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WatchNanos - What information on nanos in the MSDS?

What information on nanos in the MSDS?

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What information on nanos in the safety data sheets (MSDS)?

By AVICENN Team – Last Modified September 2022

SDS: a necessary information medium for better protection of workers

Safety data sheets (SDS) are intended to enable workers to handle substances and mixtures safely by being informed of the possible risks and the precautionary measures to be taken.

These documents are supposed to deliver complete information on the properties and hazards of substances and mixtures throughout the product processing chain.1These sheets were introduced by Directive 91/55, replaced byappendix II de REACH and the classification criteria and labeling rules adapted from the United Nations Globally Harmonized System (GHS) for the classification and labeling of chemicals. See The safety data sheet, Technical checklist, INRS, 2019.

Problem: no – or very little – specific data for nanos in the MSDS

Unfortunately, the MSDS very rarely contain specific information on the nanometric character of the materials as well as on the risks associated with their use and the recommended means of prevention. At most, they provide data on the parent material (at the micro- or macroscopic scale) whose properties and risks are very different.
Thus in the USA, sheets for carbon nanotubes available on the market provide the permissible exposure limits for graphite (also a carbon compound)2See Nanomaterials Safety, G. Miller, F. Plummer, and E. Asmatulu, Department of Environmental Health and Safety, Wichita State University, April 25, 2014...

In Australia, according to a study by the Australian Health and Safety Agency published in 2010, barely 18% of SDSs provided an adequate and sufficient description to be able to assess the occupational risk, and most sheets did not provide a description. and specific data for nanomaterials3See Safe Work Australia, An evaluation of MSDS and labels associated with the use of engineered nanomaterials, June 2010.

Korean researchers also analyzed SDSs for 97 of the nanomaterials tested by the Organization for Economic Co-operation and Development (OECD) and found4See Lee, JH et al., Evaluation of information in nanomaterial safety data sheets and development of international standard for guidance on preparation of nanomaterial safety data sheets, Nanotoxicology, 7(3), p.338, May 2013 :

  • insufficient or absent information regarding, for example, the physico-chemical characteristics, routes of exposure, toxicological profiles and protective measures;
  • the use of data (in particular occupational exposure limit values, OELs) from the same substance but in non-nanometric form, when they are not validated for the nanometric form
  • the use of misleading information, such as a CAS no. (chemical #) for another form of carbon (eg, carbon black or graphite) on a carbon nanotube SDS;
  • the absence of information concerning the risk of dust explosion, in particular aluminum oxide.

Members of the US National Institute for Occupational Safety and Health (NIOSH) came to the same conclusions after analyzing the content of fifty SDSs prepared between 2007 and 2011.5See Eastlake, A et al., A critical evaluation of material safety data sheets (MSDSs) for engineered nanomaterials, Journal of Chemical Health and Safety 19(5), pp.1-8, 2012.

We couldn't find any specific numbers for European SDSs, but it's a safe bet that they're also very low. In 2012, the INRS stated that most of the information provided in the MSDS (in particular toxicological data and preventive measures) did not relate specifically to nanomaterials but concerned the parent materials, i.e. the materials (nature identical chemical and crystalline structure) at the micro or macroscopic scale6See INRS, Nanomaterials – Definitions, toxicological risks, characterization of occupational exposure and preventive measures, ED6050, September 2012.

Finally, when it comes to products containing nanomaterials, it is even more difficult to draw up sheets corresponding to these products because nanomaterials do not necessarily have the same properties or the same dangers as in their free state.

In 2014, AVICENN had been able to identify about forty products sold in agriculture that had been declared to the R-nano register. However, none of the 42 safety data sheets consulted mentioned information on an ingredient of nanometric size, although some were updated after the introduction of European and French regulatory definitions.

Since 2021, information on nanos is mandatory on MSDS in Europe

Since 2021, it has become mandatory to specify in the SDS whether substances or mixtures are in nanometric form. Regulation 2020/878 which amends 7theappendix II du REACH Regulation on the requirements for the preparation of safety data sheets (SDS)8See Regulation n°2020/878 which modifies appendix II of the REACH regulation on the requirements relating to the preparation of safety data sheets, June 18 2020 indeed provides that it is finally mandatory to provide information specific to nanoforms from January 1, 2021 (by December 31, 2022 at the latest):

  • the SDS must mention in each relevant section if it concerns nanoforms and, if so, specify which ones, and link the security information relevant to each of these nanoforms
  • the SDS must indicate the particle characteristics that define the nanoform and, in addition to the solubility in the water, the rate of dissolution in water or other media relevant biological or environmental
  • for nanoforms of a substance to which the n-octanol/water partition coefficient is not applicable, the stability of the dispersion in different media should be indicated
  • for solids, the particle size [median equivalent diameter, method of calculating the diameter (based on number, surface or volume) and the range in which this median value varies] must be indicated; other properties may also be indicated, such as size distribution (e.g. in the form of a fork), shape and aspect ratio, state of aggregation and agglomeration, specific surface area and dusting.

