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Nanoremediation: Information for Decision Makers from NanoRem

FAQ: What affects regulatory acceptance for nanoremediation?

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?

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Taking Nanotechnological Remediation Processes from Lab Scale to End User Applications for the Restoration of a Clean Environment.
This project has received funding from the European Union Seventh Framework Programme (FP7/2007-2013) under grant agreement No. 309517
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