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NANOPARTICLES
NANOMATERIALS:
How To Overcome REACH
Regulatory Challenges
2
NANOPARTICLES
Introduction	 3
What is So Special About Nanomaterials? 	 4
Definition of a Nanomaterial in the European Union (EU)	 5
Regulation 2018/1881: Updating REACH to Address Nanoforms	 8
Important Concepts Relevant to REACH Nanoform Submissions	 9
Sets of Similar Nanoforms	 14
A Quick Overview of What Has Changed	 15
What Does This Mean for Joint Registrants?	 17
What do you Need to Do By When?	 17
Summary	 19
Useful Reading and Source Material	 20
CONTENTS
3
NANOPARTICLES
Similarly, Damascus steel swords,
forged between 300 and 1700
AD, contain wire-and-tube-like
nanostructures arranged in such
a way as to confer great strength
to the blades.2
It is unlikely, however,
that any of the people involved in
the creation of these items
understood that it was the minute
structure of the material that
conveyed their special properties.
In more recent times, scientists
have come to understand the value
of nanomaterials and exploit them
to deliver technological advances in
a wide range of industries; however,
as the use of nanomaterials has
increased, so have questions about
their safety to human health and
the environment, and, therefore,
how best to regulate them.
Regulations vary worldwide and
they are evolving in line with the
revolution of nanotechnology. In
2018, the European Commission (EC)
adopted regulation 2018/1881,3
which
amended the existing Registration,
Nanomaterials are chemical
substances that have a
particle size between 1
and 100 nanometres (nm)
in at least one dimension.1
What is special about
nanomaterials is that the
properties of a substance
change when it is scaled
down to nanosize – such
changes can include
improvements in optical,
electrical and magnetic
properties.
The unique characteristics of
nanomaterials have been exploited
for hundreds of years to produce a
range of diverse items. For example,
the corrosion-resistant blue pigment,
Maya Blue, first used by the Mayans in
800 AD is a complex nanomaterial that
combines a dye with nanoporous clay.
INTRODUCTION
Evaluation, Authorization and
Restriction of Chemicals (REACH)
regulation, to address nanomaterials
directly. The regulation mandates
effective characterization of a
substance and contains new data
requirements relevant to both new
and registered nanomaterials.
Importantly, the amendment
also applies to any substance that
might contain nanomaterials (e.g.
powder), whether or not it has been
manufactured as a nanomaterial.
The European Union Observatory
for Nanomaterials (EUON),
which provides information about
nanomaterials on the EU market,
had identified 81 pigments that
could be classed as nanomaterials,
as of June 28, 2018.
This e-book reviews the REACH
amendment and some of the
key concepts it contains in order
to explain how to prepare for
the revised regulation coming
into force on January 1, 2020.
4
NANOPARTICLES
The feature that all nanomaterials
have in common is their minute
size – in all other aspects of
physiochemistry, nanomaterials
are a diverse and heterogeneous
group. It is not necessarily the minute
size that determines if a nanomaterial
is hazardous or not, but the size
does mark out nanomaterials as
substances that need specific
regulatory consideration.4
CHARACTERISTICS OF NANOMATERIALS
Many nanomaterials also exist at the micro- and
macroscopic level, but it is impossible to predict if
the physiochemical behavior observed at this scale
changes when the material is nanosized. This is one
of the main challenges in understanding and regulating
nanomaterials, especially when there is no clear size
threshold at which properties may change.
Nanomaterials have applications in a range of industries;
for example, they can be used for pathogen detection
in food packaging, to aid the refinement of crude oil,
in the medical sector to improve targeted drug delivery,
and in electronics to enable wearable technology in
phones and clothes.
5
NANOPARTICLES
Within the EU, there is currently
no single specific regulation
for nanomaterials. Instead,
nanomaterials are governed by
different legislations; for example,
nanomaterials in cosmetic products
are addressed under Regulation
1223/2009 and those in medical
devices under Regulation 2017/745.
The EC first recommended a
definition for a nanomaterial in
2011 (2011/696).1
In 2018, the EC
adopted Regulation 2018/1881,3
which amended existing REACH
regulation, to address nanomaterials.
Regulation 2018/1881 provided
a definition of a nanoform,
as it specifically applied to
REACH legislation.
There are some differences between
the definitions of nanomaterials and
nanoforms, as shown in Figure 1.
In general, nanomaterials
are defined as chemical
substances or materials
with particle sizes
between 1 and 100 nm in
at least one dimension;1,4
however, the detailed
definition from a
regulatory perspective
varies across the globe,
with the EU definition
being one of the
most specific.
DEFINITION OF A NANOMATERIAL
6
NANOPARTICLES
FIGURE 1. DEFINITIONS OF A NANOMATERIAL AND NANOFORM1,4
Nanomaterial (2011/696) Nanoform (2018/1881)
Nanomaterial means a natural,
incidental or manufactured material,
containing particles in an unbound
state or as an aggregate or agglomerate,
where, for 50% or more of the particles
in the number size distribution,
one or more external dimensions
is in the size range 1–100 nm.
In specific cases and where warranted
by concerns for the environment,
health, safety or competitiveness,
the number size distribution threshold
of 50% may be replaced by a
threshold between 1 and 50%.
By derogation, fullerenes, graphene
flakes and single-wall carbon nanotubes
with one or more external dimensions
below 1 nm should be considered
as nanomaterials.
There is no
flexibility of
the ≥50%
threshold
criteria
in REACH
The term substance, rather than material,
is used in REACH and there is no
incidental substance in REACH
A nanoform is a form of a natural or
manufactured substance, containing
particles in an unbound state or as an
aggregate or agglomerate, where,
for 50% or more of the particles
in the number size distribution,
one or more external dimensions
is in the size range 1–100nm,
including also, by derogation fullerenes,
graphene flakes and single-wall carbon
nanotubes with one or more external
dimensions below 1 nm.
7
NANOPARTICLES
FIGURE 1. DEFINITIONS OF A NANOMATERIAL AND NANOFORM1,4
PARTICLE
A minute piece of matter
with defined physical
boundaries
AGGLOMERATE
A collection of weakly
bound particles
or aggregates, where
the resulting external
surface area is similar
to the sum of the
surface areas of the
individual components
AGGREGATE
A particle comprising
of strongly bound
or fused particles
8
NANOPARTICLES
The EC has been considering the appropriate way to regulate nanomaterials for some time (Figure 2), culminating in the
adoption of Regulation 2018/1881 on December 3, 2018. Although not explicitly stated in Regulation 2018/1881, it is clearly
implied that all registrants of active substances must confirm if their substance contains nanoforms. Importantly, this
applies to substances that are intentionally created as nanomaterials, as well as substances that may contain nanoforms –
this may be especially relevant to registrants of powders, in which nanoforms may unintentionally exist. The EC NM
definition of a nanomaterial covers only particles that are solid at normal temperature and pressure (NTP).5
The regulation
mandates that, by January 1, 2020, dossiers for both previously registered substances and new substance registrations
should include information on nanoforms.
