Evaluation of National Environmental Health Plans (PNSE): focus on nanos
The High Council for Public Health (HCSP) has published its Overall assessment of National Health-Environment Plans (2004-2019) this Monday, June 20. Dated March 2022, it traces the evolution of public health-environment policies in France over the past fifteen years and issues general and other more specific recommendations. Those concerning the issue of manufactured nanomaterials – on which the HCSP heard AVICENN in May 2021 – are presented below.
Contributions of PNSE to the consideration of nanomaterials
The HCSP concludes that the PNSE 2 and 3 have, in a global way, made it possible to highlight the complex theme of nanomaterials, “poorly perceived by the public and little taken into account at EU level in 2009, at the start of NEHAP 2, in particular in the field of regulation”. However, he considers that “the role of the PNSE in bringing this theme is not clearly identified. (…) the dynamic was initiated on the occasion of the Grenelle de l'environnement and the national debate on nanotechnology which allowed it to be taken into account in the PNSE 2″.
HCSP recommendations concerning nanos
Governance around nanos in France
The HCSP relays calls from civil society (including AVICENN) to “more transversality between ministries to increase efficiency”. It points out situations of duplication between the action carried out at the national level within the framework of r-nano and the actions carried out in the regions (within the framework of the PRSEs) and calls for “creating synergies and complements” between these two levels. The HCSP relays the remarks of AVICENN and associations that "ultimately want more information, awareness and communication, but also sanctions from the public authorities when the breaches are noted" and more transversality of ministries which tend to act individually "in their organ pipe", at the central level as well as at the decentralized level (in the DREETS or in the DREALs): “Each administration carries out its inspection in companies, without sharing information and without coordinating actions. It would be appropriate to set up a “nanos task force” which would centralize information and work and which would also be available at regional level”.
The HSCP confirms that « the r-nano register must be improved because poorly filled by manufacturers and difficult to use because of too restrictive access. Its openness must be wider and, in particular, to researchers working on the relationship between exposure and health effects in epidemiological studies." page (in French).
The HCSP is also in favor of an increase in resources dedicated to r-nano: “ ANSES has a single person to manage the R-Nano register, respond to requests from declarants, support them and produce the annual report, which is notoriously insufficient to steer and lead the action”.
The HCSP also recommends the removal of the difficulties encountered by the EpiNano epidemiology device monitoring of the health of workers exposed to nanomaterials, via “texts, and a decree or a circular” aimed at making the system restrictive (since the voluntary work on which it is based did not make it possible to integrate a sufficient number of companies and workers).
Research on the risks associated with nanomaterials
The HCSP recommends supporting research aimed at better understanding the health impacts of exposure to nanomaterials.
It also asks that the health risks of new technologies be taken into account “balance between risks and their socio-economic utility”.
Lastly, he would like a "safe(r) by design" approach to be preferred, which looks at all the risks and must be carried out before bringing innovations to market.
Noting with AVICENN the weakness of the PNSE 4 concerning the issues of information and awareness on nanomaterials, the HCSP recommends"Improving public information on the presence of nanomaterials in consumer products through clear labeling ("composcore" according to the HCSP opinion of 27/08/2020 or "toxiscore") and strictly enforce regulations ".
It now remains to be seen how these recommendations will be taken into account to optimize the implementation of the PNSE 4.