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Carbon nanotubes Risks and Regulations

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  • pg 1
									           Institute of Technology Assessment
          of the Austrian Academy of Sciences                                                               No. 024en • February 2012




       René Fries, Sabine Greßler,
                                                Carbon nanotubes – Part II:
                    Myrtill Simkó*              Risks and Regulations


Summary                                         Introduction                                    cancer and or mesothelioma (connective-
                                                                                                tissue tumours of the pleura or protective
Carbon nanotubes (CNTs) can be in-              The use of carbon nanotubes (CNTs) in en-       lining around the lung). The latter are not
haled and thus deposited in the lungs.          gineering or medicine raises great hopes        necessarily malignant. They develop when
Studies have shown that specific CNTs,          for innovative applications and, conse-         macrophages (phagocytic cell) try to ab-
namely those that are long (10-20 µm),          quently, considerable economic potential        sorb the needle-shaped asbestos fibres but
thin (5-10 nm), needle-shaped and non-          (also see dossier no. 022en). Conversely,       fail to do so because these are too long.
soluble (biopersistent), can promote the        there are justified concerns that the use of    This gives rise to the development of so-
formation of lung diseases and show be-         CNTs could have negative impacts on hu-         called giant cells produced by several cells
haviour similar to that of asbestos fibres.     man health and the ecosystem. Some of           fusing into one in order to be able to in-
Short or long fibres that are not needle-       these health impacts can be avoided by          gest the fibres. The chronic activation of
shaped will not, however, induce inflam-        avoiding specific CNTs. Difficulties also ex-   these giant cells (a permanent attempt to
matory changes, no more than a single           ist with a view to detection procedures and     digest the fibres) leads to nodular new tis-
carbon particle would. Comprehensive            measurement methods. At present, there          sue formation, so-called granuloma, which
life-cycle analyses regarding the poten-        is no reliable technology to conduct meas-      may develop into a mesothelioma with a
tial environmental benefits arising from        urements of CNTs concentrations and their       long latency period of 30 to 40 years. This
the use of CNTs (such as resource sav-          analysis at the same time, to be applied        may be due to the fact that the fibres move
ings owing to more light-weight mate-           for instance in the workplace. This state-      very slowly from the inside of the lung to
rials) are not available to date. At pres-      ment is, however, true for most hazardous       the peritoneum3 and cannot be broken
ent, the production of CNTs still requires      substances. This dossier provides an            down by the body during this time.
a high energy input, which offsets any          overview of potential risks CNTs might pose     It must be underlined that CNTs exist in
potential environmental benefits. Their         for health and environment, as well as in-      great diversity, and their biological impact
high reactivity and ability to transport        formation about ongoing regulation activ-       depends on their shape. It is assumed that
other substances raises concerns about          ities.                                          CNTs that look like asbestos fibres will al-
a possible ecotoxicity of CNTs. The da-                                                         so behave similarly to asbestos in the lung.
ta available are still restricted in scope,                                                     In order to verify that assumption, most in-
and the discussion of results is contro-                                                        vestigations involve inhalation studies on
versial. Given the lack of reliable data                                                        animals (in vivo, mostly using rats or mice).
on exposure, an adequate assessment             Toxicity                                        The animals are either exposed to CNTs
of health and/or environmental risks is                                                         and inhale them through the nose, or the
not possible for the time being.                In the first decade after the discovery of      fibres are applied directly to the lung or tho-
At present, specific regulations for CNTs       CNTs1, potential negative health impacts        rax (by instillation).
or other nanomaterials exist neither in         were not studied closely – mostly due to the
                                                                                                One research team, for instance, found
the laws governing chemicals nor in reg-        fact that the production methods available
                                                                                                that intraperitoneal injection of long (ca.
ulations for occupational health and            at the time only allowed researchers to pro-
                                                                                                20 µm) needle-shaped nanotubes result-
safety. Hence, the relevant authorities         duce CNTs at laboratory scale and high
                                                                                                ed in chronic inflammation, but there was
recommend that the precautionary prin-          cost2. Around the turn of the millennium,
                                                                                                little or no such effect caused by short nee-
ciple should be applied and measures            when new methods (chemical vapour dep-
                                                                                                dle-shaped, or by curved and long and
taken to avoid exposure or keep it as low       osition at reduced pressure) made it pos-
                                                                                                curved nanotubes. Since these nanotubes
as possible.                                    sible to produce larger quantities of CNTs
                                                                                                resemble asbestos fibres as regards their
                                                on an industrial scale, the health impact
                                                                                                properties (shape, length and solubility), a
                                                of this material was increasingly studied
                                                                                                comparable response to exposure was dis-
                                                through toxicological investigations.
                                                                                                cussed. The study deliberately used nano-
                                                It was the similarity of CNTs to asbestos fi-   tubes similar in shape and length to as-
                                                bres regarding their shape and persisten-       bestos fibres, as well as differently shaped
                                                cy that triggered first health warnings, for    ones for comparison. The results show that
                                                it is known that the handling of various as-    high concentrations (50 µg/per mouse,
                                                bestos materials can elicit inflammatory re-    with the weight of a mouse being ca. 20 g)
                     * Corresponding author     actions in the lung that may result in lung     and long and needle-shaped nanotubes