FIGURE 2. A RECENT HISTORY OF NANOMATERIAL REGULATION IN THE EU RELEVANT TO REACH
REGULATION 2018/1881:
UPDATING REACH TO ADDRESS NANOFORMS
REACH review
2nd regulatory review
on nanomaterials
Conclude that nanomaterials are best
regulated under REACH and CLP
2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020
Recommendation
2011/696 adopted
on the definition
of a nanomaterial
Regulation 2018/1881
adopted outlining
amendments to
REACH Annexes I, III
and VI-XII to address
nanoform substances
Regulation 2018/1881
comes into force on
1 January 2020
GUIDANCE REGULATION OTHER
Voluntary
nanomaterials
reporting enabled
in IUCLID
Voluntary
nanomaterials
reporting enabled
in IUCLID
European Union
Observatory for
Nanomaterials
(EUON) launched
ECHA issues first
guidance document
on nanomaterials
ECHA issues further
guidance on inclusion
of nanomaterials in
REACH dossiers
JRC publishes an
overview of concepts
and terms used in the
EC’s definition of
nanomaterial
Further guidance
expected from ECHA
and from the JRC
9
NANOPARTICLES
The production of nanomaterials
can result in the creation of a number
of different nanoforms of the
substance, which can vary in terms
of size distribution, shape and surface
chemistry. This means that various
nanoforms may be present in one
nanomaterial or that the production
process may need to be adjusted
to produce only one nanoform.
IMPORTANT CONCEPTS RELEVANT
TO REACH NANOFORM SUBMISSIONS
It is important to understand how these different
characteristics may impact the behavior and reactivity
of a nanoform. The behavior encompasses factors like
solubility, hydrophobicity or the ease of dispersal –
all of which can affect where the nanoform ultimately
ends up in biological systems.
UNDER REACH REGULATION, THE
THREE FEATURES THAT ARE REQUIRED
IN DOSSIERS ARE
▶▶ Particle size/number size distribution
▶▶ Particle shape
▶▶ Surface chemistry
Reactivity determines what the nanoforms do and their
subsequent toxicologic or ecotoxicologic impact.
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NANOPARTICLES
For particles that are spherical, it is easy to establish size using a single descriptor – the spherical diameter.
Not all particles are spherical, however, and although many techniques used to analyze particle size can identify
an equivalent spherical diameter, results vary with technique and there is a tendency to overestimate size.
To overcome this issue, EU regulations use external dimensions as a means of defining particle size;
two approaches of assessing external dimensions are summarized in Figure 3.
FIGURE 3. TWO COMMONLY USED APPROACHES OF ASSESSING EXTERNAL
DIMENSIONS OF IRREGULAR-SHAPED PARTICLES
PARTICLE SIZE
Smallest
dimension
MAXIMUM INSCRIBED CIRCLE DIAMETER
The diameter of largest circle that could fit inside the particle profile.
If this is <100 nm, the particle is a nanomaterial
FERET DIAMETER
This is the distance between parallel tangents. If the Feret diameter
in one dimension is <100 nm, the particle is a nanomaterial
11
NANOPARTICLES
The definition of a nanoform
specifies that more than half of
the particles in the number size
distribution should have at least
one external dimension between
1 nm and 100 nm. For most
situations, this essentially means
that if the median size of particles
in the substance is between 1 nm
and 100 nm, then the substance
is a nanomaterial.5
Although conceptually it is easy
to visualize number size distribution
as a histogram plotting particle
size (grouped into size bands)
against the number of particles
in each band, in reality, the
number of particles is measured
in alternative way. For example,
the total surface area for each
size band, which provides a
surface area size distribution.
NUMBER SIZE DISTRIBUTION
ADDITIONAL INFORMATION:
VOLUME-SPECIFIC SURFACE AREA (VSSA)
The recommended definition of a nanomaterial in Regulation 2011/696
includes a criterion based on VSSA; however, this is not defined for nanoforms
in Regulation 2018/1881. Using the VSSA criterion, a nanomaterial can be
defined as a material in which the specific surface area by volume is >60
m2/cm3. VSSA is likely to be a reliable indicator in most cases, unless the
constituent particles have rough surfaces or are porous. However, the VSSA
criterion only allows you to demonstrate that a material is a nanomaterial,
but not that it is not one. Materials that have specific surface areas <60 m2/cm3
but comply with the definition based on particle number size are still classed
as nanomaterials.
VSSA may still be a helpful tool in assessing particle size distribution in
REACH, even if it is not inherent in that regulation.
12
NANOPARTICLES
The shape of a nanoform can dictate its behavior and,
therefore, its potential (eco)toxicity – for example, it may
impact how easily a nanomaterial can enter a cell. Shape
may also differentiate one nanoform from another; therefore,
characterizing and reporting nanoform shape is important.
For the purpose of REACH submissions, there are four main
categories, as shown in Figure 4, with the nanoform category
determined as the shape represented by >50% of the particles.
PARTICLE SHAPE
SPHEROIDAL-LIKE
PARTICLES
These have three similar
external dimensions
in all projections.
They include shapes that
can be approximated
as spheres, cubes,
prisms, etc.
They exclude shapes with
an aspect ratio ≥5:1.
HIGH-ASPECT-
RATIO SHAPES
Particles with two similar
external dimensions and
a significantly larger
3rd dimension
(aspect ratio ≥5:1)
and parallel sides.
Include:
Hollow structures: nanotubes
Solid structures: nanorods
2-D SHAPES
One external dimension
significantly smaller
than the other two
external dimensions.
The smaller dimension
is the thickness
of the particle
(e.g. flakes or platelets).
OTHER
These could include:
Particles with any
other irregular shape
Mixtures of particles
with different shapes
SPHEROIDAL-LIKE
PARTICLES
These have three similar
external dimensions
in all projections.
They include shapes that
can be approximated
as spheres, cubes,
prisms, etc.
They exclude shapes with
an aspect ratio ≥5:1.
HIGH-ASPECT-
RATIO SHAPES
Particles with two similar
external dimensions and
a significantly larger
3rd dimension
(aspect ratio ≥5:1)
and parallel sides.
