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Andrew D. Maynard1, Robert J. Aitken, Tilman Butz, Vicki Colvin, Ken Donaldson,
Gnter Oberdrster, Martin A. Philbert, John Ryan, Anthony Seaton, Vicki Stone,
Sally S. Tinkle, Lang Tran, Nigel J. Walker & David B. Warheit
1.
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Abstract
The pursuit of responsible nanotechnologies can be tackled through a
series of grand challenges, argue Andrew D. Maynard and his co-authors.
When the physicist and Nobel laureate Richard Feynman challenged the science
community to think small in his 1959 lecture 'There's Plenty of Room at the
Bottom', he planted the seeds of a new era in science and technology.
Nanotechnology, which is about controlling matter at near-atomic scales to produce
unique or enhanced materials, products and devices, is now maturing rapidly with
more than 300 claimed nanotechnology products already on the market 1. Yet
concerns have been raised that the very properties of nanostructured materials that
make them so attractive could potentially lead to unforeseen health or
environmental hazards2.
The spectre of possible harm whether real or imagined is threatening to slow
the development of nanotechnology unless sound, independent and authoritative
information is developed on what the risks are, and how to avoid them 3. In what
may be unprecedented pre-emptive action in the face of a new technology,
governments, industries and research organizations around the world are beginning
to address how the benefits of emerging nanotechnologies can be realized while
minimizing potential risks4. Yet despite a clear commitment to support risk-focused
research, opportunities to establish collaborative, integrated and targeted research
programmes are being missed5. In September, Sherwood Boehlert, chair of the US
House Science Committee, commented in a hearing that "we're on the right path to
dealing with the problem, but we're sauntering down it when a sense of urgency is
required". And in October, Britain's Royal Society raised concerns that the UK
government had not made enough progress on reducing the uncertainties
surrounding the health and environmental impacts of nanomaterials 6.
The risks
D. RAMSEY
Potential health risks from exposure to engineered nanomaterials must be understood and minimized.
Fears over the possible dangers of some nanotechnologies may be exaggerated, but
they are not necessarily unfounded. Recent studies examining the toxicity of
engineered nanomaterials in cell cultures and animals have shown that size, surface
area, surface chemistry, solubility and possibly shape all play a role in determining
the potential for engineered nanomaterials to cause harm 7. This is not surprising:
we have known for many years that inhaled dusts cause disease, and that their
harmfulness depends on both what they are made of and their physical nature. For
instance, small particles of inhaled quartz lead to lung damage and the potential
development of progressive lung disease, yet the same particles with a thin coating
of clay are less harmful8. Asbestos presents a far more dramatic example: thin,
long fibres of the material can lead to lung disease if inhaled, but grind the fibres
down to shorter particles with the same chemical make-up and the harmfulness is
significantly reduced9.
It is generally accepted that, in principle, some nanomaterials may have the
potential to cause harm to people and the environment. But the way science is
done is often ill-equipped to address novel risks associated with emerging
technologies. Research into understanding and preventing risk often has a low
priority in the competitive worlds of intellectual property, research funding and
technology development. And yet there is much at stake in how potential nanospecific risks are understood and managed. Without strategic and targeted risk
research, people producing and using nanomaterials could develop unanticipated
illness arising from their exposure; public confidence in nanotechnologies could be
reduced through real or perceived dangers; and fears of litigation may make
nanotechnologies less attractive to investors and the insurance industry.
smart sensors that indicate potential harm to human health. An example would be
sensors that simultaneously detect airborne nanoparticles and determine their
potential to generate reactive oxygen species possibly providing early indications
of harm. Such sensors should be available within the next 10 years.
Develop and validate methods to evaluate the toxicity of engineered
nanomaterials, within the next 515 years. There are many aspects to
evaluating nanomaterial toxicity. But there are three that we consider crucial for
stimulating high-quality research and preventing the unnecessary use of hazardous
nanomaterials: validated screening tests, developing viable alternatives to in
vivo tests, and determining the toxicity of fibre-shaped nanoparticles.
The enormous diversity of engineered nanomaterials with different sizes, shapes,
compositions and coatings matches, and possibly exceeds, that of conventional
chemicals. High-throughput protocols that are benchmarked and validated are
urgently needed to screen for potential hazards. The first part of this challenge is to
reach international agreement on a battery of in vitroscreening tests for human and
environmental toxicity within the next 2 years, and to validate these tests within
the next 5 years. Essential to this challenge will be the widespread and global
availability of standard nanoparticle samples to allow comparison and refinement of
methods across government, industry and academic laboratories.
Although testing in vivo will continue to provide the most relevant information on
human (and other organism) hazards, there is an economic and ethical impetus to
minimize the burden of animal testing. Emerging technologies including
nanotechnology are providing new possibilities for simulating and predicting
nanomaterial behaviour in living organisms. We propose that relevant and validated
alternatives to in vivo toxicity testing of engineered nanomaterials be developed
over the next 15 years.
Fibre-shaped nanomaterials possibly represent a unique inhalation hazard, and
their pulmonary toxicity should be evaluated as a matter of urgency. Inhalation of a
sufficient dose of asbestos fibres can lead to the malignant disease mesothelioma,
the causation of which is related to the length, width and chemistry of the fibres, as
well as their ability to persist in the lungs.
Although it is not clear whether fibre-shaped nanoscale particles formed from
carbon and other materials will behave like asbestos or not, some materials are
sufficiently similar to cause concern: any failure to pick up asbestos-like behaviour
as early as possible would be potentially devastating to the health of exposed
people and to the future of the nanotechnology industry. We propose that the
potential health impact of high-aspect-ratio, biopersistent engineered nanotubes,
nanowires and nanofibres is systematically investigated within the next 5 years.
Develop models for predicting the potential impact of engineered
nanomaterials on the environment and human health, within the next 10
years. To assess the safety of complex multicomponent and multifunctional
nanomaterials, scientists will need systems capable of predicting the potential
impact of new nanomaterials, devices and products. Once again our challenge here
has three parts. First, to develop validated models capable of predicting the release,
transport, transformation, accumulation and uptake of engineered nanomaterials in
the environment. In parallel, validated models must be developed that are capable
of predicting the behaviour of engineered nanomaterials in the body, including dose,
transport, clearance, accumulation, transformation and response. These models
should: relate the physical and chemical characteristics of nanomaterials to their
behaviour; allow an integrated approach to predicting potential impact of
engineered nanomaterials and nanoproducts; and estimate impact within
susceptible populations.
