The Program on Reproductive Health and the Environment (PRHE) at the University of California, San Francisco (UCSF) is part of the Department of Obstetrics, Gynecology & Reproductive Services located in UCSF’s School of Medicine. PRHE just published its "Recommendations for Addressing Potential Health Risks from Nanomaterials in California” which was commissioned by California's Office of Environmental Health Hazard Assessment (OEHA). The document is designed to provide the State with an overview of nanotechnology materials and their potential exposures and human health risks, and proposes a selection of policy options for addressing potential hazards and risks from nanotechnology. We previously provided our comments on the May 2010 draft of this document here. A year later, many of our same concerns still apply to the final document.
The new document makes a range of recommendations, which are set forth below:
Recommendations to address health risks from nanomaterials for OEHHA that can be achieved under the existing regulatory structure:
1. Develop a definition of nanomaterials that can be used to identify them.
2. Identify and define priority properties for risk characterization and collect information about them for each nanomaterial.
3. Develop characteristics by which to define, describe, and group nanomaterials according to conventional or unique properties.
4. Establish a publicly accessible clearinghouse and inventory of nanomaterial sources and products.
5. Identify and/or develop methods for monitoring nanomaterials in environmental media and through human biomonitoring.
6. Collect information on the fate and transport of nanomaterials, including through monitoring in environmental and biological media.
7. As for other chemicals, focus on identifying and addressing nanomaterials that are persistent, bioaccumulative, and toxic (PBT).
8. Use existing hazard traits from other chemicals and toxicological and environmental-health-related endpoints to assess potential adverse health outcomes from nanomaterial exposure.
9. Evaluate existing risk-assessment guidelines to determine whether they sufficiently cover nanomaterials, adjusting or incorporating nano-specific approaches as needed.
10. Integrate nanomaterials into current efforts to modernize toxicity testing.
11. Develop and maintain relationships with other governments and researchers to share relevant data and information on nanotechnology and nanomaterials’ use, applications, and toxicity.
12. Improve coordination and monitor communication among federal and state agencies, other countries’ governments, businesses, and NGOs.
13. Continue to include opportunities for public input and comment during decision-making processes.
Recommendations to support successful approaches to address potential health risks from nanomaterials that are currently outside the scope of OEHHA.
1. Require disclosure of where and what nanomaterials are manufactured, in what quantities, and for what new or existing products.
2. Require reporting of properties that can identify nanomaterials that are persistent,bioaccumulative, and toxic (PBT). Phase out uses consistent with approaches for other PBTs.
3. Develop a framework for making policy and regulatory decisions that balances the uses and benefits of nanomaterials with their toxicity and exposure potential.
4. Require testing of release and exposure potential for nanomaterials in consumer products for both existing and new products.
5. Increase efforts to protect and educate workers, researchers, and downstream users of nanomaterials
6. Require sufficient toxicological testing—preferably pre-market and also post-market as necessary—to assess risks to manufacturing and other workers and to downstream users, including consumers and susceptible subpopulations such as infants.
7. Implement a labeling system that requires labeling of products that contain nanomaterials.
8. Increase funding and support for targeted, nano-specific research to fill data gaps.
9. Conduct targeted research on the biological fate, transport, and distribution of nanomaterials, including sources, exposure routes, and internal distributions. Integrate this research with information gathered on exposure potential.