Assessment of inhalation exposure to nano-objects and their aggolomerates and aggregates

Kemesta

2016299 CEN/TC 137

To whom it may concern,

The Central Organisation of Finnish Trade Unions SAK (Suomen Ammattiliittojen Keskusjärjestö SAK) considers that the draft standard prEN 17058 has been carefully prepared and is based on up-to-date knowledge of exposure to nano-objects in workplaces. SAK also considers that the various stages of the assessment of the exposure to nano-objects in workplaces have been described clearly and to sufficient detail. Different tiers in the exposure assessment process have been clearly defined and their meaning fully described. Their meaning in the decision making process has also been defined by using a decision-tree approach usually utilized in this context.

Different exposure assessment strategies have been described in sufficient detail. In addition to this, also the currently available on-line and off-line monitoring devices for assessing exposure to nano-objects, and their functional principles, have been clearly described. The description is based on state-of-the-art knowledge.

The draft standard prEn 17058 correctly notes that occupational exposure limits (OEL) for nano-objects, for engineered or those of environmental origin, do not exist anywhere at a national or international level. SAK considers that the development of such guidelines and regulations shall have a high priority in Finland, EU and internationally. More emphasis needs to be put on understanding the characteristics of nano-objects that are causally linked to their possible harmful effects. This would enable effective actions for the preparation and implementation of regulations to control exposure to nano-objects in workplaces.

The Central Organisation of Finnish Trade Unions SAK