Third, to use predictive models for engineering nanomaterials that are safe by
design. This might include engineering the nanomaterials in ways that enhance
desired properties while suppressing hazardous ones, or creating fail-safe
mechanisms that ensure a transition to benign materials upon disposal.
Develop robust systems for evaluating the health and environmental
impact of engineered nanomaterials over their entire life, within the next 5
years. Thinking in terms of life cycles leads to a holistic approach to managing
risks and benefits. Developing robust ways of evaluating the potential impact
good or bad of a nanoproduct from its initial manufacture, through its use, to its
ultimate disposal will stretch both scientific and policy communities, but will lead to
new methodologies that are widely applicable.
Develop strategic programmes that enable relevant risk-focused research,
within the next 12 months. Ultimately, systematic and organized risk research
will empower industry, consumers and policy-makers to make the best decisions
about the development and application of emerging nanotechnologies. As end-users
of the scientific data, these communities must play a central role in shaping what is
done and how. Government research strategies that systematically reduce
uncertainty surrounding the potential impact of nanotechnologies and support
science-based oversight are essential to the safe development of nanotechnology.
But these must be complemented by, and integrated with, industry-led research.
We highlight three areas that we believe are critical to the success of such risk
research: collaboration, communication and coordination.
The first challenge is identifying mechanisms that enable collaborative research
programmes whether interdisciplinary, between government and industry, or
between different stakeholders. Virtual interdisciplinary research centres and
networks are one way of stimulating collaboration, as long as they are accompanied
by adequate resources. We would also encourage joint governmentindustry
partnerships that underpin good product stewardship and oversight, while being
transparent and credible.
References
1. The Nanotechnology Consumer Products Inventory (Woodrow Wilson
International Center for Scholars, Washington DC, 2006). Published online
at http://www.nanotechproject.org/consumerproducts.
2. Nanoscience and Nanotechnologies: Opportunities and Uncertainties (The
Royal Society and The Royal Academy of Engineering, London, 2004).
3. Taking Action on Nanotech Environmental, Health and Safety Risks (Lux
Research, New York, 2006).
4. Report of the OECD Workshop on the Safety of Manufactured Nanomaterials:
Building Co-operation, Co-ordination and Communication(Organization for
Economic Co-operation and Development, Paris, 2006).
5. Maynard, A. D. Nanotechnology: A Research Strategy for Addressing
Risk(Woodrow Wilson International Center for Scholars, Washington
DC,2006).
Abstract
Nano-this and nano-that. These days it seems you need the prefix "nano" for products
or applications if you want to be either very trendy or incredibly scary. This "nanotrend" has assumed "mega" proportions. Vague promises of a better life are met by
equally vague, generalized fears about a worse future. These debates have some
aspects in common: the subject is complex and not easy to explain; there is no
consensus on risks and benefits. - A particular problem with nanotechnology lies in
the huge gap between the public perception of what the hype promises and the
scientific and commercial reality of what the technology actually delivers today and in
the near future. There is nanoscience, which is the study of phenomena and
manipulation of material at the nanoscale, in essence an extension of existing sciences
into the nanoscale. Then there is nanotechnology, which is the design,
characterization, production and application of structures, devices and systems by
controlling shape and size at the nanoscale. Nanotechnology should really be called
nanotechnologies: There is no single field of nanotechnology. The term broadly refers
to such fields as biology, physics or chemistry, any scientific field really, or a
combination thereof, that deals with the deliberate and controlled manufacturing of
nanostructures. In addressing the health and environmental impact of nanotechnology
we need to differentiate two types of nanostructures: (1) Nanocomposites,
nanostructured surfaces and nanocomponents (electronic, optical, sensors etc.), where
nanoscale particles are incorporated into a substance, material or device ("fixed"
nanoparticles); and (2) "free" nanoparticles, where at some stage in production or use
individual nanoparticles of a substance are present. There are four entry routes for
nanoparticles into the body: they can be inhaled, swallowed, absorbed through skin or
be deliberately injected during medical procedures. Once within the body they are
highly mobile and in some instances can even cross the blood-brain barrier. How these
nanoparticles behave inside the organism is one of the big issues that need to be
resolved. Not enough data exists to know for sure if nanoparticles could have
undesirable effects on the environment. Two areas are relevant here: (1) In a free form
nanoparticles can be released in the air or water during production (or production
accidents) or as waste byproduct of production, and ultimately accumulate in the soil,
water or plant life. (2) In a fixed form, where they are part of a manufactured
substance or product, they will ultimately have to be recycled or disposed of as waste.
To properly assess the health hazards of engineered nanoparticles the whole life cycle
of these particles needs to be evaluated, including their fabrication, storage and
distribution, application and potential abuse, and disposal. The impact on humans or
the environment may vary at different stages of the life cycle. Regulatory bodies in the
U.S. as well as in the EU have concluded that nanoparticles form the potential for an
entirely new risk and that it is necessary to carry out an extensive analysis of the risk.
It is imperative that national and international regulatory bodies cooperate closely not
only with each other, but also with academia and industry; based on that,
nanomaterials and nanotechnology can be developed responsibly. With that in place
we can look forward to optimizing the benefits of nanotechnology while minimizing
and controlling the risks.
Abstract:
The field of nanotechnology has recently emerged as the most commercially
viable technology of this century because of its wide-ranging applications in our
daily lives. Man-made nanostructured materials such as fullerenes, nanoparticles,
nanopowders, nanotubes, nanowires, nanorods, nano-fibers, quantum dots,
dendrimers, nanoclusters, nanocrystals, and nanocomposites are globally produced
in large quantities due to their wide potential applications, e.g., in skincare and
consumer products, healthcare, electronics, photonics, biotechnology, engineering
products, pharmaceuticals, drug delivery, and agriculture. Human exposure to these
nanostructured materials is inevitable, as they can enter the body through the lungs
or other organs via food, drink, and medicine and affect different organs and tissues
such as the brain, liver, kidney, heart, colon, spleen, bone, blood, etc., and may
cause cytotoxic effects, e.g., deformation and inhibition of cell growth leading to
various diseases in humans and animals. Since a very wide variety of
nanostructured materials exits, their interactions with biological systems and
toxicity largely depend upon their properties, such as size, concentration, solubility,
Regulating Nanomedicine
NEW NANO TOOLS OFFER GREAT PROMISE FOR
THE FUTURE - IF REGULATORS CAN SOLVE THE
DIFFICULTIES THAT HOLD DEVELOPMENT BACK
Shannon Fischer
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In 1979, a Hebrew University biochemist named Yechezkel Barenholz teamed with Alberto Gabizon, a newly minted Ph.D.
from the Weizmann Institute of Science, to find a better way to give
chemotherapeutic doxorubicin to patients with cancer.