Include:
Hollow structures: nanotubes
Solid structures: nanorods
2-D SHAPES
One external dimension
significantly smaller
than the other two
external dimensions.
The smaller dimension
is the thickness
of the particle
(e.g. flakes or platelets).
OTHER
These could include:
Particles with any
other irregular shape
Mixtures of particles
with different shapes
THE SHAPE OF THE NANOMATERIAL HAS A DIRECT
EFFECT ON PARTICULAR CELLULAR EFFECTS:
▶▶ Needle-shaped or "wire-shaped" particles can cause physical cell damage
Spherical nanoparticles can easily cross cell membranes by endocytosis
▶▶ Single-walled carbon nanotubes have the potential to block
calcium channels
The toxicological effects of nanomaterials are numerous but could
cause asthma, lung cancer heart problems, autoimmune disease etc.
FIGURE 4. SHAPE CATEGORIES FOR NANOFORMS
13
NANOPARTICLES
As nanomaterials have a very
large surface area, the chemistry
of the surface of the particles
can have a huge influence on the
particles’ properties. In fact, surface
chemistry is often adjusted in the
manufacturing process to alter
properties such as reactivity, solubility
and dispersibility. This can be
achieved by adjusting the processes
and conditions used to create
the nanomaterial or by using
surface-specific treatments.
The surface characteristics, and
indeed the nanoform composition,
can be highly dynamic and change
depending on use or as the material
passes through the supply chain.
Tracking this can be difficult.
SURFACE CHEMISTRY
From a regulatory standpoint, it is therefore essential to characterize
the surface chemistry, in order to predict the potential hazard posed
by a nanoform. Recording this or the surface treatment methodology
is required for REACH submission.
14
NANOPARTICLES
Using sets of similar nanoforms ensures the regulation
is workable and reduces the need for unnecessary testing
for hazard and risk assessment. From a regulatory
perspective, defining groupings of similar nanoforms
on the basis of a scientific argument that can be justified
to the European Chemicals Agency (ECHA) is essential.
To achieve this, read-across methodologies (which are
widely used under REACH) that compare nanoforms
should be employed. Read-across may also be appropriate
between the conventional substance and the nanoforms
if it can be justified scientifically.
Regulation 2018/1881 sets out provision
for grouping together nanoforms
with similar characteristics into ‘sets
of similar nanoforms’. The grouping
should define the boundaries for the
set of similar nanoforms and provide
a clear justification that any variation
within these boundaries does not
affect the hazard assessment, exposure
assessment and risk assessment of the
individual nanoforms within the set of
similar nanoforms. Nanoforms can only
belong to one set of similar nanoforms.
SETS OF SIMILAR NANOFORMS
15
NANOPARTICLES
AS WELL AS DEFINING A
NANOFORM, REGULATION
2018/1881 AMENDED THE
FOLLOWING ANNEXES:7
▶▶ Annex I: general provisions for
assessing substances and preparing
chemical safety reports. Extensive
and effective identification and
characterization of nanoforms and
sets of similar nanoforms within
a substance are required; this may
pose technical challenges.
▶▶ Annex III and VI-XI: registration
requirements for tonnage bands.
Specific data requirements
applicable to nanoforms have been
identified (e.g. dispersion stability
instead of octanol/water partition
coefficient) and those not relevant
have been highlighted. Most of
these are straightforward and
simple, based on application of
the appropriate science. Note that
the requirements vary by tonnage
band, based on the total annual
tonnage for the bulk substance
and not the nanoforms.
AN OVERVIEW OF THE REGULATORY CHANGES
▶▶ Annex XII: general provisions
for downstream users to assess
substances and prepare chemical
safety reports. Risk analysis is
required for all nanoforms, so
simplification of nanoforms into
groups will be essential. What
may prove challenging is that
downstream users may apply
specific treatments to substances
that may alter the nanoform
composition and characteristics;
however, because these treatments
are usually protected under
intellectual property rights, users
may be reluctant to communicate
the changes to the registrant.
Many of the approaches and tests
required for assessing nanomaterials
are evolving, and harmonized
test guidelines appropriate for
regulatory use are in development.
A recent Organization for Economic
Co-operation and Development
(OECD) publication provides a
comprehensive review of the current
status6
, and further guidance on
measurements related to the EU
regulatory environment is planned
for publication by the Joint Research
Centre (JRC) at the end of 2019.
There is an ongoing review as
to whether Annex of the REACH
Regulation, relating to the
compilation of safety data
sheets, requires amendment.
16
NANOPARTICLES
PARTICLE
CHARACTERIZATION
The usual methods employed for
substance characterization, such as
spectral analysis and chromatography,
may be insufficient for complete
characterization of nanoforms. You
may, therefore, have to employ a
new range of techniques to fully
characterize all nanoforms and sets
of similar nanoforms. Zeta potential,
for example, which assesses the
electrical charge on a particle, may
be a good indicator of the likelihood
of agglomerate formation.
PHYSIOCHEMICAL
ENDPOINTS OVERVIEW
The regulation identifies the
partition coefficient (Kow) as being
inappropriate for nanomaterials,
as, given their small size, they can
easily cross biological membranes,
regardless of their water solubility.
Instead, dispersion stability and rate
of dissolution are key characteristics
that should be assessed. For the
latter, it is important to consider this
in terms of dissolution in water and
relevant aqueous environments such
as bodily fluids.
TOXICOLOGICAL ENDPOINTS
OVERVIEW
For conventional substances,
the Ames test for mutagenicity
(Annex VII) is a standard endpoint.
As nanoforms are too large to cross
bacterial cell walls, however, exposure
is not possible using this test, so
mammalian cell studies are required
instead. Inhalation studies are
especially relevant for nanomaterials,
as the main route of exposure is likely
to be through inhalation.
ENVIRONMENTAL FATE
AND BEHAVIOR ENDPOINTS
OVERVIEW
The dispersal stability and dissolution
rate will determine many of the
tests you will need to conduct
for environmental fate studies.
Consider also how nanoforms may
be altered by the environment and
what the implications of this are for
environmental fate and behavior.
Although waivers are available for
conventional substances with low
water solubility, these will not apply
to nanoforms.
17
NANOPARTICLES
The ‘one substance, one submission’ approach mandated under REACH still applies; however, the situation
for nanoforms can be complex because of confidentiality requirements. Individual registrants will often use
specific surface treatments to alter particle characteristics and these may be confidential, so sharing this information
may infringe intellectual property rights. It is still necessary to work with other registrants to enable dossier
update/creation, so all registrants need to explore this carefully.
