparticles through the nitrile membranes of protective gloves was found¹⁰See 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 polymer and textile membranes against nanoparticles in a liquid medium – Application to protective clothing and gloves” in Restitution of the national environmental and occupational health research program: Chemical substances and nanoparticles: models for the Study of exposures and health effects: summary in the Participant's file (p.15) and Online slideshow, November 2013.
    – Research is underway in Canada: see the page dedicated to the research project "Measurement of the effectiveness of protective gloves against nanoparticles under conditions simulating their use in the workplace", carried out jointly by McGill University, the École de technologie supérieure, the Université de Montréal and funded by the IRSST and NanoQuébec: initial results show variable effectiveness depending on the glove model (two nitrile models presented a mediocre efficacy, one of them even having to be discouraged 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 different PPE – gloves, protective footwear, filter 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 protection against particles in nano format, as well as the work program relating to 'air filters for the general cleanliness of the air.

The pregnant women must be particularly protected from any exposure to nanomaterials¹¹See in particular:
– the studies on the passage of nanomaterials through the placental barrier that we have compiled here
– warning elements concerning the reprotoxicity of nanomaterials, including the harmful effects on embryonic development (reprotoxicity) compiled leaves.

OEL nano

In France, there is no workplace exposure limit value (OEL) specific 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 revealed its OELV recommendations to reinforce risk prevention for workers exposed to TiO2 nanoparticles by inhalation: OEL-8h of 0,80 µg/m³ and pragmatic VLCT-15 min of 4 µg/m³.
• INRS, Nanostructured carbon black: towards an occupational exposure limit valueMarch 2020
• INRS, Nanometric titanium dioxide: the need for an occupational exposure limit value, Industrial hygiene and safety, n°242, NT 36, March 2016.

A few 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 with limit values ​​related to nanoparticles, Nano Inspect, page consulted on 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.

* By way of illustration, the OELs recommended in the United States are:

• 0,3 mg/m3 for titanium dioxide (TiO₂) nanoparticles (that of “ultrafine” TiO₂ (< 100 nm)¹³See NIOSH (USA), Occupational Exposure to Titanium Dioxide, Current Intelligence Bulletin, 63, 2011 (the OEL of “fine” TiO₂ being 2,4 mg/m3)
• 1µg/m3 for carbon nanotubes (CNTs) and carbon nanofibers¹⁴See NIOSH (USA), Occupational Exposure to Carbon Nanotubes and Nanofibers, Current Intelligence Bulletin, 65, April 2013
• 0,9 μg/m³ for silver nanoparticles¹⁵See NIOSH, Health Effects of Occupational Exposure to Silver Nanomaterials, Current Intelligence Bulletin 70, May 2021

INRS also considers that the values ​​proposed by the 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 for agents classified as category 1A or 1B carcinogens at European level and difficult to detect today by measuring instruments.¹⁶See Myriam Ricaud's intervention in the webinar "Nanomaterials: what health risks?" What prevention? organized by Présance Paca-Corse in June 2022.

In 2014, the European Commission also mentioned exposure limit values ​​for nanoparticles and values ​​with no specific effect¹⁷See 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 minimize worker exposure to carbon nanotubes¹⁸See Sweden: protection of workers against potentially dangerous carbon nanotubes in the manufacturing sector, OSHA Europe, November 2, 2019.

In December 2022, researcher Araceli Sánchez Jiménez, member of the Spanish Institute for Occupational Safety and Health (INSST) recalled the need to implement OELs for nanomaterials in order to protect the health of workers¹⁹See Controlling exposure to nanomaterials, Dr. Araceli Sánchez (INSST), EUON, December 2022.

Professionals nevertheless point out that the exposure limit values ​​are not necessarily relevant for taking into account immune reactions and carcinogenesis, as very low doses can be as toxic as high doses.

Do not forget the “external” workers…

– On the production site

The exhibition of temporary workers and subcontractors should also be minimized²⁰See in particular: CFDT, Nanotechnologies, the requirement of responsible developmentNovember 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
- Interim: the lost bet of a real medical follow-up, Health & Work No. 073 – January 2011
- Working can seriously harm your health, Subcontracting of risks, endangerment of others, attacks on dignity, physical and moral violence, occupational cancers, Annie Thébaud-Mony, La Découverte, 2008
- Safety at work: subcontractors are forgotten by a minimum reform, CGT Toulouse University Hospital, April 12, 2015.

In the event of an accident or fire, in addition to the workers present, it is also necessary that rescue teams, firefighters²¹See ENSOSP, Nanomaterials: challenges, risks and elements of reflection on the operational response of firefighters 2010, etc. are well informed of the presence of nanomaterials on the site and well protected.