Sixteen years later, the result of that collaborationDoxilwon
approval from the U.S. Food and Drug Administration (FDA). It
was a reformulation of doxorubicin into tiny, drug-loaded membrane
spheresliposomesfewer than 100-nm across. They were so
small they could course through the bloodstream until they leaked
right through the particularly porous vasculature that marked a
cancer site. And though the particles didnt necessarily fight the
cancer better, they did fight it with fewer side effects. As it happens,
they were also the first formal nanodrug in history.
Since its arrival to market, Doxil has made more than US$600
million in annual sales battling Kaposis sarcoma, multiple
myeloma, and ovarian and breast cancer. It has been joined by
dozens of nano bedfellows, most of them also anticancer drugs,
many also liposomes, although there are also dextran-coated iron
CAUTION IS ADVISED
But regulators are first to acknowledge their failings, and many are
at work to address these shortcomings. The FDA has invested
heavily in new in-house nanotechnology regulatory science
programs, aimed at ramping up new methods to profile and test
nanomaterials in vitro and vivo. The National Cancer Institutes
Nanotechnology Characterization Laboratory (NCL) has examined
nanomaterials and their complexities since 2004. Every year, it
accepts a dozen or so potential nanotherapeutics developed from
labs nationwide and runs a battery of tests that serve to both assess
those drugs and add to its growing body of assay protocols and
troublesome manufacturing pitfalls such as sterility and batch-tobatch variabilityall of which it shares with the science community
and FDA. In the past ten years, it has characterized nearly 300
different nanomaterials and sent six on to clinical trials. Meanwhile,
the information and standards that it has gathered have begun to
unofficially reshape not only the FDAs own review practices but
strategies internationally.
As the field is developing very quickly, a benefit is that people are
looking to establish protocols and normssimilar to best practices
and the NCL has helped to establish that, Mumper says. His lab,
he explains, has submitted investigational new drug applications to
the FDA for nanomaterials and was referred to protocols established
by the NCL. The position the FDA takes, he says, is: These are
the accepted best practices in terms of standard operations, and this
is generally what the community has adopted. You may not have to
do all the protocols, but you have to justify why youre not doing
them.
Internationally, the European Commission is collaborating with the
NCL to develop a European nanotechnology characterization lab
network of its own, which it hopes to launch this year in existing
labs. Recently, the European Medicines Agency (EMA)partially
FUTURE TENSE
Laying this foundation will be essential to the future. Across the
world, hundreds of nanomedicines and devices are wending their
way through the clinical testing pipeline. If the pace continues as is,
market forecasters predict that the global nanomedicine market will
hit US$130.9 billion by 2016.
Many of these compounds will still be relatively known quantities
liposomes, nanocrystalsbut as time goes on, more novel creations
will emerge and begin to blur the lines between physical devices and
chemical drugs, and that may be a problem. The FDA has an Office
of Combination Products to determine whether multifunction
products should be assessed as the drug, biologic, or device,
depending on its primary mode of action. Multipurpose
theranostic agents that can diagnose, treat, and track diseases may
not always be easily categorized and some researchers worry that
that could lead to inconsistent evaluations. Critics such as Bawa are
concerned that this process is too impreciseparticularly because,
he says, at the time of an investigational application, its not always
clear which mode of action provides the most important therapeutic
action and some products can even have two different, equally
critical modes of action.
Furthermore, not all regulatory bodies have defined combination
product offices, eitherthe EU assesses medical products and
devices separately and differently. Currently, advanced and
biotechnological drugs like nanomedicines are evaluated under the
centralized body of the EMA, but devices are regulated under the
various authorities of the individual member states. If a medicine
with a device component arrives for review at the EMA, the EMA
evaluates it in consultation with medical device authorities, and vice
versa.
With respect to the evaluation of the device component,
Logistically, its more difficult, says Falk Ehmann, the Innovation
Task Force coordinator in the EMAs Specialised Scientific
Disciplines Department. A worst-case scenario where one state rules
one way and its neighbor rules differently can happen, he says.
There are robust procedures in place to prevent that occurrence, and
collaboration is the norm, but still the potential is there, he says.
And with the theranostics, its getting more and more
complicated.
On the other hand, it means a brave new world where the definition
of privacy is concerned.
These are more difficult issues that regulations cannot handle on
their own. Discussions among researchers and ethicists are
underway, but the critical group that needs to participate will be the
public, and that has yet to happen at a broad level. But the greatest
fear, as far as Ferrari can see, is that regulatory fears and ethical
quandaries be allowed to grow so large that nanomedicines future is
stifled. Its easy to build scary scenarios, he says. But I live in a
world where every patient who comes to me is facing death.
Nanomedicines abilities, in the end, will be key to saving lives like
theirs from cancer and other diseases, and not to take advantage of it
would be the greatest risk of all.
application.
This article does not attempt to cover the whole field, but offers, by means of some
examples, a few insights into how nanotechnology has the potential to change
medicine, both in the research lab and clinically, while touching on some of the
challenges and concerns that it raises.
What is Nanotechnology?
The prefix "nano" stems from the ancient Greek for "dwarf". In science it means one
billionth (10 to the minus 9) of something, thus a nanometer (nm) is is one billionth of
a meter, or 0.000000001 meters. A nanometer is about three to five atoms wide, or
some 40,000 times smaller than the thickness of human hair. A virus is typically 100
nm in size.
The ability to manipulate structures and properties at the nanoscale in medicine is
like having a sub-microscopic lab bench on which you can handle cell components,
viruses or pieces of DNA, using a range of tiny tools, robots and tubes.
Manipulating DNA
Therapies that involve the manipulation of individual genes, or the molecular
pathways that influence their expression, are increasingly being investigated as an
option for treating diseases. One highly sought goal in this field is the ability to tailor
treatments according to the genetic make-up of individual patients.
This creates a need for tools that help scientists experiment and develop such
treatments.