If you have a substance that is
registered under REACH and
you suspect it may contain
nanoforms, you will need to
confirm this. A useful approach
is to ask these questions:
▶▶ Is the substance a solid or a liquid?
▶▶ Does the substance consist
of particles or aggregates/
agglomerates of particles that have
an external dimension between
1nm and 100nm?
▶▶ Does the particle size distribution
data indicate the possibility of
nanoparticles (>50% having a
diameter below 100nm?
▶▶ What is the particle shape (e.g.
sphere, cube, tube, wire, plate)?
THE NEXT STEPS FOR JOINT REGISTRANTS
REQUIREMENTS AND TIMINGS
If the substance is confirmed to
be a nanomaterial you will need to
fully identify and characterize it and
update your dossier in line with the
new regulatory requirements.
For many registrants, the biggest
challenge will be the correct
characterization of nanoforms.
Fortunately, ECHA have published
a best practice guide for the
characterization of nanomaterials
for REACH. This helpful document
suggests the use electron microscopy,
dynamic light scattering and X-ray
scattering methods to determine
particle size. For surface area it
is recommended to measure the
gas adsorption isotherm of the
substance microscopy to
determine particle shape.
When carrying the latter
measurements, it is noted that
sample preparation is very important
because the method used can
affect results significantly (e.g.
sonication versus dispersion) and
because size is method dependent,
no single method is perfect, and
the use of multiple methods is
preferable. Finding a laboratory that
understands the relevance from a
regulatory perspective and has the
scientific capability to run the particle
characterization tests and interpret
the results is crucial.
18
NANOPARTICLES
If you have many nanoforms, you
need to group them into sets of
similar nanoforms on the basis
of scientific arguments that can
be justified to ECHA. The ECHA
guidance document on quantitative
structure–activity relationships
(QSAR) and grouping has good
information on how best to tackle
this.8
Optimizing the grouping means
that you can then also use read-across
to address endpoints required for
hazard assessment, which could
obviously reduce the need for
costly additional studies.
Finally, Regulation 2018/1881
requires manufacturers and
importers to assess, and where
relevant, generate the necessary
information and document in the
chemical safety report that the risks,
arising from the identified uses
of the substance with nanoforms
they manufacture or import, are
adequately controlled.
MAIN CONSIDERATIONS:
▶▶ Determine rate of dissolution in
addition to water solubility testing
▶▶ Determine dispersion stability
in octanol and water where
determination of the octanol-water
partition coefficient is not possible
▶▶ Review any QSAR determinations
that use as input experimental values
for water solubility and octanol-water
partition coefficient and consider
using dissolution rate instead
▶▶ Provide information on dustiness
▶▶ Consider one or more in vitro
mutagenicity study(ies) for
substances registered at 1-10tpa,
in addition to the standard
data requirement for bacterial
mutagenicity
▶▶ Bear in mind that for low volume
substances (1-10ta), the inhalation
exposure route may be more
important than the standard
requirement for oral exposure
in acute toxicity
▶▶ Make sure sub chronic repeated dose
tests carried out on nanomaterials
via inhalation exposure include
histopathological determination
of brain and lung tissues as well
as examination of bronchoalveolar
lavage (BAL) fluid, kinetics and an
appropriate recovery period
▶▶ Unless the nanoform dissolves
quickly on entering the organism,
the toxicokinetic assessment should
be carried out on the nanoform in
addition to the bulk substance
▶▶ For substance registered above 10tpa,
specific relevant physicochemical
properties may provide useful
information on a case-by-case basis
(e.g. agglomeration/aggregation
state, surface morphology/
topography, crystallinity)
▶▶ Waivers should be reviewed to
make sure nanoforms are addressed
separately from bulk substance
▶▶ Ecotoxiological test and
environmental tests for nanoforms,
may not be waived on the basis of
high insolubility in water alone.
Annexes VII to X of the REACH
Regulation (EC) No 1907/2006 will
be amended to include these changes.
19
NANOPARTICLES
The regulatory framework
for nanomaterials is evolving,
as the technology expands.
New regulations exist under
REACH that require the
submission of additional data
for nanoforms by January 1, 2020
for both currently registered
substances and new substances.
Crucially, these requirements
apply to substances intentionally
developed as nanomaterials,
as well as those that may
unintentionally contain
nanomaterials by virtue
of their formulation.
SUMMARY
The identification and
characterization of specific
nanoforms requires assessment
of particle size distribution, particle
shape and surface chemistry.
By employing read-across and
robust scientific arguments, it will
be possible to categorize nanoforms
into sets of similar nanoforms in
order to simplify the assessment
of hazard and risk.
20
NANOPARTICLES
1
	 EC definition of a nanomaterial
	(2011/696/EU). https://eur-lex.
	 europa.eu/legal-content/EN/
	 TXT/?uri=CELEX:32011H0696
2
	 The Guardian. Nanotechnology
	 is ancient history. April 24, 2012	
	 www.theguardian.com/
	 nanotechnology-world/nanotechnology-
	 is-ancient-history
3
	 EC amended REACH regulation
	 to address nanoforms (2018/1881).
	 https://eur-lex.europa.eu/legal-content/
	 EN/TXT/PDF/?uri=CELEX:32018
	 R1881&from=EN
4
	 EC, Joint Research Centre (JRC).
	 An overview of concepts and terms
	 used in the European Commission’s
	 definition of nanomaterial. 2019
	 https://ec.europa.eu/jrc/en/
	 publication/eur-scientific-and-technical-
	 research-reports/overview-concepts-
	 and-terms-used-european-
	 commissions-definition-nanomaterial
USEFUL READING AND SOURCE MATERIAL
5
	 EC, Joint Research Centre (JRC).
	 Requirements on the measurements
	 for the implementation of the
	 European Commission’s definition
	 of the term ‘nanomaterial’. 2012	
	 http://publications.jrc.ec.europa.eu/
	 repository/handle/JRC73260
6
	 Rasmussen et al. Developing OECD
	 test guidelines for regulatory testing
	 of nanomaterials to ensure mutual
	 acceptance of test data. Regulatory
	 Toxicology and Pharmacology
	 2019; 104: 74–83.	
	 www.sciencedirect.com/science/article/
	 pii/S0273230019300534?via%3Dihub
7
	 ECHA. How to prepare registration
	 dossiers that cover nanoforms: best
	 practices. Version 1.0 May 2017.
	https://echa.europa.eu/
	 documents/10162/13655/how_to_
	 register_nano_en.pdf/f8c046ec-f60b-
	 4349-492b-e915fd9e3ca0
8
	 ECHA. Guidance on information
	 requirements and chemical safety
	 assessment Appendix R.6-1 for
	 nanomaterials applicable to the
	 Guidance on QSARs and Grouping
	 of Chemicals. Version 1.0 May 2017
	https://echa.europa.eu/
	 documents/10162/23036412/appendix_
	 r6_nanomaterials_en.pdf
ADDITIONAL
ORGANIZATIONS
NanoDefine is an EC funded project
to develop measurements for the
classification of nanomaterials	
www.nanodefine.eu/
European Union Observatory for
Nanomaterials (EUON) provides
information about existing
nanomaterials on the EU market.
