Doctoral defense: start legislating on nanomaterials now!

Micro and nanotechnology Nanoparticles
Associate Professor Steffen Foss Hansen’s doctoral dissertation is a thorough proposal for a legislation on the use of nanomaterials. For it is high time, he believes.

Nanotechnology is fantastic. However, nanomaterials do not belong in ordinary consumer products—at least not if there is no reason for it—and not at all without being evaluated and regulated in detail by the environmental authorities.

This is the opinion of Steffen Foss Hansen, and his view is based on a solid foundation. He has, in fact, conducted research into risk and regulation of nanomaterials for ten years, and he has recently earned a doctorate after having defended his dissertation entitled ‘Registration, Evaluation, Authorisation, Categorisation and Tools to Evaluate Nanomaterials – Opportunities and Weaknesses’.

The words in the title obviously indicate the subject-matter of the thesis, but they have also been carefully chosen and combined to form the subtitle ‘REACT NOW’.

“Nanotechnology and the use of nanomaterials are flourishing and are constantly developing, but—in terms of legislation—things are moving incredibly slowly. In fact, manufacturers are completely free to use nanomaterials—or simply mention the word nano in the product name—without the authorities being able to evaluate the materials or document that they are actually present. My doctoral dissertation is both a proposal for how the legislation can be structured and, not least, a rallying cry for action: “Get started, dammit,” says the newly fledged Doctor.

Doctoral dreams
Steffen Foss Hansen has dreamed about writing a doctoral dissertation ever since he handed in his PhD dissertation, which also dealt with risk management of nanomaterials. However, this requires that you have a groundbreaking idea—a kind of engine—as he puts it.

"Nanotechnology and the use of nanomaterials are flourishing and are constantly developing, but—in terms of legislation—things are moving incredibly slowly. "
Steffen Foss Hansen

The first engine part for Steffen’s doctoral dissertation was the publicly accessible database nanodb.dk of all the products in Europe which the manufacturers claim contain nanomaterials. The database has been created and is maintained by Steffen and his colleagues in DTU Environment, and, so far, it contains more than 3,000 products.

Once the database was up and running, Steffen started having ideas for how to categorize the products and evaluate them in relation to human and environmental risk.

“In more than half the cases, we can’t even determine the type of nanomaterial in question. The manufacturer may perhaps state that nanomaterials have been used, but without specifying which ones and for what purpose. 'Nano' has quite simply become a word that sells products. Here at DTU Environment, we have the apparatus to perform analyses, but we have not been able to obtain the funding necessary to analyse all products in the database. Of course, this should, in fact, be a public authority responsibility,” says Steffen.

Colour codes for hazardousness
However, he does not believe that evaluation of the products in terms of health and environment should be abandoned completely. This is, in fact, where the second engine part kicks in: Steffen and his colleagues have developed a visually convincing system in which each product is assigned the colour red, yellow, or green (or grey if the material is known) in five permanent categories.

The first three categories concern the degree of exposure in relation to professional users, ordinary consumers, and the environment, and the last two categories refer to our knowledge of potential impacts on humans and the environment, respectively.

“In this way, we can provide an evaluation without knowing exactly the concentrations of nanomaterials which the individual product contains. And it can be decided that certain combinations of colour codes will result in a requirement for authorization. If three categories are red, it should be considered whether there is reason to impose certain restrictions on the use of the product,” says Steffen Foss Hansen.

His database and categorization of the products are thus a framework for future legislation on nanomaterials.

“I’m not a lawyer, so I’m not able to draft legislative texts, but my dissertation is the first story about how such legislation could be structured from end to end”.

Message to the politicians
The doctoral dissertation is also a way of conveying the message to the politicians:

“I can see that the dissertation has generated huge interest, both internationally and in Denmark. 5,000 people saw the announcement of my dissertation defence on LinkedIn—a scientific article would probably not have created the same attention. But the dissertation will not necessarily end up in the Danish Parliament or the European Parliament.

However, one of the opponents works for the European Chemicals Agency. And it may well be that he can place it strategically on the right desk. I am hoping that it may help get the ball rolling.”