Imagine, for example, being able to stretch out a section of DNA like a strand of
spaghetti, so you can examine or operate on it, or building nanorobots that can
"walk" and carry out repairs inside cell components. Nanotechnology is bringing that
scientific dream closer to reality.
For instance, scientists at the Australian National University have managed to attach
coated latex beads to the ends of modified DNA, and then using an "optical trap"
comprising a focused beam of light to hold the beads in place, they have stretched
out the DNA strand in order to study the interactions of specific binding proteins.
delivery of such drugs is that the body breaks most of them down before they reach
their destination.
But what if it were possible to produce such drugs in situ, right at the target site?
Well, in a recent issue of Nano Letters, researchers at Massachusetts Institute of
Technology (MIT) in the US show how it may be possible to do just that. In their
proof of principle study, they demonstrate the feasibility of self-assembling
"nanofactories" that make protein compounds, on demand, at target sites. So far
they have tested the idea in mice, by creating nanoparticles programmed to produce
either green fluorescent protein (GFP) or luciferase exposed to UV light.
The MIT team came up with the idea while trying to find a way to attack metastatic
tumors, those that grow from cancer cells that have migrated from the original site to
other parts of the body. Over 90% of cancer deaths are due to metastatic cancer.
They are now working on nanoparticles that can synthesize potential cancer drugs,
and also on other ways to switch them on.
Nanofibers
Nanofibers are fibers with diameters of less than 1,000 nm. Medical applications
include special materials for wound dressings and surgical textiles, materials used in
implants, tissue engineering and artificial organ components.
Nanofibers made of carbon also hold promise for medical imaging and precise
scientific measurement tools. But there are huge challenges to overcome, one of the
main ones being how to make them consistently of the correct size. Historically, this
has been costly and time-consuming.
But last year, researchers from North Carolina State University, revealed how they
had developed a new method for making carbon nanofibers of specific sizes. Writing
in ACS Applied Materials & Interfaces in March 2011, they describe how they
managed to grow carbon nanofibers uniform in diameter, by using nickel
nanoparticles coated with a shell made of ligands, small organic molecules with
functional parts that bond directly to metals.
Nickel nanoparticles are particularly interesting because at high temperatures they
help grow carbon nanofibers. The researchers also found there was another benefit
in using these nanoparticles, they could define where the nanofibers grew and by
correct placement of the nanoparticles they could grow the nanofibers in a desired
specific pattern: an important feature for useful nanoscale materials.
Lead is another substance that is finding use as a nanofiber, so much so that
neurosurgeon-to-be Matthew MacEwan, who is studying at Washington University
School of Medicine in St. Louis, started his own nanomedicine company aimed at
revolutionizing the surgical mesh that is used in operating theatres worldwide.
The lead product is a synthetic polymer comprising individual strands of nanofibers,
and was developed to repair brain and spinal cord injuries, but MacEwan thinks it
could also be used to mend hernias, fistulas and other injuries.
Currently, the surgical meshes used to repair the protective membrane that covers
the brain and spinal cord are made of thick and stiff material, which is difficult to
work with. The lead nanofiber mesh is thinner, more flexible and more likely to
integrate with the body's own tissues, says MacEwan. Every thread of the nanofiber
mesh is thousands of times smaller than the diameter of a single cell. The idea is to
use the nanofiber material not only to make operations easier for surgeons to carry
out, but also so there are fewer post-op complications for patients, because it breaks
down naturally over time.
Researchers at the Polytechnic Institute of New York University (NYU-Poly) have
recently demonstrated a new way to make nanofibers out of proteins. Writing
recently in the journalAdvanced Functional Materials, the researchers say they came
across their finding almost by chance: they were studying certain cylinder-shaped
proteins derived from cartilage, when they noticed that in high concentrations, some
of the proteins spontaneously came together and self-assembled into nanofibers.
They carried out further experiments, such as adding metal-recognizing amino acids
and different metals, and found they could control fiber formation, alter its shape,
and how it bound to small molecules. For instance, adding nickel transformed the
fibers into clumped mats, which could be used to trigger the release of an attached
drug molecule.
The researchers hope this new method will greatly improve the delivery of drugs to
treat cancer, heart disorders and Alzheimer's disease. They can also see
applications in regeneration of human tissue, bone and cartilage, and even as a way
to develop tinier and more powerful microprocessors for use in computers and
consumer electronics.
A schematic illustration showing how nanoparticles or other cancer drugs might be used to treat cancer.
This illustration was made for theOpensource Handbook of Nanoscience and Nanotechnology
byproducts of human activity, they have been present since the Stone Age, in smoke
and soot.
Of attempts to investigate the safety of nanomaterials, the National Cancer Institute
in the US says there are so many nanoparticles naturally present in the environment
that they are "often at order-of-magnitude higher levels than the engineered particles
being evaluated". In many respects, they point out, "most engineered nanoparticles
are far less toxic than household cleaning products, insecticides used on family pets,
and over-the-counter dandruff remedies," and that for instance, in their use as
carriers of chemotherapeutics in cancer treatment, they are much less toxic than the
drugs they carry.
It is perhaps more in the food sector that we have seen some of the greatest
expansion of nanomaterials on a commercial level. Although the number of foods
that contain nanomaterials is still small, it appears set to change over the next few
years as the technology develops. Nanomaterials are already used to lower levels of
fat and sugar without altering taste, or to improve packaging to keep food fresher for
longer, or to tell consumers if the food is spoiled. They are also being used to
increase the bioavailablity of nutrients (for instance in food supplements).
But, there are also concerned parties, who highlight that while the pace of research
quickens, and the market for nanomaterials expands, it appears not enough is being
done to discover their toxicological consequences.
This was the view of a science and technology committee of the House of Lords of
the British Parliament, who in a recent report on nanotechnology and food, raise
several concerns about nanomaterials and human health, particularly the risk posed
by ingested nanomaterials.
For instance, one area that concerns the committee is the size and exceptional
It would appear, therefore, whether actual or perceived, the potential risk that
nanotechnology poses to human health must be investigated, and be seen to be
investigated. Most nanomaterials, as the NCI suggests, will likely prove to be
harmless.
But when a technology advances rapidly, knowledge and communication about its
safety needs to keep pace in order for it to benefit, especially if it is also to secure
public confidence. We only have to look at what happened, and to some extent is
still happening, with genetically modified food to see how that can go badly wrong.
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Nanotechnology In Medicine: Huge Potential, But What Are The Risks?