The preceding precautions were defined first to minimize the exposure of workers expressly handling nanomaterials, mainly during the steps of:

• research in laboratories
• production nanomaterials (laboratories, chemical industry workshops, start-ups)
• transformations ou integration of nanomaterials into products (research labs, cosmetics, plastics, paints, coatings, etc.)

But they must also be applied for peripheral activities, which must not be neglected, in particular:

• le cleaning,maintenance and maintenance premises and equipment (including filters)
• la collection, transportation, processing (recycling) and / or theelimination of waste which should be treated as hazardous waste²²See in particular INRS, From production to processing of manufactured nanomaterial wasteMay 2019 (as well as everything that has been in contact with nanomaterials: packaging, filters for ventilation systems, vacuum cleaner bags, respiratory protection equipment, overalls, etc.)

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

The German Institute for Occupational Safety and Health had alerted him in 2007 to the fact that the 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), in the same way as the manipulation zones.

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

– Downstream of the production chain

One of the weak links still too little aware of today: the (many) workers downstream of the production chain, exposed to nanomaterials without knowing it…

• … during their application / installation / use (cements, paints, dyes, cosmetics, nanocoatings for example)
• … during the'machining (cutting, sanding, drilling, polishing, etc.) and/or the reparation products that contain it (automotive, construction, etc.)

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

They are therefore vulnerable and less (in)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 hierarchy

Raising awareness of risks

Although it does not include specific considerations for nanomaterials, the European Framework Directive on Safety and Health at Work of 1989²⁵See Council Directive 89/391/EEC on the introduction of measures to encourage improvements in the safety and health of workers at work, June 12, 1989 – Official Journal No. L 183 of 29/06/1989 p. 0001 – 0008 specifies, however, that it is the responsibility of the employer 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 are to be applied in practice, particularly in the case of nanomaterials, insofar as the risks associated with these substances are still poorly known and potentially significant.

There remains a great deal of awareness and information work to be rolled out (and adapted) to the various actors:

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

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

(Theoretically) useful information materials

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

• Safety Data Sheets (FDS) very rarely contain specific information on the nanoscale nature of the materials manufactured as well as on the risks associated with their use and the recommended means of prevention. Whether since 2021, SDS must provide information specific to nanoforms (physico-chemical characteristics and risks), we are still a long way off²⁶See our sheet on nano information in the MSDS.

• La Information products can sometimes give some information but today only in terms of physico-chemical characteristics.

• Le Single document, a safety management tool, is another important information medium in which the necessary information on the risks associated with the nanomaterials handled in the company should appear.

One of the simple measures to put in place as a first step to remedy this lack of information, would be to oblige the last actors in the supply chain who complete a r-nano statement to communicate to professional users to whom they provide “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 by various means. Even more than for other occupational risks, workers, even informed ones, can in fact tend to minimize nano risks, due to the latter's invisibility, to which is added the pressure to produce results (the famous “publish or perish” of the world of research; or productivity objectives at the industrial level), practices in the field, the weight of habits, considerations of comfort, over-confidence, etc. which are all parameters likely to limit the application of safety rules by even well-informed professionals.

Surveys of nanoscience / nanotechnology researchers (chemists or physicists) show little awareness of the risks associated with nanomaterials - whether in the United States or Canada (unlike toxicologists, ecotoxicologists, biologists, or researchers in social sciences generally more cautious)²⁷See Scientists versus Regulators: Precaution, Novelty & Regulatory Oversight as Predictors of Perceived Risks of Engineered Nanomaterials, Beaudrie CEH et al., PLOS one, September 2014, in Europe²⁸See Great deeds or great risks? Scientists' social representations of nanotechnology, Bertoldo R et al, Journal of Risk Research 2015 but also in France²⁹At the CEA for example:
- "New risks", environmental controversy and participatory democracy: the example of Grenoble's opposition to nanotechnology, Liéval C, Eastern Geographical Review, 53(1-2), 2013
- The development of nanotechnologies in Grenoble: between a deterritorialised risk and an opposition to uncertain targets, what place for taking risks into account at the local level?, 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 to be “under control”. In the latter case, however, risk “control” stops at the laboratory gates! The risks relating to the products that come out of them are not controlled, thereby exposing workers called upon to use or repair them and/or consumers, without the latter being aware of it.
This observation is also valid in Southeast Asia, particularly in countries heavily involved in nanotechnology (Indonesia, Malaysia, the Philippines, Singapore, Thailand and Vietnam), where the issue of risks and safety around nano is not yet considered an important issue by researchers too "enthusiastic" to deal with nano-security³⁰See 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 worker exposure and monitor their health over the long term

Medical monitoring of "nano" workers necessary in the long term...