It is funded by the EC and maintained 	
by ECHA. https://euon.echa.europa.eu/
21
NANOPARTICLES
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NANOMATERIALS: How To Overcome REACH Regulatory Challenges

  • 2. 2 NANOPARTICLES Introduction 3 What is So Special About Nanomaterials? 4 Definition of a Nanomaterial in the European Union (EU) 5 Regulation 2018/1881: Updating REACH to Address Nanoforms 8 Important Concepts Relevant to REACH Nanoform Submissions 9 Sets of Similar Nanoforms 14 A Quick Overview of What Has Changed 15 What Does This Mean for Joint Registrants? 17 What do you Need to Do By When? 17 Summary 19 Useful Reading and Source Material 20 CONTENTS
  • 3. 3 NANOPARTICLES Similarly, Damascus steel swords, forged between 300 and 1700 AD, contain wire-and-tube-like nanostructures arranged in such a way as to confer great strength to the blades.2 It is unlikely, however, that any of the people involved in the creation of these items understood that it was the minute structure of the material that conveyed their special properties. In more recent times, scientists have come to understand the value of nanomaterials and exploit them to deliver technological advances in a wide range of industries; however, as the use of nanomaterials has increased, so have questions about their safety to human health and the environment, and, therefore, how best to regulate them. Regulations vary worldwide and they are evolving in line with the revolution of nanotechnology. In 2018, the European Commission (EC) adopted regulation 2018/1881,3 which amended the existing Registration, Nanomaterials are chemical substances that have a particle size between 1 and 100 nanometres (nm) in at least one dimension.1 What is special about nanomaterials is that the properties of a substance change when it is scaled down to nanosize – such changes can include improvements in optical, electrical and magnetic properties. The unique characteristics of nanomaterials have been exploited for hundreds of years to produce a range of diverse items. For example, the corrosion-resistant blue pigment, Maya Blue, first used by the Mayans in 800 AD is a complex nanomaterial that combines a dye with nanoporous clay. INTRODUCTION Evaluation, Authorization and Restriction of Chemicals (REACH) regulation, to address nanomaterials directly. The regulation mandates effective characterization of a substance and contains new data requirements relevant to both new and registered nanomaterials. Importantly, the amendment also applies to any substance that might contain nanomaterials (e.g. powder), whether or not it has been manufactured as a nanomaterial. The European Union Observatory for Nanomaterials (EUON), which provides information about nanomaterials on the EU market, had identified 81 pigments that could be classed as nanomaterials, as of June 28, 2018. This e-book reviews the REACH amendment and some of the key concepts it contains in order to explain how to prepare for the revised regulation coming into force on January 1, 2020.
  • 4. 4 NANOPARTICLES The feature that all nanomaterials have in common is their minute size – in all other aspects of physiochemistry, nanomaterials are a diverse and heterogeneous group. It is not necessarily the minute size that determines if a nanomaterial is hazardous or not, but the size does mark out nanomaterials as substances that need specific regulatory consideration.4 CHARACTERISTICS OF NANOMATERIALS Many nanomaterials also exist at the micro- and macroscopic level, but it is impossible to predict if the physiochemical behavior observed at this scale changes when the material is nanosized. This is one of the main challenges in understanding and regulating nanomaterials, especially when there is no clear size threshold at which properties may change. Nanomaterials have applications in a range of industries; for example, they can be used for pathogen detection in food packaging, to aid the refinement of crude oil, in the medical sector to improve targeted drug delivery, and in electronics to enable wearable technology in phones and clothes.
  • 5. 5 NANOPARTICLES Within the EU, there is currently no single specific regulation for nanomaterials. Instead, nanomaterials are governed by different legislations; for example, nanomaterials in cosmetic products are addressed under Regulation 1223/2009 and those in medical devices under Regulation 2017/745. The EC first recommended a definition for a nanomaterial in 2011 (2011/696).1 In 2018, the EC adopted Regulation 2018/1881,3 which amended existing REACH regulation, to address nanomaterials. Regulation 2018/1881 provided a definition of a nanoform, as it specifically applied to REACH legislation. There are some differences between the definitions of nanomaterials and nanoforms, as shown in Figure 1. In general, nanomaterials are defined as chemical substances or materials with particle sizes between 1 and 100 nm in at least one dimension;1,4 however, the detailed definition from a regulatory perspective varies across the globe, with the EU definition being one of the most specific. DEFINITION OF A NANOMATERIAL
  • 6. 6 NANOPARTICLES FIGURE 1. DEFINITIONS OF A NANOMATERIAL AND NANOFORM1,4 Nanomaterial (2011/696) Nanoform (2018/1881) Nanomaterial means a natural, incidental or manufactured material, containing particles in an unbound state or as an aggregate or agglomerate, where, for 50% or more of the particles in the number size distribution, one or more external dimensions is in the size range 1–100 nm. In specific cases and where warranted by concerns for the environment, health, safety or competitiveness, the number size distribution threshold of 50% may be replaced by a threshold between 1 and 50%. By derogation, fullerenes, graphene flakes and single-wall carbon nanotubes with one or more external dimensions below 1 nm should be considered as nanomaterials. There is no flexibility of the ≥50% threshold criteria in REACH The term substance, rather than material, is used in REACH and there is no incidental substance in REACH A nanoform is a form of a natural or manufactured substance, containing particles in an unbound state or as an aggregate or agglomerate, where, for 50% or more of the particles in the number size distribution, one or more external dimensions is in the size range 1–100nm, including also, by derogation fullerenes, graphene flakes and single-wall carbon nanotubes with one or more external dimensions below 1 nm.