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Nanotechnology Risks
Ready or not, here it comes. In the next 20 years, nanotechnology will touch the life of
nearly every person on the planet. The potential benefits are mind boggling and brain
enhancing. But like many of the great advancements in earth's history, it is not without risk
Here are some of the risks posed to society by nanotechnology.
NANOTOXICOLOGY
Introduction
Possible dangers of Nanotechnology
Australian News - Carbon nanotubes
The importance of prevention
Government Initiatives - Australia
In Europe
More information
Introduction
recent media reports of research into the use of nanoparticles to treat dental
cavities. The Project on Emerging Technologies (based at the Woodrow
Wilson International Center for Scholars) keeps a list of commercially
available products containing nano materials. Recently updated (October
2013), the Nanotechnology Consumer Products Inventory now contains 1,628
consumer products that have been introduced to the market since 2005,
representing a 24 percent increase since the last update in 2010. The list is
updated regularly, and can be browsed, or searched by product or country.
Other forms of nanotechnology being developed include tiny sensors called
nano-units, of which some simple types are readily available; 'smart materials'
that change in response to light or heat; 'nano-bots' - tiny mobile robots that
have yet to be developed but are theoretically possible; and self-assembling
nano-materials that can be assembled into larger equipment. These are being
actively developed. Australia's own CSIRO, for example, has developed a
building material that with nanotechnology, is able to repair itself multiple
times.
Nanotechnology is already a huge industry with billions of dollars being spent
on research and development worldwide. There is still a great deal to learn
about both the potential benefits and risks of the technology.
Nevertheless, most experts agree that the use of nanotechnology in
electronics, the pharmaceutical industry and in areas such as medical imaging
is outstripping our understanding of the OHS risks.
Nanotechnology could lead to significant developments in medicine,
manufacturing and computing. However it may also bring significant new
health hazards.
Back to top
Although most of the press coverage has been on the dangers of 'nano-goo'
such as self-replicating particles that get out of control, or 'nano-robots', the
real risks are much more simple, and real. The miniature size of
nanomaterials and the way their surfaces are modified to increase the ease
with which they can interact with biological systems - the very characteristics
that make them attractive for applications in medicine and industry - makes
nanomaterials potentially damaging for humans and the environment.
Nanoparticles are likely to be dangerous for three main reasons:
1. Nanoparticles may damage the lungs. We know that 'ultra fine' particles
from diesel machines, power plants and incinerators can cause
considerable damage to human lungs. This is both because of their size
(as they can get deep into the lungs) and also because they carry other
chemicals including metals and hydrocarbons in with them.
2. Nanoparticles can get into the body through the skin, lungs and
digestive system. This may help create 'free radicals' which can cause
cell damage and damage to the DNA. There is also concern that once
nanoparticles are in the bloodstream they will be able to cross the
blood-brain barrier.
3. The human body has developed a tolerance to most naturally occurring
elements and molecules that it has contact with. It has no natural
immunity to new substances and is more likely to find them toxic.
The danger of contact with nanoparticles is not just speculation. As more
research is undertaken, concerns increase. Here are some of the recent
findings:
particles can penetrate deep into the lungs and may move to other parts of the
body, including the liver and brain.
NIOSH's Nanotechnology Research Centre (NTRC), has also released an
interim report Progress Towards Safe Nanotechnology in the Workplace[pdf]
(Feb 2007). The NTRC was established to coordinate and facilitate research
in nanotechnology and develop guidance on the safe handling of
nanomaterials in the workplace. The report identifies 10 critical OHS areas
and reports on the advancements to date. The areas include toxicity and
internal dose -determined heart and lung responses to nanoparticles; risk
assessment; epidemiology and surveillance - developing guidance for
nanotechnology employers and workers on how to implement OHS
surveillance programs in the workplace; engineering controls and PPE; and
measurement methods.
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As hazardous as asbestos?
Safe Work Australia has done quite a bit of work on carbon nanotubes.
In June 2011: a research report, Durability of carbon nanotubes and their
potential to cause inflammation. The report considered the durability of carbon
nanotubes and the tendency to cause lung inflammation if inhaled, two
indicators of potential asbestos-like behaviour. Carbon nano-tubes are
already being used in a number of different applications.
Key findings in the report include:
Some types of carbon nanotubes can be durable, but others may also
break down in simulated lung fluid.
Carbon nanotubes of certain length and aspect ratio can induce
asbestos-like responses in mice, confirming previous findings. However,
this response may be reduced if the nanotubes are less durable.
tightly agglomerated particle-like bundles of carbon nanotubes did not
cause an inflammatory response in mice.
In October 2012, a further report: Human Health Hazard Assessment and
Classification of Carbon Nanotubes which it commissioned NICNAS to do. In
addition, an information sheet Classification of Carbon Nanotubes as
Hazardous Chemicals has also been published.
At the moment no one knows for certain how dangerous the many different
types of nanoparticles are likely to be to humans. However it is important that
we do not allow workers to be exposed to an unknown danger where effects
may not be known for years, even decades.
These risks were highlighted in a report from the UK's Royal Society which
said 'nanotechnology offers many potential benefits, but its development must
be guided by appropriate safety assessments and regulation to minimise any
possible risks to people and the environment.' It also called for a tightening up
of regulations.
should not be allowed on the market unless sufficient data are supplied to
show no harmful effect for human health and the environment.' It adds that
risk reduction measures must be used and employers must involve workers
and their representatives in the assessment and reduction of nanomaterialrelated risks. Other measures called for by ETUC include training and health
surveillance for workers exposed to nanomaterials, at least 15 per cent of
public research budgets on nanotech to be dedicated to health and
environmental aspects and for workplace health and safety to be included in
all research programmes.Statement and Resolution.
The ACTU Occupational Health and Safety, Rehabilitation and Compensation
Policy (2012) now has a specific section on Nanotechnology. Download the
Policy here.
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Government initiatives
research and public concerns about potential health and environment risks.
There is little in the materials about ethical, cultural or privacy issues.'
Below are the documents, now on the Department of Industry website:
occurring naturally.
While natural nanoparticles are randomly structured and diffusely distributed in the
environment, industrially produced suspensions or powders contain pure
nanomaterials of very uniform size, shape and structure. Such nanomaterials have
unique properties such as the high tensile strength of CNTs or the photocatalytic
activity of nano-TiO2, which make them interesting for novel products and
applications. Precisely these special features make it so difficult to predict the fate
and behavior of ENPs in the environment1.
