Each EU Member State will have a legal and regulatory
framework for dealing with remediation that may be driven by European
Directives (for example, the Industrial Emissions Directive) or national
legislation (for example planning, contaminated land legislation). A
nanoremediation project may involve engagement with a number of regulators, for
example to address:
- Chemical
classification, labelling and packaging
- Health
and safety
- Achieving
remediation objectives (for example, to return an installation to baseline
conditions (IED) or through planning conditions to support redevelopment)
- Control
of emissions (to air, land and water) from the remediation process
In general there will be a lead regulator for remediation,
depending on the circumstances and Member State. For example, in the UK for
remediation being carried out under planning the lead regulator will be the
local authority, consulting the Environment Agency on controlled water issues.
However, the regulation of the emissions from the remediation process will be
controlled through environmental permitting by the Environment Agency.
Each regulator will have different requirements, enforced
under different national legislation and will have a variable knowledge of in
situ remediation in general and nanoremediation in particular. It is
therefore recommended, when dealing with each regulator, to provide as much
relevant information as possible in a clear and concise format. In some cases,
for example permit applications, information may be required in a standard
format and guidance on how to complete an application will be provided by the
regulatory body. The regulatory framework should be sufficiently developed in
all or most Member States to accommodate the use of nanoparticles in
remediation.
Nanoremediation must comply with the same regulatory
requirements applying to any other substance being injected into the subsurface
as part of a remediation process; and the same health and safety requirements
for materials handling and use:
- Materials
and substances used in remediation must fully comply with prevailing
health and safety legislation, and public domain material safety sheets
are a prerequisite.
- Adequate
demonstration that the remediation being deployed will achieve the
necessary risk management goals for the purpose it is being used for. As
for all contaminated land management activities, effective use of
conceptual site models underpins reliable and robust decision making.
- Risk
management of any substance release, unreacted fractions and potential
by-products in the ground (including delivery, transport and change over
time) with respect to human health, ecological and environmental
risks/toxicity.
- Compliance
with REACH regulation with respect to production and marketing of (new)
substances. Note: Under REACH, the different forms
(solids, powders, nanomaterials, etc.) of the same substance can be
considered within a single registration of a substance. However, the
registrant must ensure the safety of all included forms and provide
adequate information to address the different forms in the registration,
including the chemical safety assessment and its conclusions, e.g. through
different classifications where appropriate (EC
2016).
At a European level nanoremediation is not seen as being a
special case from a regulatory standpoint.
However, given that there can be general public concerns over
nanotechnologies. NanoRem has carried out comprehensive ecological testing of a
range of NPs, sustainability assessments and risk-benefit analyses. Additionally, NanoRem has developed a
protocol for risk assessment of NP deployment in situ Other key outputs
include in depth reporting of field studies (described below) and field based
monitoring protocols. All of these
outputs are available from the NanoRem Tool Box (http://www.nanorem.eu/toolbox/index.aspx).
There are no specific generic sustainability advantages or
disadvantages to the use of nanoremediation.
As for all in situ remediation
work, sustainability is highly dependent on site specific factors, and all
technologies should be considered on their particular merits for any particular
site. With regard to eco-toxicological
aspects it was found that no significant
toxicological NP related effects were observed on soil and water organisms when
ecotoxicological test were undertaken using the NanoRem NPs (including with
respect to the particles’ interaction with contaminants and the resulting
products). However, toxicity was
detected from a process additive for one of the milled nZVI products, but this
may have been an anomaly. Field scale
observations detected transient perturbations in aquifers, attributed to
(intentional) pH and redox shifts resulting from NP introduction. Of course, NP injections were taking place
into already highly disturbed subsurface environments.
Further Information
Thematic Pages:
Related FAQs:
How safe is nanoremediation to use and what are the possible risks associated with it?
