1. CCMI
9 September 2015
Public Hearing: Nanotechnology for a competitive chemical industry
Social aspects: education, health and safety

2. Content Main messages included in:
Position of industriAll European Trade Union on the general report of the European Commission on REACH [DE], [EN], [FR]
Position of industriAll European Trade Union on nanotechnology and nanomaterials[DE], [EN], [FR]
Joint Declaration of the Social Partners of the European Chemical Industry on REACH and the inclusion of nanomaterials in its annexes link

3. 1. industriAll Europe‘s positions - Background
REACH is the Regulation on Registration, Evaluation, Authorisation and Restriction of Chemicals. It entered into force on 1st June It streamlines and improves the former legislative framework on chemicals of the European Union (EU).
Objectives of REACH : to “ensure a high level of protection of human health and the environment, as well as the free circulation of substances on the internal market while enhancing competitiveness and innovation and to shift the responsibility to manage chemical risks from public authorities to industry”.
In February 2013, 5 years after the REACH regulation entered into effect, the European Commission submitted its general report on REACH, in line with Article 117 para. 4 of the REACH regulation. This report is also referred to as the “REACH Review”
Report says:
« REACH sets the best possible framework for the risk management of nanomaterials when they occur as substances or mixtures but more specific requirements for nanomaterials within the framework have proven necessary ».
industriAll Europe agrees

4. 2. industriAll Europe‘s point of view
Safety data sheets
Industriall Europe supports a more precise classification of substances and the improvement of the extended safety datasheets
SDS should provide practical and feasible information to the downstream users especially at the workplaces
SDS should be updated and include all available data on nanomaterials
In addition to SDS, need to improve available information on the risks / dangers of all substances for all users (technical leaflets, scientific publications, conferences and forums where finding from safety research can be disseminated)
Special characteristics and unique properties of nanomaterials require quick action for the protection of employees, downstream users and the environment
Appropriate training and collective protection, and if necessary adequate individual protection (especially for nanomaterials) must be provided for workers

5. 3. industriAll Europe‘s point of view
Still insufficient data and knowledge concerning exposure to nanomaterials at the workplace → the Commission should focus on the workers safety legislation. Before adequate knowledge on the properties of nanomaterials is gained the precautionary principle must apply. Necessary to assess the safety of nanomaterials case by case.
To ensure a high level of protection of human health and the environment while maintaining current and future opportunities for technological development and further growth, the focus now has to be placed on prevention and protection. Protective measures must be reviewed regularly for effective protection from possible dangers of nano-scale particles.
Important for nanotechnology industry and new investments that playing field is clear at European & international levels. Nanotechnology is a key-enabling technology and offers great potential for growth and jobs. SMEs and start-up companies play a key role.
Current legislative framework on the competences of consultative bodies in the field of H&S must be explicitely extended concerning nanotechnology and the risk analysis methods foreseen in H&S directives must be implemented.

6. 4. industriAll Europe‘s point of view
An intensive programm of public and private reasearch must be coordinated at European level to increase knowledge on nanomaterials, their properties and potential risks to the health of workers and consumers, and to the environment.
Significant progress must be made to develop appropriate methods in toxicology and ecotoxicology to improve progress in scientific analysis of these risks. This must be part of the program priorities of European and national research.
Risk assessment and labelling of nanomaterials should be based on REACH & CLP
Product safety must apply from research to disposal
Safety reasearch should develop preventive exposure scenarios to help design better H&S measures at work
An open social dialogue is needed about the future opportunities, awareness of the possible risks and the safe handling and use of nanomaterials

7. 5. Joint Declaration of the Social Partners in the Chemical Industry
industriAll European Trade Union & European Chemicals Employers Group (ECEG)
sole officially recognized European Social Partners / social dialogue since 2004
chemical(NACE 20)
pharmaceutical (NACE 21)
rubber & plastics (NACE 22) sectors
Joint declaration of 9 September 2014
Safe handling and responsible use of nanos
Research, Development and innovation
REACH provides the best appropriate framework to address all chemical substances (Annexes & ECHA guidance documents)
REACH must be applied indiscriminately to all imported products
Further joint work on nanomaterials
Social Partners Roadmap – Awareness raising activities promoting innovation and safe use of nanotechnology and nanomaterials

8. THANK YOU !
Y. Lallemand