In the environment, nanomaterials can undergo a range of chemical processes (see
info box) that depend on many factors (e.g. pH value, salinity, concentration
differences, the presence of organic or inorganic material).
The characteristics and properties of a nanomaterial also play a major role.
Bioavailability is decisive in determining potential toxicity. This depends strongly on
whether nanoparticles remain stable in an environmental medium or are removed
from the respective medium through agglomeration and deposition, or are
transformed into a form that organisms cannot take up.
The current lack of data prevents a comprehensive picture of the fate and behavior
of nanomaterials in the environment. Moreover, the available studies are poorly
comparable because different nanomaterials with different properties (for example
surface functionalization see below) are used, and because both the methodology
and the duration of the studies also often differ considerably.
The research results on the potential impacts of ENPs on the environment and
human health were recently compiled in the framework of an EU project 7.
The following account briefly summarizes our current state of knowledge on the fate
and behavior of ENPs in the environmental compartments air, water, soil and
sediment based on that report.
Air
When nanoparticles enter the atmosphere, they move from zones of higher
concentration to zones of lower concentration (diffusion). Air currents distribute the
particles rapidly; these can migrate great distances from their original source.
Nonetheless, nanoparticles tend to aggregate into larger structures
(agglomeration). Detecting nanoparticles in the air is very difficult because simple
measurements of size distributions can hardly distinguish such agglomerates from
natural particulates. The speed with which particles in the air are deposited on the
ground, in the water or onto plants (deposition) depends on particle diameter.
Nanoparticles from the air are deposited much slower than larger particles due to
their smaller diameters.
Water
The general rule is that nanoparticles distributed in the water behave much like
colloids, which are well described in the chemical literature. Colloids are droplets or
particles that are finely distributed in a medium; they are relatively unstable
because they rapidly adhere to one another due to electrostatic attractive forces
and then sink as a result of gravity. Natural water bodies typically contain dissolved
or distributed materials, including natural nanomaterials. As expected, synthetic
nanomaterials that enter a natural water body bind themselves to such natural
materials. The fate and behavior of nanomaterials in the water, however, are also
influenced by factors such as pH, salinity (ionic strength) and the presence of
organic material.
Naturally present organic material (NOM) can lead to the decomposition of
C60 fullerenes or of their aggregates and thus alter particle size and shape. A NOM
such as humic acid can stabilize certain carbon nanotubes (MWCNT) in the water
and thus prevent their settlement. Some CNTs are also deliberately produced
through special surface changes so that they do not aggregate. The type of such
functionalization helps determine whether CNTs can be removed from a natural
water body through sedimentation.
As CNTs are very polymorphic, it is usually impossible to provide generally valid
statements about their fate and behavior in the environment. A strong influence of
the surrounding environment on behavior, in particular the presence of NOM, has
also been determined for other nanomaterials such as metals or metal oxides 10.
Soil and sediment
Unfortunately, the data for this environmental compartment are insufficient to draw
general conclusions. Considerably fewer studies are available for this sector than for
water or air. There is, however, comprehensive literature on the mobility of natural
colloids in the soil and groundwater, which helps draw conclusions about
nanomaterial behavior.
Accordingly, nanomaterials in the soil and in sediments are assumed to bind
themselves to solids. The generally very low concentrations of particles in the
groundwater support this notion. The bioavailability and therefore the potential
toxicity of a nanomaterial for soil organisms apparently depend strongly on
whether it binds to NOM. The bioavailability of nanosilver in complex media such as
soil is considerably lower than in water because the reactive silver ions can bind to
components in the soil (e.g. NOM)11.
The co-transport of pollutants in the soil with ENPs has only been poorly studied, but
is probably not relevant for most pollutants and ENPs due to the extremely low ENP
concentrations in soils12.
Potential environmental processes that can influence the behavior and the
properties of nanomaterials (after 7)
freshwater organisms (e.g. water fleas, fishes). More studies on marine and
terrestrial invertebrates are also necessary to determine potential toxicities, as are
further studies on amphibians, reptiles, birds or plants, bacteria and in particular
microorganisms. To date, no ecotoxicological studies are available that could explain
in detail the mechanisms of uptake, distribution, metabolization and excretion of
nanoparticles13.
In an overview of the relevant scientific literature compiled in 2010, only 12 studies
were identified that can actually be classified as ecological studies (i.e. that more or
less consider the complexity of natural ecosystem). These few studies on the effects
of ENPs on ecological communities failed to detect significant increases in mortality
rates or changes in their compositions1.
The following paragraphs briefly summarize the results of ecotoxicological studies
on selected nanomaterials (for a comprehensive review see 7).
Carbon nanotubes (CNTs)
The ecotoxicity of CNTs has been treated in only a few studies, and in some cases
the results are highly contradictory. While some studies were unable to determine
any negative effects on test organisms, others clearly did, for example in the case
of fishes and amphibian larvae. The reason for this is the great variability of CNTs:
they differ considerably in length, structure, surface charge, surface chemistry,
agglomeration behavior and purity (see also14; 15). Moreover, investigating the
toxicity of CNTs for aquatic organisms is very difficult because CNTs are very poorly
soluble in water, have different sizes and diameters, and form complex
aggregates5.
CNTs are often surface functionalized so that their fine distribution in water remains
very stable and they do not sediment to the bottom. Such surface changes,
however, promote the tendency of CNTs to accumulate heavy metals, which can
influence their transport in water bodies or even in biological systems 16.
Nano-TiO2
Titanium dioxide nanoparticles are among the most frequently investigated
nanomaterials. A range of standardized tests are already available for fishes,
crustaceans and algae. Nano-TiO2 has a photocatalytic effect, i.e. under UV
radiation, reactive oxygen species (ROS) develop that can damage the cell
membrane of microorganisms.
Studies have been conducted to simulate the conditions in natural running waters
at the laboratory scale (so-called aquatic microcosms). They show that
TiO2 nanoparticles and low concentrations of larger, naturally developed
agglomerates can both significantly damage the cell membranes of
microorganisms.
Microorganisms are very sensitive to nano-TiO2 the precise effect on ecosystem
7 Aitken, Robert J., et al., 2008, Engineered Nanoparticles: Review of Health and
Environmental Safety (ENRHES) (pdf). Final Report.
8 Kaegi, R., et al., 2008, Synthetic TiO 2 nanoparticle emission from exterior facades
into the aquatic environment, Environmental Pollution 2008(156), 233-239.