                                                                   1
                                                                                                                    No. 024en • February 2012




can elicit chronic inflammation (granulo-          term studies with CNT exposure under re-            An overview published in 201017 provides
ma)4, whereas short and/or curved nano-            alistic conditions are still lacking.               a summary assessment on CNT toxicity. The
tubes do not. A similar study was conduct-                                                             study particularly mentions the risks for
                                                   How will CNTs behave when they enter the
ed with long and thick SWCNTs (single-                                                                 people with occupational exposure to CNTs
                                                   body through the mouth? There is only one
walled CNTs) and MWCNTs (multi-walled                                                                  and confirmed the generally agreed hypoth-
                                                   study on the acute toxicity of orally ingest-
CNTs) in mice. The strongest response was                                                              esis that very specific types of CNTs, name-
                                                   ed SWCNTs11. In the study, mice were ad-
elicited by long and rigid as well as thick and                                                        ly long, thin, needle-shaped, and biopersis-
                                                   ministered single doses of 1000 mg/kg body
rigid MWCNTs, whereas short and thin, as                                                               tent CNTs, can have pathological effects
                                                   weight of three types of SWCNTs: SWCNTs
well as flexible SWCNTs hardly triggered in-                                                           comparable to those triggered by asbestos
                                                   (1 nm × 1-2 µm, 25 % Fe, metal impurities),
flammation5.                                                                                           fibres.
                                                   purified SWCNTs (1 nm × 1-2 µm, < 4 % Fe)
It is also known that the surface properties       and ultra-short SWCNTs (1 nm × 20-80 nm,
of nanoparticles can have an influence on          < 1.5 % Fe). Despite the high concentrations
their biological effectiveness. It was shown,      and the different CNT types, no toxic effect
for instance, that water-soluble SWCNTs in-        was observed after 14 days.
jected into mice (up to 400 µg/mouse) are
                                                                                                       Environmental Impact
                                                   In-vitro studies (experiments on cell cultures)
quickly excreted through the kidneys with a
                                                   also demonstrate potential risks and the            Processes and products that involve nano-
half-life of three hours6. Another research
                                                   mode of action of substances such as CNTs,          technology harbour some promise, includ-
group presented similar results, whereby
                                                   but do not realistically reflect the in-vivo sit-   ing that of environmental benefits, for in-
chemically altered (hydroxylated) SWCNTs
                                                   uation. There is a large number of in-vitro         stance by saving raw materials and energy.
were quickly distributed in the body regard-
                                                   studies, using different cell systems, CNTs,        In the future, construction parts made from
less of the form of application (injected in-
                                                   concentrations and functionalization (surface       CNT-optimised plastics for vehicles or air-
travenously, subcutaneously or into the ab-
                                                   modifications), in order to reveal mecha-           craft may decrease fuel consumption be-
dominal cavity) and were eliminated just as
                                                   nisms or study changes in the genetic sub-          cause of their lighter weight. CNTs may al-
quickly through urine7. This means that non-
                                                   stance, i.e. the genotoxic potential of CNTs.       so improve the thermal and mechanical
biopersistent CNTs can easily be processed
                                                   Standard and modified in-vitro tests were al-       properties of plastics and make them in-
by the body.
                                                   so carried out to investigate possible posi-        creasingly competitive with metals18. Exist-
After a single aspiration exposure of mice         tive effects and their mechanisms. Genotox-         ing studies, however, assess environmental
to highly concentrated (30 mg/m3) MWC-             ic effects can take either a primary route by       benefits mainly in qualitative terms, and there