  • 7. 7 NANOPARTICLES FIGURE 1. DEFINITIONS OF A NANOMATERIAL AND NANOFORM1,4 PARTICLE A minute piece of matter with defined physical boundaries AGGLOMERATE A collection of weakly bound particles or aggregates, where the resulting external surface area is similar to the sum of the surface areas of the individual components AGGREGATE A particle comprising of strongly bound or fused particles
  • 8. 8 NANOPARTICLES The EC has been considering the appropriate way to regulate nanomaterials for some time (Figure 2), culminating in the adoption of Regulation 2018/1881 on December 3, 2018. Although not explicitly stated in Regulation 2018/1881, it is clearly implied that all registrants of active substances must confirm if their substance contains nanoforms. Importantly, this applies to substances that are intentionally created as nanomaterials, as well as substances that may contain nanoforms – this may be especially relevant to registrants of powders, in which nanoforms may unintentionally exist. The EC NM definition of a nanomaterial covers only particles that are solid at normal temperature and pressure (NTP).5 The regulation mandates that, by January 1, 2020, dossiers for both previously registered substances and new substance registrations should include information on nanoforms. FIGURE 2. A RECENT HISTORY OF NANOMATERIAL REGULATION IN THE EU RELEVANT TO REACH REGULATION 2018/1881: UPDATING REACH TO ADDRESS NANOFORMS REACH review 2nd regulatory review on nanomaterials Conclude that nanomaterials are best regulated under REACH and CLP 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 Recommendation 2011/696 adopted on the definition of a nanomaterial Regulation 2018/1881 adopted outlining amendments to REACH Annexes I, III and VI-XII to address nanoform substances Regulation 2018/1881 comes into force on 1 January 2020 GUIDANCE REGULATION OTHER Voluntary nanomaterials reporting enabled in IUCLID Voluntary nanomaterials reporting enabled in IUCLID European Union Observatory for Nanomaterials (EUON) launched ECHA issues first guidance document on nanomaterials ECHA issues further guidance on inclusion of nanomaterials in REACH dossiers JRC publishes an overview of concepts and terms used in the EC’s definition of nanomaterial Further guidance expected from ECHA and from the JRC
  • 9. 9 NANOPARTICLES The production of nanomaterials can result in the creation of a number of different nanoforms of the substance, which can vary in terms of size distribution, shape and surface chemistry. This means that various nanoforms may be present in one nanomaterial or that the production process may need to be adjusted to produce only one nanoform. IMPORTANT CONCEPTS RELEVANT TO REACH NANOFORM SUBMISSIONS It is important to understand how these different characteristics may impact the behavior and reactivity of a nanoform. The behavior encompasses factors like solubility, hydrophobicity or the ease of dispersal – all of which can affect where the nanoform ultimately ends up in biological systems. UNDER REACH REGULATION, THE THREE FEATURES THAT ARE REQUIRED IN DOSSIERS ARE ▶▶ Particle size/number size distribution ▶▶ Particle shape ▶▶ Surface chemistry Reactivity determines what the nanoforms do and their subsequent toxicologic or ecotoxicologic impact.
  • 10. 10 NANOPARTICLES For particles that are spherical, it is easy to establish size using a single descriptor – the spherical diameter. Not all particles are spherical, however, and although many techniques used to analyze particle size can identify an equivalent spherical diameter, results vary with technique and there is a tendency to overestimate size. To overcome this issue, EU regulations use external dimensions as a means of defining particle size; two approaches of assessing external dimensions are summarized in Figure 3. FIGURE 3. TWO COMMONLY USED APPROACHES OF ASSESSING EXTERNAL DIMENSIONS OF IRREGULAR-SHAPED PARTICLES PARTICLE SIZE Smallest dimension MAXIMUM INSCRIBED CIRCLE DIAMETER The diameter of largest circle that could fit inside the particle profile. If this is <100 nm, the particle is a nanomaterial FERET DIAMETER This is the distance between parallel tangents. If the Feret diameter in one dimension is <100 nm, the particle is a nanomaterial
  • 11. 11 NANOPARTICLES The definition of a nanoform specifies that more than half of the particles in the number size distribution should have at least one external dimension between 1 nm and 100 nm. For most situations, this essentially means that if the median size of particles in the substance is between 1 nm and 100 nm, then the substance is a nanomaterial.5 Although conceptually it is easy to visualize number size distribution as a histogram plotting particle size (grouped into size bands) against the number of particles in each band, in reality, the number of particles is measured in alternative way. For example, the total surface area for each size band, which provides a surface area size distribution. NUMBER SIZE DISTRIBUTION ADDITIONAL INFORMATION: VOLUME-SPECIFIC SURFACE AREA (VSSA) The recommended definition of a nanomaterial in Regulation 2011/696 includes a criterion based on VSSA; however, this is not defined for nanoforms in Regulation 2018/1881. Using the VSSA criterion, a nanomaterial can be defined as a material in which the specific surface area by volume is >60 m2/cm3. VSSA is likely to be a reliable indicator in most cases, unless the constituent particles have rough surfaces or are porous. However, the VSSA criterion only allows you to demonstrate that a material is a nanomaterial, but not that it is not one. Materials that have specific surface areas <60 m2/cm3 but comply with the definition based on particle number size are still classed as nanomaterials. VSSA may still be a helpful tool in assessing particle size distribution in REACH, even if it is not inherent in that regulation.
  • 12. 12 NANOPARTICLES The shape of a nanoform can dictate its behavior and, therefore, its potential (eco)toxicity – for example, it may impact how easily a nanomaterial can enter a cell. Shape may also differentiate one nanoform from another; therefore, characterizing and reporting nanoform shape is important. For the purpose of REACH submissions, there are four main categories, as shown in Figure 4, with the nanoform category determined as the shape represented by >50% of the particles. PARTICLE SHAPE SPHEROIDAL-LIKE PARTICLES These have three similar external dimensions in all projections. They include shapes that can be approximated as spheres, cubes, prisms, etc. They exclude shapes with an aspect ratio ≥5:1. HIGH-ASPECT- RATIO SHAPES Particles with two similar external dimensions and a significantly larger 3rd dimension (aspect ratio ≥5:1) and parallel sides. Include: Hollow structures: nanotubes Solid structures: nanorods 2-D SHAPES One external dimension significantly smaller than the other two external dimensions. The smaller dimension is the thickness of the particle (e.g. flakes or platelets). OTHER These could include: Particles with any other irregular shape Mixtures of particles with different shapes SPHEROIDAL-LIKE PARTICLES These have three similar external dimensions in all projections. They include shapes that can be approximated as spheres, cubes, prisms, etc. They exclude shapes with an aspect ratio ≥5:1. HIGH-ASPECT- RATIO SHAPES Particles with two similar external dimensions and a significantly larger 3rd dimension (aspect ratio ≥5:1) and parallel sides. Include: Hollow structures: nanotubes Solid structures: nanorods 2-D SHAPES One external dimension significantly smaller than the other two external dimensions. The smaller dimension is the thickness of the particle (e.g. flakes or platelets). OTHER These could include: Particles with any other irregular shape Mixtures of particles with different shapes THE SHAPE OF THE NANOMATERIAL HAS A DIRECT EFFECT ON PARTICULAR CELLULAR EFFECTS: ▶▶ Needle-shaped or "wire-shaped" particles can cause physical cell damage Spherical nanoparticles can easily cross cell membranes by endocytosis ▶▶ Single-walled carbon nanotubes have the potential to block calcium channels The toxicological effects of nanomaterials are numerous but could cause asthma, lung cancer heart problems, autoimmune disease etc. FIGURE 4. SHAPE CATEGORIES FOR NANOFORMS
  • 13. 13 NANOPARTICLES As nanomaterials have a very large surface area, the chemistry of the surface of the particles can have a huge influence on the particles’ properties. In fact, surface chemistry is often adjusted in the manufacturing process to alter properties such as reactivity, solubility and dispersibility. This can be achieved by adjusting the processes and conditions used to create the nanomaterial or by using surface-specific treatments. The surface characteristics, and indeed the nanoform composition, can be highly dynamic and change depending on use or as the material passes through the supply chain. Tracking this can be difficult. SURFACE CHEMISTRY From a regulatory standpoint, it is therefore essential to characterize the surface chemistry, in order to predict the potential hazard posed by a nanoform. Recording this or the surface treatment methodology is required for REACH submission.
