Nanotechnology Law Report

Women in Europe for a Common Future Issues Position Paper: Nano the Great Unknown

Women in Europe for a Common Future, (WECF) founded in the Netherlands in 1994, " is a network of 100 member organizations and individual members who share a common concern to promote a healthy environment for all, strengthen the role of women and promote a gender and rights based approach in environment and sustainable development policy and implementation." Recently, WECF issued a position paper, "Nano: The Great Unknown". WECF takes the position that "Neither the industry nor public authorities have shown adequate leadership and willingness in addressing" the possible toxic effects of manufactured nanomaterials (MNMs) on humans and the environment.

After briefly surveying European Union (EU) and non-EU regulatory efforts and finding them all lacking, the WECF calls for applying the precautionary principle and the principle of "no data, no market" for all nanomaterials and products containing nanomaterials.

WECF demands that full information about possible risks of nanoparticles as well as access to information on which products contain nanomaterials should be provided to the public, including developing countries) without delay.

The position paper then presents seven additional demands or "actions" by WECF:

1- "WECF demands that manufactured nanomaterials are treated as totally new substances."

2- " WECF demands the application of "no data, no market" - and in the case of REACH, this is to be independent of tonnage. Registration of nanomaterials under the corresponding bulk chemical should by default be prohibited."

3- "Nanosubstances should be subject to a far reaching health assessment (health, environment)."

4- "WECF asks decision-makers specifically to implement the precautionary principle and introduce producers liability immediately; this will render companies already producing or using nanomaterials accountable for possible damage caused by their products."

5- "Immediate compulsory labelling of all products containing nanomaterials."

6- "Citizens must be informed and involved in decision making . . . .WECF demands a wide-ranging citizens dialogue on the risks and benefits of the new technology. The decision making procedures have to become more democratic and need to be adapted to cover dynamic technological revolutions such as nanotechnology."

7- "All products for children and pregnant women must be MNM-free until it is proven that they present no health risks to those specific groups of consumers. WECf considers the sale of products without adequate risk research as absolutely irresponsible."

While the position paper does raise legitimate issues that have been raised by other groups, legislatures and interested parties, such as providing information on product labels indicating if the product does contain nanomaterials, other issues, such as the demand for public debates, are more problematic. It should be recalled that such debates were tried in France in 2010 (and discussed here), debates which ended in chaos.  The potential exists for such public forums to become the territory of demagogues. Other demands, such as "Immediate, compulsory labelling", show that WECF has no understanding of the regulatory process.

While the position paper may hold the spotlight for a short time, it probably won't have much of an impact on the EU's regulatory bodies.

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