Late last year ChemSec added carbon nanotubes to the SIN List, thereby suggesting that nanomaterials should be identified as Substances of Very High Concern (SVHCs) for the first time.
After having described our methodology behind this move in the scientific journal “Nature Nanotechnology”, two critical opinion pieces and one editorial appeared in the next volume.
The title of the editorial – The risks of nanomaterial risk assessment – itself reveals that the critique is based on a misunderstanding, which in its defense, is a common and frequent misunderstanding.
The SIN List, like its blueprint the REACH Candidate List, adds substances based solely on their intrinsic properties. It is hazard-based, and thus no risk assessment has been performed.