  • 14. 14 NANOPARTICLES Using sets of similar nanoforms ensures the regulation is workable and reduces the need for unnecessary testing for hazard and risk assessment. From a regulatory perspective, defining groupings of similar nanoforms on the basis of a scientific argument that can be justified to the European Chemicals Agency (ECHA) is essential. To achieve this, read-across methodologies (which are widely used under REACH) that compare nanoforms should be employed. Read-across may also be appropriate between the conventional substance and the nanoforms if it can be justified scientifically. Regulation 2018/1881 sets out provision for grouping together nanoforms with similar characteristics into ‘sets of similar nanoforms’. The grouping should define the boundaries for the set of similar nanoforms and provide a clear justification that any variation within these boundaries does not affect the hazard assessment, exposure assessment and risk assessment of the individual nanoforms within the set of similar nanoforms. Nanoforms can only belong to one set of similar nanoforms. SETS OF SIMILAR NANOFORMS
  • 15. 15 NANOPARTICLES AS WELL AS DEFINING A NANOFORM, REGULATION 2018/1881 AMENDED THE FOLLOWING ANNEXES:7 ▶▶ Annex I: general provisions for assessing substances and preparing chemical safety reports. Extensive and effective identification and characterization of nanoforms and sets of similar nanoforms within a substance are required; this may pose technical challenges. ▶▶ Annex III and VI-XI: registration requirements for tonnage bands. Specific data requirements applicable to nanoforms have been identified (e.g. dispersion stability instead of octanol/water partition coefficient) and those not relevant have been highlighted. Most of these are straightforward and simple, based on application of the appropriate science. Note that the requirements vary by tonnage band, based on the total annual tonnage for the bulk substance and not the nanoforms. AN OVERVIEW OF THE REGULATORY CHANGES ▶▶ Annex XII: general provisions for downstream users to assess substances and prepare chemical safety reports. Risk analysis is required for all nanoforms, so simplification of nanoforms into groups will be essential. What may prove challenging is that downstream users may apply specific treatments to substances that may alter the nanoform composition and characteristics; however, because these treatments are usually protected under intellectual property rights, users may be reluctant to communicate the changes to the registrant. Many of the approaches and tests required for assessing nanomaterials are evolving, and harmonized test guidelines appropriate for regulatory use are in development. A recent Organization for Economic Co-operation and Development (OECD) publication provides a comprehensive review of the current status6 , and further guidance on measurements related to the EU regulatory environment is planned for publication by the Joint Research Centre (JRC) at the end of 2019. There is an ongoing review as to whether Annex of the REACH Regulation, relating to the compilation of safety data sheets, requires amendment.
  • 16. 16 NANOPARTICLES PARTICLE CHARACTERIZATION The usual methods employed for substance characterization, such as spectral analysis and chromatography, may be insufficient for complete characterization of nanoforms. You may, therefore, have to employ a new range of techniques to fully characterize all nanoforms and sets of similar nanoforms. Zeta potential, for example, which assesses the electrical charge on a particle, may be a good indicator of the likelihood of agglomerate formation. PHYSIOCHEMICAL ENDPOINTS OVERVIEW The regulation identifies the partition coefficient (Kow) as being inappropriate for nanomaterials, as, given their small size, they can easily cross biological membranes, regardless of their water solubility. Instead, dispersion stability and rate of dissolution are key characteristics that should be assessed. For the latter, it is important to consider this in terms of dissolution in water and relevant aqueous environments such as bodily fluids. TOXICOLOGICAL ENDPOINTS OVERVIEW For conventional substances, the Ames test for mutagenicity (Annex VII) is a standard endpoint. As nanoforms are too large to cross bacterial cell walls, however, exposure is not possible using this test, so mammalian cell studies are required instead. Inhalation studies are especially relevant for nanomaterials, as the main route of exposure is likely to be through inhalation. ENVIRONMENTAL FATE AND BEHAVIOR ENDPOINTS OVERVIEW The dispersal stability and dissolution rate will determine many of the tests you will need to conduct for environmental fate studies. Consider also how nanoforms may be altered by the environment and what the implications of this are for environmental fate and behavior. Although waivers are available for conventional substances with low water solubility, these will not apply to nanoforms.
  • 17. 17 NANOPARTICLES The ‘one substance, one submission’ approach mandated under REACH still applies; however, the situation for nanoforms can be complex because of confidentiality requirements. Individual registrants will often use specific surface treatments to alter particle characteristics and these may be confidential, so sharing this information may infringe intellectual property rights. It is still necessary to work with other registrants to enable dossier update/creation, so all registrants need to explore this carefully. If you have a substance that is registered under REACH and you suspect it may contain nanoforms, you will need to confirm this. A useful approach is to ask these questions: ▶▶ Is the substance a solid or a liquid? ▶▶ Does the substance consist of particles or aggregates/ agglomerates of particles that have an external dimension between 1nm and 100nm? ▶▶ Does the particle size distribution data indicate the possibility of nanoparticles (>50% having a diameter below 100nm? ▶▶ What is the particle shape (e.g. sphere, cube, tube, wire, plate)? THE NEXT STEPS FOR JOINT REGISTRANTS REQUIREMENTS AND TIMINGS If the substance is confirmed to be a nanomaterial you will need to fully identify and characterize it and update your dossier in line with the new regulatory requirements. For many registrants, the biggest challenge will be the correct characterization of nanoforms. Fortunately, ECHA have published a best practice guide for the characterization of nanomaterials for REACH. This helpful document suggests the use electron microscopy, dynamic light scattering and X-ray scattering methods to determine particle size. For surface area it is recommended to measure the gas adsorption isotherm of the substance microscopy to determine particle shape. When carrying the latter measurements, it is noted that sample preparation is very important because the method used can affect results significantly (e.g. sonication versus dispersion) and because size is method dependent, no single method is perfect, and the use of multiple methods is preferable. Finding a laboratory that understands the relevance from a regulatory perspective and has the scientific capability to run the particle characterization tests and interpret the results is crucial.
