The debate, moderated by Roger Drew, discusses whether product stewardship can effectively replace regulation for the safe management of nanomaterials (NMs). Key questions raised include the robustness of chemical legislation for NMs, the industry's role in product stewardship, and the need for explicit testing requirements to ensure safety for workers and consumers. Both debaters, David Azoulay and David Warheit, explore the advantages and challenges of each approach in ensuring the safe use of nanomaterials.

1. Debate: "Can product stewardship
replace regulation? Case nanomaterials"
Moderator: Roger Drew, Toxicology Consultant, Australia.
Debaters:
David Azoulay, Managing Attorney, CIEL, Switzerland.
David Warheit, Technical Fellow − Toxicology and Risk Assessment,
The Chemours Company, US.
Helsinki Chemicals Forum June 15th 2018

2. 2
Nanomaterials (NMs) – here, there and every where.
Abound in human environment:
• In nature.
• Food.
• Consumer products.
• Therapeutics and diagnostics.
• Industrial processes.
• Day to day articles.

3. 3

4. 4
Nanomaterials (NMs) – here, there and every where.
Potentially as diverse as chemicals with
similar challenges for safety management
Concern is with manufactured NMs.
- Each with unique properties (??).
- Very few tested.
- How safe?
- What’s the exposure?
- What’s the risk?

5. 5
- Chemical regulation has evolved over the last 50+ years.
- Predilection towards risk and rule based regulation.
- Amount of information required to assess risk tends to be
based on the amount of chemical produced/marketed.
- Chemical product stewardship = Responsible Care ®
- Evolved over 30+ years to build trust and confidence.
- A set of Core Principles practiced in 68 global economies.
- Has considerably decreased injuries and incidents.
In these paradigms can “chemical”
be replaced by “nanomaterial” ?

6. Questions from the forum organiser:
• Is chemical legislation robust enough for NM’s?
• What’s the role of industry product stewardship?
• How can companies show due diligence?
6
• Can workers and consumers [researchers] have
confidence in safe use of NM, or should there be
explicit testing requirements?

7. 7
With respect to understanding hazards and safe use,
what are the challenges/benefits with product
stewardship or regulation for NM’s?
David Azoulay: What detracts from product stewardship but
is attractive about regulation?
David Warheit: What are the benefits of product stewardship
and the issues with regulation?