The need to set up specific monitoring of the health of workers exposed to nanomaterials has been pointed out for many years.³¹See 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 challenges for worker health?, ETUI, May 2013
- Working with nanoparticles: exposure registry and health monitoring, Health Council of the Netherlands, December 2012
- Elements of feasibility 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 PA et al., Journal of Occupational and Environmental Medicine, 53 (6 Suppl.), 42-47, 2010
- Resolution on nanotechnology and nanomaterials, European Trade Union Confederation (CES or ETUC), December 2010
- Medical surveillance of workers exposed to nanomaterials: lessons from the Keystone congress, Malard S. and Radauceanu A., Documents for the occupational physician, 124, 489-49, 2010
- The National Exposure Registry: history and lessons learned, Schultz MG 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 PA et al., Journal of Occupational and Environmental Medicine, 51 (3), 323-335, 2009
- Working group for the implementation of epidemiological monitoring of workers exposed to nanomaterials et "Health risks of nanotechnology" actor's notebook for the national public debate on nanotechnology 2009-2010, IReSP, 2009
- ISO/TR 12885 Nanotechnologies – Health and safety practices in occupational settings relevant to nanotechnologies 2008
- Nanomaterials, Safety at work, Afsset, May 2008
- Nanotechnologies, nanoparticles: what dangers? what risks?, Committee for Prevention and Precaution (CPP), Ministry of Ecology, May 2006.
Insofar as there are fears of harmful effects on the health of workers associated with nanomaterials, and these effects could take many years to appear, the surveillance of workers' health must be carried out on a long-term basis, including when these workers have ceased to be exposed to nanomaterials. As in the case of asbestos, it is feared that pathologies will appear several years – even decades – after the exposure of workers 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 the end of their occupational exposure to nanomaterials .
When the workers are women, it would be appropriate, in addition to all the protective measures mentioned above, to extend this medical surveillance to their offspring, to check the possible repercussions on the state of health of their child(ren). ).

Studies with the first results of medical follow-up are beginning to appear and confirm the concerns of the health services: they were carried out in Taiwan³²See 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 at the end of 2013 revealed correlations between manipulation of nanomaterials and markers of pulmonary and cardiovascular diseases, markers of inflammation and oxidative stress and antioxidant enzymes and in Korea³³See 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 have biases, or do not detail exposure and/or working conditions.

Occupational health services, occupational physicians, etc. do they have the means to ensure such follow-up? In the current state of things, nothing is less certain.

… to be backed up by monitoring their exposure to nanomaterials

Within companies where nanomaterials are handled, a monitoring of worker exposure to nanomaterials should also be carried out alongside the specific medical follow-up mentioned above.
From 2009, the creation of exhibition registers for workers exposed to nanomaterials had been promoted by the American Institute for Occupational Safety and Health (NIOSH)³⁴See NIOSH, Interim guidance for medical screening and hazard surveillance for workers potentially exposed to engineered nanoparticles, Current Intelligence Bulletin, 60, 2009.

Combined with the performance of these medical examinations over the long term, such registers would allow:

• byassess the medium and long-term impact of manufactured nanoparticles on the health of workers (epidemiological studies); this is to fill a gap, because until recently, the links between exposure and diseases could not be duly established today, for lack of data
• de notify the persons concerned of preventive measures or therapeutic progress which were not known at the time the register was established
• byadapt the measures and means of prevention and protection, in order to adjust them more finely to the risks better identified thanks to epidemiological studies.

The show record should contain the name and physico-chemical characteristics of the nanomaterial(s) handled, the type of activity, the dates, the duration and intensity of the 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 by process in order to be able to carry out further epidemiological studies.³⁵See Aída Ponce Del Castillo (ETUI), Nanomaterials in the workplace, what are the challenges for worker health?May 2013.
The exposure register should be kept within the company and accessible to the health authorities, in compliance with industrial and commercial secrecy.
As for the medical file, each worker should be able to have data concerning his personal exposure.

When will there be national registers of exposed workers?

Ideally such registers are even put in place at national scale : the European Trade Union Confederation (ETUC or ETUC) thus demanded in 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 the exposed workers, the circumstances, duration and concentrations of exposure and the protective measures used”³⁶See Resolution on nanotechnology and nanomaterials, European Trade Union Confederation (CES or 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 register and a system of monitoring the health of workers in contact with manufactured nanoparticles³⁷See Health Council of the Netherlands, Working with nanoparticles: exposure registry and health monitoringDecember 2012.

Since 2014 in France, the device EpiNano aims to carry out epidemiological surveillance of workers potentially exposed to nanomaterials The most common. To date, very few companies have unfortunately agreed to participate in the system and the few to have entered into this process do not necessarily go all the way.

Favor a nano 'safe by design' approach?

Very fashionable in recent months and developed for a number of years, the idea of ​​designing nanomaterials and/or nanotechnologies "safe by design" has been widely promoted by manufacturers, to the point of receiving numerous funding, Europeans in particular. 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...

Pursue research efforts

Among the challenges to be met are 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 quickly as possible - whether this involves the development or updating of regulations or measures of information and protection.