regulation

The European Union is to make the labelling of nanomaterials in cosmetics mandatory according to Chemistry World.

The cosmetic regulation states that all ingredients present in the product in the form of nanomaterials should be clearly indicated in the list of ingredients, by inserting the word ‘nano’ in brackets after the ingredient listing. The ruling defines nanomaterial as ‘an insoluble or biopersistant and intentionally manufactured material with one or more external dimensions, or an internal structure, on the scale from 1 to 100 nm’.

As always, the devil is in the details and the detail in question is the definition. While one of the advantages of nanotechnology is that it allows you to control very tightly the size range of the particles that you are creating, top down technologies such as milling and grinding tend to produce particles with a wide range of different sizes, and while the mean size may be above 100nm, that does not mean that there will not be any sub 100 nm particles present. I suppose the definition of ‘intentionally manufactured’ is also open to question.

I have seen a number of ads recently for ‘chemical free’ cosmetics – which once again depends on whether you class tea tree oil and water as chemicals or not, and nanoparticle free cosmetics are a similar oxymoron. Depending on the production method used, the mean particle size could have to be as large as gravel in order to be even 99% nanoparticle free.

Germany has adopted the EU proposals with the caveat that

the general mention on labels of nano-scale materials in cosmetic products using the term “nano” might be misunderstood by consumers as a warning.’

While labelling may assuage some of the regulatory concerns, will the average consumer would be any more concerned with labelling the nanoparticle containing ingredients than they are with currently permissible constituents. Grabbing a bottle at random from my wife’s dresser I find a long list of ingredients such as Methyl Glucech-20, PEG-12 Dimethicone, and Polyquaternium-4, and I can’t really see that putting Hydroxyethyl cellulose dimethyl diallylammonium chloride copolymer (nano), or (C₈H₁₆N)_x^.xCl^.(C₂H₆O₂)_x (nano) would make much difference compared with the power of the cosmetic company’s marketing machine.

And that’s before I get into another debate with a polymer chemist about whether or not polymers are nanotech!

battle-between-lent-and-carnival Following on from the recent spat of name calling, there do seem to be opposing camps in the nanotech world, let’s call them the super optimists and the super pessimists.

The super optimists, and here I include the folks at Foresight, Institute of Molecular Manufacturing etc, tend to be people who spend a lot of time sitting in front of a computer but have little understanding of the wider world. Hence for them the path from reading Engines of Creation to terraforming Mars and curing all known disease is straight and clutter free.

The super pessimists on the other side tend to think dark gloomy thoughts about all kinds on things – I’m thinking of a number of NGO’s here – and use scare tactics to add two and two together to make 27.581 in the sense of taking pieces of real science and although failing to understand what the science actually means, conclusions are still drawn and regulation demanded.

Both groups tend to be somewhat idealistic and take a very black and white view of a world that is quite gloriously and defiantly Technicolour, as the rest us know only too well. I’m reminded of Peter Bruegel the Youngers 1559 painting “The Battle of Carnival and Lent” and its imagery still speak to us after almost four hundred and fifty years.

As a footnote about regulation, one of the rather simplistic views of nanotechnology is that if it can be regulated than that somehow makes the problem go away. Nothing could be more wrong – hazards are intrinsic and risks can be minimised but any regulation needs a system of policing to allow it to have any effect. The failure of various financial watchdogs on both sides of the Atlantic to spot the danger of highly leveraged investors or the actions of Bernie Madoff and Alan Stanford, through the recent tainted baby milk scandal in China to the failure of almost every ‘war on drugs’ shows how easy it is to set up a regulatory system, but how hard it is to have any effect on the real world.

Hydroxyethyl cellulose dimethyl diallylammonium chloride copolymer (nano) – Because I’m Worth It

Taking a Black & White View of a Technicolour World

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