These details had been requested for a long time by many actors

Many institutions have expressed their wish that the MSDS contain specific data for the nano format and that the presence of nanomaterials in the products be reported. Among them are in particular:

Since nanomaterials are chemical agents, the general rules relating to the protection of the health of employees must be applied (prevention of chemical risks according to the labor code) hence the need for appropriate SDSs.

A fairly broad consensus is emerging on the need to:

  • include in the MSDS the physico-chemical characteristics and dangers of nano-objects; to provide specific recommendations in terms of precaution, protection – both with regard to handling, storage and the end of life of the product and to report information that is not (yet) available – in particular toxicological or ecotoxicological data)
  • ensure that the MSDS are regularly updated to incorporate advances in knowledge (and report information that is not (yet) available – in particular toxicological or ecotoxicological data)
  • ensure that workers are informed about the risks to enable employers to adopt practical control measures in the workplace, as well as for workers' representatives to verify these measures16See Position on nanomaterials in REACH and safety data sheets, IndustriAll European Trade Union, European trade union federation, May 2013
  • ensure the transmission of SDS throughout the supply chain in order to "enable the monitoring of the product during its stages of industrial transformation, that is to say on part of its life cycle“. The ultimate objective is to transmit the SDS from the beginning to the end of the “life cycle”. These transformations can lead to the need to produce new MSDS corresponding to the product formed (case of functionalization of nanomaterials). Some hazardous characteristics can be reduced in the final product – for example, in a liquid or a composite, the risk of inhalation is low – although caution should always be taken17At the end of 2013, university researchers showed that carbon nanotubes, although contained in a matrix, can be released into the environment under the effect of sunlight and moderate humidity or abrasion: Development of a conceptual framework for evaluation of nanomaterials release from nanocomposites: environmental and toxicological implications, The Science of the Total Environment, 473-474, 9-19, December 2013. See also our sheet What release of manufactured nanomaterials into the environment?.

SDSs should be accompanied by other worker information measures

Complementary supports must be deployed for substances and mixtures…

As already specified by Afsset (ex-ANSES) in 2008, “the provision of these MSDS cannot, on its own, guarantee sufficient information; the employer must also establish, for each position or work situation, a notice indicating the measures taken to prevent risks, the applicable hygiene rules and, depending on the circumstances, the rules for the use of protective equipment collective and personal protective equipment« 18See Nanomaterials – Safety at work, Afsset, May 2008.

Indeed, the readability of the information provided is often limited. Too often the information is too technical and complex, preventing its proper understanding and use by non-experts. Even in large companies where the staff representative institutions (GO P) play an important role in protecting the health of employees, the SDS are not always well exploited. A fortiori, in small and very small companies, the MSDS are not necessarily read; the health of workers is then less protected19See the remarks of Jean-Paul Domingue, of the CGT Gironde, during the public meeting of November 3, 2009 in Bordeaux under national public debate : “In the company, if there are CHSCTs, they are not entitled to the information, to the consultation that they should have. I have heard of MSDS (Material Safety Data Sheet). There are already SDSs for cleaning products… It is already difficult to obtain them and when we do, it is difficult for the occupational physician to have them, to be able to read and analyze them… When we are in the invisible risk, it is even more difficult than in the visible risk. ». More operational (additional) information is therefore necessary.

… And a fortiori for finished products!

SDSs are not required to be provided for finished objects or products (the "articles" within the meaning of REACH) into which substances and/or mixtures have been incorporated. Although the SDS format can, for a few specific items, be used to communicate safety information down the supply chain, it is not mandatory for most items. Result: no information on the presence of nanos in products used by many workers (paints, cements, etc.)! Hence the imperative need for a register of products containing nanos, publicly available.

Elsewhere on the web

A remark, a question? This sheet produced by AVICENN is intended to be supplemented and updated. Please feel free to contribute.

The next nano appointments

15
Feb.
2023
Unnoticed and ungoverned: How nanomaterials are slipping through the cracks (ECOS, Brussels and online)
Brussels and online
Conference
  • Hybrid event (face-to-face and online)
  • Organizers: Environmental Coalition on Standards (ECOS), Friends of the Earth Germany (FEDERATION)
  • Speakers: representatives of the European Commission, civil society and research  
  • Website : https://ecostandard.org/…
5
June
2023
NanoSafe conference 2023 (CEA, Grenoble)
Grenoble
Conference
  • 8th International Conference on Health Issues for a Responsible Approach to Nanomaterials
  • June 5-9, 2023
  • Organizer: Commissariat for Atomic Energy and Alternative Energies (CEA)
  • Website : www.cea.fr/cea-tech/pns/nanosafe/…  
22
June
2023
How the world deals with Materials on the Nanoscale – Responsible Use and Challenges (OECD-BMUV, Berlin)
Berlin
Conference
  • International conference from June 22 to 23, 2023
  • Organizers: OECD, German Federal Ministry for the Environment, Nature Conservation, Nuclear Safety and Consumer Protection (BMUV)
  • Website : https://www.bmuv.de/…

Sheet initially created in June 2014

Notes & references

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