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International Conference on Working Safely with Nanomaterials at the Royal College of Physicians - Edinburgh, 6 July 2012

Judith Hackitt CBE FREng, HSE Chair

First of all I must say a few thank yous - to The British Occupational Hygiene Society and the UK Nanosafety Partnership Group for inviting me to speak today at this International Conference on Working Safely with Nanomaterials.

But also thank you to all of you who are attending today, especially if you have stayed on after your attendance at X2012, the 7th International Conference on the Science of Exposure Assessment held earlier this week which has also covered nanotechnology along with other new technologies.

As a scientist - or more correctly an engineer - myself I have to say that I find the whole array of new technological developments which are taking place around us today fascinating and exciting.

When we consider the challenges which face our own and future generations on this planet there is no doubt at all that we need the very best of scientific and technological innovation to provide solutions in healthcare, medicine, energy, climate change, transport and just about every other aspect of the unsustainable way we live our lives today.

Nanomaterials have potential application in all of these fields but it is also important to remember that the technology of nanomaterials is not as novel as some people believe it to be.

They occur in nature, and, they find their way into the environment from vehicle emissions, and during the everyday processes of burning and cooking.  However, recent advances in technology allow us to manipulate atoms much more precisely and easily, leading to a huge expansion in the potential uses of, and a rapid rise in interest in this area of technology.  There are already many consumer products using nanoparticles commercially available worldwide.  These include titanium dioxide in paints, zinc oxide in sunscreen, stain-resistant coatings, self-cleaning glass, industrial lubricants, advanced tyres and semiconductors.

Nano-enabled pesticides and fertilisers are being developed, which exploit the increased active surface area of nanoparticles, enabling higher performance from using much lower quantities. Many more applications are in the pipeline, ranging from targeted drug delivery and gene therapy, to energy storage devices.  Most drivers are completely unaware that they are driving vehicles which use Cerium nanoparticles as a diesel fuel additive to achieve fuel efficiencies and reduce emissions by 90%.

So is this evolution or revolution?

Are those at the forefront of developing these technologies able to identify and manage the risks which may exist?

And how do we ensure that risk management enables innovation and development to continue to take place rather than acting as an obstacle?

These are questions which we seek to answer in HSE in order to determine our approach to dealing with new and developing technologies.  It is not unique to nanomaterials.  We adopt the same approach when considering how to regulate and work with those in new and emerging energy technologies such as carbon capture and storage.

In many cases we will be involved in considering how we regulate technologies which may end up competing with one another for market share.  It is not for us to express views on the pros and cons of any particular route or process., nor for us to attempt to become experts in any/all of the growing number of fields of innovation.  But it is for HSE to ensure that risks are being identified, acknowledged and managed appropriately at every stage as all of these technologies develop.

HSE has taken an interest in the occupational use and the manufacture of ultrafine particles such as carbon black and titanium oxide for many years and a lot of the lessons learnt in these areas can be used and developed for application to nanomaterials.

But we see our role as one of enabling business to develop and grow while seeking to influence at an early stage the consideration of health and safety issues in the development and introduction of new technologies.  We all recognise that there are many benefits offered by nanotechnologies and that understanding and managing the risks posed by these materials is vital to enable them to be developed to their full potential.

HSE believes that effective risk management should be about taking practical steps to protect people from real harm.  Our approach is to seek a balance between the unachievable aim of absolute safety and the kind of poor management of risk that damages lives and the economy. Primarily the level of health and safety achieved in the sphere of new technologies will be determined by how well those creating the risks recognise, manage and control them.

Another important aspect of our non-expert involvement is to help those developing and deploying new technologies to identify and implement appropriate management and control measures. This is turn then enables us to play a further important role in providing public reassurance that these risks are being properly controlled.  Building public confidence in new technologies is an important responsibility which we take seriously and we know we play a significant role in that.

On a much broader front, HSE is currently reviewing all of its guidance to ensure it represents a practical and proportionate approach that helps organisations understand and comply with health and safety law.

There are a number of internal and external drivers to the review of guidance:

As part of this review HSE has looked at its existing guidance in relation to nanotechnology and has decided that it needs to be updated and revised.  But it is important that we recognise the distinct difference between the guidance that HSE will produce and that which has already been produced by the UK Nanosafety Partnership Group.  HSE’s 'new' guidance will be based on the generic principles of COSHH and good control practice and will include information on a range of nanomaterials at various stages of development and commercial production. This publication will be aimed at employers, health and safety managers in manufacturing, and relevant SMEs.

We are of course working hard to maintain an appropriate level of knowledge as developments take place in nanotechnology.  The Health and Safety Laboratory (HSL), has been developing in-house expertise and is playing an important part in HSE’s research work.  EU-wide research networks have been established and HSE has supported numerous projects, including the Nanodevice Project which many of you will be familiar with.  Nanodevice is an EU project aimed at developing innovative concepts and reliable methods for characterising nanomaterials in workplace air with novel, portable and easy-to-use devices suitable for use in the workplaces.