NTs (0.5 to 50 µm), it was shown that the          direct contact with the DNA or a secondary          are only a few isolated life-cycle analyses
particles penetrate to the subpleural region,      route through inflammatory reactions such           (LCAs). What is usually lacking in descrip-
i.e. under the protective lining of the thoracic   as the formation of reactive oxygen species         tions of the environmental benefits of nano-
cavity. At lower concentrations (1 mg/m3)          (ROS) (see 12). It has been shown that both         technology products and applications are
such effects were not observed8. Another           are possible, depending on the purity of            analyses and assessments of the resource
study9 corroborated these results and found        CNTs administered. The production of CNTs           and energy input required for their produc-
that aspired MWCNTs (ca. 4 µm, 10-80 µg            gives rise to metal by-products that may in-        tion. Environmental organisations are con-
per mouse) reached the pleura after 56 days        duce or increase an effect. As contradicto-         cerned that the benefits claimed may be ex-
and elicited an inflammatory response there.       ry results have been described depending on         aggerated and warn that the new technol-
These insights are of major significance,          the biological system, the genotoxic poten-         ogy may even involve higher energy-relat-
since pathogenic fibres (such as asbestos) are     tial of CNTs in vitro has not been conclusive-      ed and environmental costs18. CNT produc-
known to induce diseases such as mesothe-          ly determined to date (for comprehensive            tion does indeed require a great deal of en-
lioma particularly in the pleural cavity.          overviews see 5; 13-15).                            ergy – first estimates speak of 0.1 to 1.0 TJ
                                                                                                       (terajoule) per kilogramme19. One TJ cor-
It must be noted, however, that the concen-        Because of their very small mass and dimen-
                                                                                                       responds approximately to the amount of en-
trations used in animal testing are extreme-       sions, CNTs can remain suspended in am-
                                                                                                       ergy supplied by 167 barrels of oil (ca.
ly high in order to elucidate the biological       bient air for a long time and, when inhaled,
                                                                                                       26550 litres)19. This would make CNTs one
response mechanisms and, thus, the impact          reach even the tiniest ramifications of the
                                                                                                       of the most energy-intensive materials
of nanoparticles. In one of the above stud-        lungs. There is very little information about
                                                                                                       known. Production methods differ, howev-
ies, each of the mice inhaled 30 mg MW-            whether CNTs can be degraded in a biolog-
                                                                                                       er, with respect to their energy consumption,
CNTs per m3 air. For an average human be-          ical environment – that is to say under nat-
ing with a body weight of 70 kg this would         ural conditions. A research team described
correspond to approx. 100 g per m3 air. As         that SWCNTs can be degraded (in vitro) with
CNTs are very light-weight, 100 g would            the help of natural enzymes16. It remains to         Forms of
have a volume of almost 700 ml10. Hence,           be clarified whether and how fast CNTs de-           carbon –
30 mg of CNTs per cubic metre of air is a          grade, since this would also supply impor-           name of
very large amount for a mouse that weighs          tant information about their bio-availabili-         substance           EC No.       CAS No.
ca. 20 g. While such tests are very impor-         ty. As CNTs can have pathological effects            Carbon            231-153-3      7440-44-0
tant, the data are still preliminary and the       over a long term, these data are of great sig-
results only show short-term effects. Long-        nificance.                                           Carbon Black      215-609-9      1330-86-4

                                                                                                        Graphite          231-955-3      7782-42-5

                                                                                                        Fullerene C60          –        99685-96-8
                    Table 1: EC and CAS (Chemical Abstracts Service) registration numbers of
                                                        carbon-based nano-scale materials               CNTs                   –             –



                                                                          2
                                                                                                                         No. 024en • February 2012