9 Westerhoff, Paul, et al., 2011, Occurrence and removal of titanium at full scale
wastewater treatment plants: implications for TiO 2 nanomaterials, Journal of
Environmental Monitoring 13(5), 1195-1203.
10 Ottofuelling, Stephanie, et al., 2011, Commercial Titanium Dioxide Nanoparticles
in Both Natural and Synthetic Water: Comprehensive Multidimensional Testing and
Prediction of Aggregation Behavior,Environmental Science & Technology 45 (23), pp
10045-10052.
11 Lapied, Emmanuel, et al., 2010, Silver nanoparticles exposure causes apoptotic
response in the earthworm Lumbricus terrestris (Oligochaeta), Nanomedicine 5(6),
975-984.
12 Hofmann, Thilo/Von der Kammer, Frank, 2009, Estimating the relevance of
engineered carbonaceous nanoparticle facilitated transport of hydrophobic
contaminants in porous media, Environmental Pollution157, 1117-1126.
13 Handy, Richard D., et al., 2008, The ecotoxicology of nanoparticles and
nanomaterials: current status, knowledge gaps, challenges, and future
needs, Ecotoxicology 17, 315-325.
14 NanoTrust-Dossier 022en (pdf).
15 NanoTrust-Dossier 024en (pdf).
16 Schierz, A./Znker, H., 2009, Aqueous suspensions of carbon nanotubes: Surface
oxidation, colloidal stability and uranium sorption, Environmental Pollution 157,
1088-1094
17 Battin, Tom J., et al., 2009, Nanostructured TiO 2: Transport Behavior and Effects
on Aquatic Microbial Communities under Environmental Conditions, Environmental
Science & Technology 43(21), 8098-8104
18 Dabrunz, Andr, et al., 2011, Biological Surface Coating and Molting Inhibition as
Mechanisms of TiO2 Nanoparticle Toxicity in Daphnia magna, PLoS ONE 6(5), 1-7.
19 NanoTrust-Dossier 010en (pdf).
20 Yin, Liyan, et al., 2011, More than the Ions: The Effects of Silver Nanoparticles on
Lolium multiflorum, Environmental Science & Technology 45, 2360-2367.
21 NanoTrust-Dossier 015en (pdf).
22 Sutherland, William J., et al., 2009, A horizon scan of global conservation issues
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Read more: Nanotechnology and the environment - Hazard potentials and risks
Inhalation
For inhaled engineered nanomaterials, the target site most likely to be affected is the lungs.
There is evidence that inhaled nanomaterials have the potential to initiate inflammatory
responses. However, the factors that determine the severity of the response are not fully
understood. Also the longer term health consequences for repeated exposure are in many
cases unknown. Epidemiological studies looking at the health effects of exposure to ambient air
pollution have suggested that in addition to effects in the lungs, people inhaling air that contains
high levels of particles with sizes in the ultrafine range (this includes particles that fall within the
Commission definition of a nanoparticle) are more likely to suffer from diseases of the
cardiovascular system. However, the relevance of this finding to workers exposed to
nanomaterials at work is unclear.
Dermal
In addition to inhalation, there is the potential for nanomaterials to contact the skin and
gastrointestinal tract as a result of workplace exposure. With the exception of nanomaterials that
are used in cosmetic products there have been few investigations into the effects of
nanomaterials on the skin. Any effects that do arise as a result of skin contact are expected to
be site of contact effects. Research looking at the skin absorption potential for nanomaterials
has suggested that if there is any absorption across the skin the amounts that are absorbed will
be low.
Injection
There is no information that will enable general conclusions to be drawn about the fate of
nanomaterials that enter the gastrointestinal tract as a result of workplace exposure.
Characterise nanomaterials
It is important to understand the physical characteristics and the chemical composition of a
nanomaterial before you begin to work with it since this information will be a key element of your
risk assessment. If you have good information on the physical and chemical characteristics of
the nanomaterials that you are using, this will help you to determine how similar or different it is
to other nanomaterials.
When trying to assess the hazards of nanomaterials, it may be tempting to refer to information
that is available for apparently similar materials. All comparisons of biological/toxicological data
between nanomaterials need to be supported by a detailed physical characterisation of both
materials demonstrating the similarities and differences between the materials. In the absence
of an adequate assessment of the physical characteristics, general conclusions drawn on
nanoparticles which may have similar chemical compositions but, in fact, have different sizes,
shapes, crystal structures, surface coatings, and surface reactivity characteristics may be
misleading. In general, we do not recommend that you rely on hazard information for similar
nanomaterials in your risk assessment unless you have good data to confirm that this approach
is appropriate.
Characterisation information for engineered nanomaterials should be available from
manufacturers or suppliers along with a safety data sheet. If this information is not available you
could ask the manufacturers or suppliers to provide this information.
Size
There is no clear evidence for a step change in hazardous properties relating to the specific
dimensions of a particle. However, it has been reported that particles with dimensions below 20
- 30 nm are less thermodynamically stable and undergo dramatic changes in their crystalline
structure compared to larger particles with the same chemical composition . These changes will
influence the way these very small particles interact with their environment and biological media.
Consequently it is harder to predict their toxicological behaviour based on information obtained
for larger sized particles, including those at the nano scale, even where the chemical
composition is the same.
The size cut-off of 100 nm that has been used within the Commission definition has been
chosen because many of the specified effects of nanomaterials occur with particles with
dimensions in the range 1 100 nm. Also this ensures consistency with definitions that are used
elsewhere. It should not be assumed that a particle that has no dimensions below 100 nm is
free from hazard and it should not be assumed that a particle that has at least one dimension
that is below 100 nm is highly hazardous. There will be a wide variation in the hazard potential
of nano-sized particles just as there is a wide variation in the hazard potential of other
substances.
Aggregation/agglomeration state
When nanomaterials are released, in nearly all situations they will rapidly form aggregates and
agglomerates so that exposure in practice is to a much larger secondary particle than a nanosized primary particle. The size of aggregates/ agglomerates will influence the residence time of
the material in workroom air and may reduce the potential for a nanomaterial to be inhaled. The
aggregation/agglomeration behaviour of nanomaterials is heavily influenced by the external
environment i.e. workroom air, dispersion media, etc. It is therefore useful to understand the
aggregation/agglomeration behaviour in the environment for which the risk assessment is being
conducted.