But those of you here who know HSE well will also now that we believe in improving health and safety through partnership working.  We have developed good links with Occupational Health and Safety professionals in the Higher Education sector.  And it is clear from these contacts that the increase in research using all types of nanomaterials has led to a feeling that in some areas there was insufficient health and safety guidance available for them to advise researchers and employees appropriately.  The Universities Safety and Health Association, (USHA) formed the UK Nano Forum to develop specific guidance aimed at research and higher education.  Since its formation, membership has grown to include The Institute of Occupational Safety and Health (IOSH) and Institute of Safety in Research and Technology (ISTR) the British Occupational Hygiene Society (BOHS), the Institute of Occupational Medicine (IOM), and the HSE’s own Health and Safety Laboratories (HSL); What is now the UK Nanosafety Partnership Group, has produced guidance specifically aimed at research establishments and academia; HSE is very happy to endorse this guidance.  We believe that the existence of this specific guidance alongside our own more generic guidance, once published, will be complementary.

Other speakers will provide more detail on the status of both sets of guidance later on today.

HSE actively engages with companies, trade bodies and others, across all sectors which we regulate, encouraging them to take the lead in setting standards and generating industry/sector specific guidance.  Successful projects are based on organisations working in partnership to generate and improve collaboration between employers and workers, particularly in small firms.  Partnership brings together key players in workplace health and safety who are "part of the solution". The UK Nanosafety Partnership Group brings together key experts in the nanotechnology field and helps to establish links with others who have interests in this field.  We very much hope to see the UK Nanosafety group continue in the future and expand to include industry representation.

Nanotechnology is already a global business with large-scale exploitation of UK developed innovations taking place outside the UK/EU.  There is increasing pressure from some member states within the EU to introduce specific legislation to deal with nanotechnology.  However HSE starts from a position of believing that the existing UK regulatory framework for occupational health and safety, (the Health and Safety at Work etc Act 1974 and the Control of Substances Hazardous to Health Regulations (COSHH) 2002) is sufficient to cover the safe use and handling of manufactured nanomaterials.  But, where nanomaterials have an uncertain or not clearly defined toxicology and where sound evidence is not available on the hazards, HSE would expect duty holders to adopt a precautionary approach in order to comply with their legal obligations.  HSE will remain vigilant and if new evidence emerges that shows that the current framework does not meet requirements and provide sufficient safeguards we will take steps to address that.

HSE has an important role in relation to the Registration, Evaluation and Authorisation of Chemicals (REACH) Regulations and while Defra takes the lead on REACH policy, HSE is the UK REACH Competent Authority. REACH provides a single regulatory framework for the control of chemicals and ensures information on the properties of chemicals is transmitted down the supply chain thus enabling them to be handled safely.  Nanomaterials are included in principle within the scope of REACH.  However, having been closely involved personally in the development of REACH from its earliest green paper days, I know that many aspects of REACH were not designed with nanomaterials front and centre in anyone's mind.  This is already leading to some implementation issues and some changes to the REACH legislation may be necessary to regulate nanomaterials as effectively as possible.  HSE is participating  in these discussions.

Cooperation between regulators and Government is important in any area where there are cross cutting responsibilities and implications.  HSE works with other Government Departments and agencies to provide a 'cross government' approach to nanotechnologies that reflects the Government’s agenda.  The Science Minister, David Willets, and Defra's Minister, Lord Taylor of Holbeach, have recently agreed a structure for the Government's engagement with stakeholders in the area of nanotechnology.  They held a Nanotechnologies Roundtable last Autumn, which highlighted the need for leadership by Government; a more joined up approach across Departments; and a need for government and business to work together to develop a forward thinking, innovation-focused strategic approach.

The new arrangements include a new Nanotechnologies Strategy Forum (NSF), chaired by Ministers, which will meet twice a year; with a Strategic Policy Officials Group to take forward actions at the working level.  The Nanotechnologies Strategy Forum is intended to facilitate balanced discussion between by industry, regulators, researchers and consumers on the opportunities and risks that come with nanotechnology.  Forums like this are a tried and tested Government mechanism for bringing a wide range of stakeholders together in areas of new and emerging technology – HSE also participates in similar forums on Nuclear development and on Carbon Capture and Storage.  Forum discussions and comments are a matter of public record but are not attributed to individuals.

There are still some knowledge gaps in relation to nanomaterials that need to be addressed. Key facts such as:

This information is needed to inform regulators’ understanding of the UK workforce, so that a sensible risk-based approach to the regulation of these new materials can continue to be developed and supported under the existing regulatory framework.

HSE developed a survey form, which the UK Nanosafety Partnership Group administered on our behalf to all universities in the UK and the response was encouraging. We are gaining a better understanding on how the use of nanotechnologies in research and in universities is developing and how well the UK universities are controlling nanotechnology and I would like to take this opportunity to thank those involved for their cooperation.

There is no doubt that we are on a journey in the development and safe management of the many and various applications of nano technologies.  It is very encouraging to see the way that partnership working and recognition of respective roles and responsibilities has brought us this far.  But this is a staging post on the journey, not the destination, and we will need to continue to work in partnership and grow our networks.  We need to share information and learning and best practice. Events such as this conference today are very important and I am sure that there will be need for similar events in the future.  It's important that we all show leadership in taking forward our respective contributions to achieve safe working with nanomaterials.

I am certainly looking forward to hearing the presentations today and I hope you all find the conference valuable.

Updated 2012-07-19