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Recommendations on a Revision of the EC Definition of Nanomaterial Based on Analytical Possibilities
(2015)
In October 2011 the European Commission (EC) published a "Recommendation on the definition of nanomaterial" (2011/696/EU), to promote consistency in the interpretation of the term "nanomaterial" for legislative and policy purposes in the EU. The EC NM Definition includes a commitment to its review in the light of experience and of scientific and technological developments. This review is ongoing in 2015 and as a contribution to the review the Joint Research Centre of the European Commission (JRC) has already developed a series of three scientific-technical reports with the title: “Towards a review of the EC Recommendation for a definition of the term nanomaterial” which provides to the EC policy services science-based options on how the definition could be revised or supported with additional guidance.
The overarching nature and wide scope of the EC NM Definition, as it does not exclude a priori any particulate material regardless the state, form and size, creates many analytical challenges in its imple-mentation for all stakeholders, including enterprises and regulators.
The NanoDefine project has as core objective to support the implementation of the EC NM Definition. In this report key aspects of the EC NM Definition are addressed, with the goal to improve the implement-ability of the EC NM Definition. These aspects are presented and discussed based on the results of two years of research performed within the framework of the project. As a result this report assesses how well the requirements of the EC NM Definition can be fulfilled with currently available analytical possi-bilities. It presents recommendations and options on a revision of the EC NM Definition to improve the implementability of the definition based on currently available analytical possibilities, according to the state of the art of mid-2015.
Of the technical issues considered in this report, the following seem to deserve the most attention in terms of clarification of the definition and/or provision of additional implementation guidance:
The term ‘external dimension’.
A clear definition of 'External dimension' should be included in the text of the EC NM definition and more precise guidance on what is considered as an external dimension and how to properly character-ise it should be provided.
The ‘number based particle size distribution‘.
The EC NM Definition uses a threshold related to the number based size distribution of particles. Yet most of the easily available techniques provide a mass-, volume- or scattered light intensity-based size distribution which needs to be converted into a number based distribution to be used for regulatory pur-poses. A specific guidance on the conditions under which these methods can be used to identify a na-nomaterial by employing appropriate quantity or metrics conversion should be provided.
The ‘polydispersity‘ and ‘upper size limit‘
Polydispersity is a challenge for the measurement of particle size distribution for the EC NM definition, specifically for materials with high polydispersity index and broad size distribution especially when the volume or mass of the fraction containing particles below 100 nm is very small. Therefore a dedicated guidance should be provided that allows applying an upper size limit in measurements and particle statistics.
Advances in scanning electron microscopy (SEM) enable the high-resolution imaging of single nanoparticles (NPs) with sizes well below 10 nm. The SEM analysis in transmission mode (T-SEM) of NPs on thin film supports has many benefits when compared to the analysis of NPs on bulk substrates. The enhanced material (mass - thickness) contrast of the T-SEM imaging mode is well suited for in-depth and, particularly valuable, to very accurate, traceable, lateral dimensional measurements of NPs. Compared to samples prepared on bulk substrates, T-SEM with energy dispersive X-ray spectroscopy (EDS) achieves a drastically improved spatial resolution of the emitted X-rays. The poor signal-to-noise ratio of the X-ray spectra emitted by a single nanoparticle (NP) can be improved by the use of high-sensitivity (high collection solid angle) silicon drift (SDD), energy-dispersive X-ray spectrometers (EDS). The EDS spectral imaging of a single NP with a spatial resolution below 10 nm has become possible. This is demonstrated by means of various examples of nanostructures. Advanced data processing of T-SEM/EDS results sets the stage for the automated classification of NPs by feature analysis. This method combines the detection of morphological structures of interest by image processing of T-SEM micrographs with the chemical classification by EDS.