Spotlighting CLH report for TiO2 : nano-safety perspective
At the European level, as with all other forms of chemicals, nanoparticles are regulated under the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) and Regulation, and the Classification and Labelling (CLP) Regulation. The CLP Regulation is based on the United Nations’ Globally Harmonised System (GHS) as a starting point for hazard communication. Nano-titanium dioxide (TiO2 nano) is one of the top five nanoparticles by production volume that have been used in various products. Its safety has been thoroughly studied in many EU sponsored nano-safety projects. The growing production of both pigment grade TiO2 (primary particles of 400–700 nm) and TiO2-nano (primary particles are <100 nm) as well as an abundance of safety reports resulted in the selection of TiO2 as a candidate for the Community Rolling Action Plan (CoRAP). In line with safety-evaluation activities, in May 2016, the French ANSES submitted the CLH report for TiO2 to the European Chemical Agency (ECHA). The ECHA’s Committee for Risk Assessment (RAC) suggested classifying TiO2 as a substance suspected of causing cancer through the inhalation route (category 2). In Europe, this proposal is currently undergoing the discussion and decision-making procedure, as prescribed by the CLP Regulation. The final decision of the TiO2 classification will be made by the European Commission. The aim of this paper is to explain the importance of including a scientific perspective when formulating CLP regulations. The expanding volume of scientific literature reveals that the complex nature of interactions between nanomaterials and organisms is unmanageable for decision-makers. Presenting scientific findings in simple and updateable summaries of evidence for the various interested parties could be the way forward.