“While technology is developing apace, we are not seeing the Commission adequately address the regulatory framework” stated Judith Kirton-Darling, ETUC Confederal Secretary responsible for health and safety. “The precautionary principle is fundamental to guaranteeing public and occupational health and safety – the Commission must take action to ensure it is at the centre of EU nanotechnology policy”, stressed Judith.
The Commission’s position demonstrates that nanotechnology development is still a new field, in which addressing safety concerns continue to present a challenge. Detecting nanomaterials is a difficult task and investigating exposure is even more complex. Since workers are potentially the most exposed to high levels of engineered nanoparticles, ETUC believes that occupational health and safety must remain a priority in the Community strategy.
Given this fact, the principle of ‘no data, no market’, as developed within the EU’s REACH legislation on chemicals must be applied to all nanomaterials. In case of uncertainty, the precautionary principle has to be applied and explained to workers.
The ETUC emphasizes that a comprehensive strategy on workers protection and occupational health and safety is needed to boost the real industrial benefits of nanotechnologies. The ETUC agrees with the Commission that more research is needed on safety aspects, reliable test methods and risk assessment.
In relation to job creation, the ETUC questions the statistics on the direct employment associated to nanotechnologies, which is estimated at 300,000 to 400,000 jobs in the EU. [[High Level Expert Group on ‘Key Enabling Technologies’ (2011) Final report http://ec.europa.eu/enterprise/sectors/ict/files/kets/hlg_report_final_en.pdf]] The original source that the Commission refers to does not disclose what methodological approach was used to reach these figures. Moreover, the estimate does not include structural changes in the job market. In addition to which the ETUC believes that many of the potential nanotechnology jobs may come from the commercialization of nanotechnology products.
To achieve a strong manufacturing industry as the Commission stresses, Europe needs adequate training and skills. The ETUC recalls that there is a lack of skilled labour capable of handling these highly multi-disciplinary technologies . [[EC (2012) Key enabling Technologies: A key to growth and jobs http://europa.eu/rapid/pressReleasesAction.do?reference=MEMO/12/484& ]] The Second Regulatory Review wholly lacks provisions on this essential aspect.
The ETUC also draws attention to the fact that the EC's Communication does not provide new elements that could clarify the regulatory situation and that existing gaps are still unaddressed. The ETUC expected the Commission to tackle the regulatory deficiencies underlined by the European Parliament in its Resolution of 2009 but the Commission has clearly failed to fulfill that expectation. Modifications of REACH are urgently needed to ensure the potential high risks of nanomaterials are properly controlled.