Aggregates/agglomerates
Aggregates/agglomerates of nanoparticles are not necessarily stable and when the external
environment changes e.g. the transition from workroom air to inhaled air, the
aggregation/agglomeration state may change. So although a nanomaterial may be present in
comparatively large aggregates/ agglomerates in the workroom air, there is the potential for
disaggregation and disagglomeration to occur within the respiratory tract allowing smaller
primary particles to penetrate to the deep lung. For this reason, although the
aggregation/agglomeration state may reduce the potential to inhale a nanomaterial, it should not
be assumed that nanomaterials that are exclusively present in workroom air as large
aggregates/agglomerates will retain this state once inhaled. A precautionary assumption is that
any nanomaterial that is inhaled has the potential to penetrate to the deep lung.
Surface area
Many, but not all, of the toxic effects of particulate materials are mediated by events that take
place at the particle surface. As the size of a particle decreases, the surface area to mass ratio
increases. Therefore, any effects that are caused as a result of interactions at the particle
surface are likely to be enhanced for nanomaterials compared to larger particles. This is one
reason why nano-sized particles appear to be more potent than larger sized particles with the
same chemical composition when doses are compared on the basis of mass. When doses are
compared on the basis of total surface area, the apparent difference in toxicological potency is
often not seen. This has led the scientific community to recommend that exposures and doses
in toxicity studies for nanomaterials should be expressed in terms of surface area as well as
mass.
There is very little experience with the use of surface area to express exposures and doses. The
majority of the hazard data that is currently available will have been obtained from studies using
mass to express dose. In this situation, a dose-response relationship for a larger particle that is
expressed in terms of mass may underestimate the dose-response relationship for a
nanomaterial, even though the chemical composition may be the same. For this reason, it is not
appropriate to extrapolate dose-response relationships and no-effect levels that have been
obtained from studies with larger particle sizes to nanomaterials unless there is scientific
evidence to demonstrate that the extrapolation is valid.
Shape
There is evidence that the shape of a nanomaterial can influence its toxicity. This has been
demonstrated most coherently for certain high aspect ratio nanomaterials (HARN). High aspect
ratio means that one or two of the three dimensions of a particle are much smaller than the
other dimension(s). Fibres are a classic example of high aspect ratio materials. The World
Health Organisation (WHO) defines a respirable fibre as an object with length greater than 5m,
a width less than 3m and a length to width ratio (aspect ratio) greater than 3:1 . Where any of
these dimensions is in the nanoscale, a particle that has an aspect ratio greater than 3:1 would
be considered a HARN. Platelet like structures where only one dimension falls within the nano
size range are also considered to be HARN.
are biopersistent,
consequences of exposure to plate-like particles are not known. Much more research is needed
into these particle types to understand the level of hazard that they represent.
There is no information to indicate how the shape of nanomaterials that are not HARN may
influence their toxicological properties, but it will be useful to obtain information on particle
shape to inform future scientific investigations into the importance of this parameter for nonHARN nanomaterials.
Surface charge
The surface charge of a particle can influence the adsorption of ions, contaminants, the
interaction of the particle with biomolecules, uptake into cells and the way the cells react when
exposed to the particle. The zeta potential of a particle is a measure of its surface charge.
Recent research has identified that certain metal and metal oxide nanoparticles that are known
to be inflammogenic also have a high positive zeta potential . This suggests that this parameter
may be a useful predictor of certain types of toxicological effects. Further research is required to
fully understand the relationship between zeta potential and toxicological effect, but it may be
useful to obtain information on this property so that you can use it in future to inform your risk
assessment.
Chemical composition
Solubility
Some of the adverse effects that may arise following exposure to nanomaterials arise as a
result of solubilisation of the material. It has been found that the solubility of a nanomaterial may
be different to that of larger particles of the same substance. For example, nano sized silver
particles have a greater tendency to release silver ions into solution compared to larger silver
particles. If dissolution leads to the release of reactive or cytotoxic components, and these are
released more readily from a nano form compared to larger particles, the dose-response
relationship for the larger particle may underestimate the dose-response relationship for the
nano form.
In some cases, where reactive or cytotoxic components are not released, enhanced dissolution
will speed up the rate at which nano sized particles are cleared from e.g. the lungs. This could
result in a nano form presenting a lower level of hazard compared to a larger particle depending
on the type of effects that are seen with the larger particle.
It may be useful to consider information on the toxicological properties of ionic forms of
elements that are present in nanomaterials to help understand which sites in the body could be
affected following exposure. It is not appropriate to extrapolate dose response relationships and
no-effect levels that have been obtained from studies with larger particle sizes or ionic forms to
nanomaterials unless there is scientific evidence to demonstrate that the extrapolation is valid.
It has also been suggested that nanomaterials that are highly acidic or alkaline could produce
localised irritation at the site of contact (e.g. lungs, skin or gastrointestinal tract).
Establishing sameness
In order to determine the similarities and differences between the material that you are working
with and the material for which hazard data is available, it is important to obtain as much
information as possible on the physical and chemical characteristics of both materials. The
previous section identifies some physical and chemical characteristics that may be particularly
relevant; future research may identify other relevant characteristics. For this reason, sameness
should be assessed on the basis of all available information. It is suggested that as a minimum
the following characteristics could be used to establish sameness (other characteristics may be
added to this list as our understanding of the relationships between physical characteristics and
hazard improves):
Surface functionalisation/treatment
Shape
Surface area
The greater the differences between the physical and chemical characteristics of your material
and the physical and chemical characteristics of another material, even though they may have
the same chemical composition, the greater the uncertainty in extrapolating hazard data
between the two materials. It is therefore important to have information on the physical and
chemical characteristics of the material that you are using to ensure that you identify hazard
data for materials with similar physical and chemical characteristics. If you find hazard data, but
cannot properly establish the identity and characteristics of the material that has been tested, it
is unwise to assume that the results are applicable to your material.
In the absence of adequate information about the physical characteristics (size, shape, crystal
structure, surface coating, surface reactivity, etc), of the particular nanomaterial you are going to
work with, it is unwise to make general conclusions about its potential hazards based on other
nanoparticles which may have a similar chemical composition, unless you have good data to
confirm that this approach is appropriate. Where nanomaterials have an uncertain or not clearly
defined toxicology and unless, or until, sound evidence is available on the hazards from
inhalation, ingestion, or absorption a precautionary approach should be taken to the risk
management.