  • 18. 18 NANOPARTICLES If you have many nanoforms, you need to group them into sets of similar nanoforms on the basis of scientific arguments that can be justified to ECHA. The ECHA guidance document on quantitative structure–activity relationships (QSAR) and grouping has good information on how best to tackle this.8 Optimizing the grouping means that you can then also use read-across to address endpoints required for hazard assessment, which could obviously reduce the need for costly additional studies. Finally, Regulation 2018/1881 requires manufacturers and importers to assess, and where relevant, generate the necessary information and document in the chemical safety report that the risks, arising from the identified uses of the substance with nanoforms they manufacture or import, are adequately controlled. MAIN CONSIDERATIONS: ▶▶ Determine rate of dissolution in addition to water solubility testing ▶▶ Determine dispersion stability in octanol and water where determination of the octanol-water partition coefficient is not possible ▶▶ Review any QSAR determinations that use as input experimental values for water solubility and octanol-water partition coefficient and consider using dissolution rate instead ▶▶ Provide information on dustiness ▶▶ Consider one or more in vitro mutagenicity study(ies) for substances registered at 1-10tpa, in addition to the standard data requirement for bacterial mutagenicity ▶▶ Bear in mind that for low volume substances (1-10ta), the inhalation exposure route may be more important than the standard requirement for oral exposure in acute toxicity ▶▶ Make sure sub chronic repeated dose tests carried out on nanomaterials via inhalation exposure include histopathological determination of brain and lung tissues as well as examination of bronchoalveolar lavage (BAL) fluid, kinetics and an appropriate recovery period ▶▶ Unless the nanoform dissolves quickly on entering the organism, the toxicokinetic assessment should be carried out on the nanoform in addition to the bulk substance ▶▶ For substance registered above 10tpa, specific relevant physicochemical properties may provide useful information on a case-by-case basis (e.g. agglomeration/aggregation state, surface morphology/ topography, crystallinity) ▶▶ Waivers should be reviewed to make sure nanoforms are addressed separately from bulk substance ▶▶ Ecotoxiological test and environmental tests for nanoforms, may not be waived on the basis of high insolubility in water alone. Annexes VII to X of the REACH Regulation (EC) No 1907/2006 will be amended to include these changes.
  • 19. 19 NANOPARTICLES The regulatory framework for nanomaterials is evolving, as the technology expands. New regulations exist under REACH that require the submission of additional data for nanoforms by January 1, 2020 for both currently registered substances and new substances. Crucially, these requirements apply to substances intentionally developed as nanomaterials, as well as those that may unintentionally contain nanomaterials by virtue of their formulation. SUMMARY The identification and characterization of specific nanoforms requires assessment of particle size distribution, particle shape and surface chemistry. By employing read-across and robust scientific arguments, it will be possible to categorize nanoforms into sets of similar nanoforms in order to simplify the assessment of hazard and risk.
  • 20. 20 NANOPARTICLES 1 EC definition of a nanomaterial (2011/696/EU). https://eur-lex. europa.eu/legal-content/EN/ TXT/?uri=CELEX:32011H0696 2 The Guardian. Nanotechnology is ancient history. April 24, 2012 www.theguardian.com/ nanotechnology-world/nanotechnology- is-ancient-history 3 EC amended REACH regulation to address nanoforms (2018/1881). https://eur-lex.europa.eu/legal-content/ EN/TXT/PDF/?uri=CELEX:32018 R1881&from=EN 4 EC, Joint Research Centre (JRC). An overview of concepts and terms used in the European Commission’s definition of nanomaterial. 2019 https://ec.europa.eu/jrc/en/ publication/eur-scientific-and-technical- research-reports/overview-concepts- and-terms-used-european- commissions-definition-nanomaterial USEFUL READING AND SOURCE MATERIAL 5 EC, Joint Research Centre (JRC). Requirements on the measurements for the implementation of the European Commission’s definition of the term ‘nanomaterial’. 2012 http://publications.jrc.ec.europa.eu/ repository/handle/JRC73260 6 Rasmussen et al. Developing OECD test guidelines for regulatory testing of nanomaterials to ensure mutual acceptance of test data. Regulatory Toxicology and Pharmacology 2019; 104: 74–83. www.sciencedirect.com/science/article/ pii/S0273230019300534?via%3Dihub 7 ECHA. How to prepare registration dossiers that cover nanoforms: best practices. Version 1.0 May 2017. https://echa.europa.eu/ documents/10162/13655/how_to_ register_nano_en.pdf/f8c046ec-f60b- 4349-492b-e915fd9e3ca0 8 ECHA. Guidance on information requirements and chemical safety assessment Appendix R.6-1 for nanomaterials applicable to the Guidance on QSARs and Grouping of Chemicals. Version 1.0 May 2017 https://echa.europa.eu/ documents/10162/23036412/appendix_ r6_nanomaterials_en.pdf ADDITIONAL ORGANIZATIONS NanoDefine is an EC funded project to develop measurements for the classification of nanomaterials www.nanodefine.eu/ European Union Observatory for Nanomaterials (EUON) provides information about existing nanomaterials on the EU market. It is funded by the EC and maintained by ECHA. https://euon.echa.europa.eu/
  • 21. 21 NANOPARTICLES Learn more about our chemical solutions at www.covance.com/chemical Covance is the drug, medical device and diagnostics business segment of LabCorp, a leading global life sciences company. COVANCE is a registered trademark and the marketing name for Covance Inc. and its subsidiaries around the world. The Americas +1.888.COVANCE (+1.888.268.2623) +1.609.452.4440 Europe/Africa +00.800.2682.2682 +44.1423.500888 Asia Pacific +800.6568.3000 +65.6.5686588 © Copyright 2019 Covance Inc. EBKCPC004-0919