                                            Table 2: Selected countries and their CNT regulations          surfaces of CNTs are often functionalised (for
                                                                                                           instance with chemical compounds or by coat-
 Country      Regulations on nanomaterials – and specifically on CNTs                        Sources       ing), which may increase their stability in wa-
                                                                                                           ter systems and influence both their environ-
 EU           •   No nano-specific requirements at present                                       33; 34
                                                                                                           mental behaviour and their toxicity22.
              •   As of the entry into force of REACH in 2008, the precautionary                    35

                  principle has had to be applied and all chemicals exceeding 1 JT                         The identification of potential environmen-
                  require registration with the relevant EU authority (ECHA) prior to use                  tal risks indispensably requires data on ex-
                                                                                                           posure, which do not exist for the time be-
              •   In principle, “chemical equivalents” of substances already registered
                  do not require re-registration                                                           ing. An estimate for 2007/08 assumes a
                                                                                                           worldwide production volume of not more
              Demands for changes                                                                          than 500 t23. A lack of information on prod-
              •   EU-Parliament demands that all nanomaterials be treated as new                    26
                                                                                                           ucts containing CNTs makes estimates of that
                  substances, as well as an overview of all nanomaterials in use and                       kind extremely difficult. Given the fact that
                  regulatory evaluation by the EU Commission before 2012                                   CNTs in consumer products are mainly in-
              First new requirements                                                                       corporated in a substrate (e.g. plastics), the
              •   The exemption status of carbon was removed in 2008 with an explicit                      authors of that study see the probability of
                  reference to nano-risks                                                                  a possible release into the environment as
                                                                                                           being less during its service life than during
              •   At international level, Fullerenes C60 have already been recognised
                  as having specific properties which merit separate CAS registration                      disposal by waste incineration. As the com-
                                                                                                           bustion temperatures of incinerators are
              •   This is not yet the case for CNTs
                                                                                                           higher than the ignition temperature of
 USA          •   Previously: voluntary submission of information on nano-substances;            36; 37    CNTs, they should theoretically burn up com-
                  only few companies responded                                                             pletely. It is still possible to envisage scenar-
                                                                                                           ios, however, where CNTs would survive the
              New regulation
                                                                                                           incineration process. In such a case, estimates
              •   Since 2010, SWCNTs and MWCNTs have been subject to strict
                                                                                                           say that about 0.1 % of the total quantity of
                  notification requirements within the context of the Toxical Substances
                                                                                                           CNTs will not be captured by filters and might
                  Control Act. Their manufacture, import or use (also as a continuation
                  of ongoing activities) requires notification                                             be released into the environment. Another
                                                                                                           study assesses current environmental con-
 Australia    •   Previously: voluntary submission of information on nano-substances                38     centrations of CNTs in Europe and the USA
                                                                                                           as too little to constitute any risk24.
              New regulation
              •   SWCNTs and MWCNTs are new chemicals
              •   Pre-import authorisation required under the Industrial Chemicals
                  Notification & Assessment Act 1989
                                                                                                           Regulatory Issues and
              •   Details of the new regulation will be decided in 2011
                                                                                                           Health and Safety at the
 Japan        •   Up until now: discussion rounds and considerations as well as                     38

                  recommendations on CNT limits for occupational exposure                                  Workplace
                                                                                                           In the European Union, nanomaterials are
which leads experts to expect that techno-            scope, the respective organs showed black            covered by the REACH (Registration, Evalu-
logical progress and the development in pro-          CNT agglomerations21. To date, an analysis           ation and Authorisation of Chemicals) regime
duction processes will lower the energy in-           of marine organisms or ecosystems has not            for chemicals. REACH has a central database
put required.                                         been conducted22, but it is known that a             that registers all chemicals produced or im-
                                                      number of methodological problems exist in           ported in the EU in quantities of one tonne
Their high reactivity and ability to transport
                                                      determining the toxicological profile of             per year or more per manufacturer or im-
other substances has raised concerns about
                                                      CNTs. For examinations, CNTs need to be              porter. A chemical safety report needs to be
a possible ecotoxicity of CNTs. The data
                                                      dissolved in water. Due to their poor solubil-       submitted only if the quantity is ten tonnes
available are still restricted in scope, and the
                                                      ity, scientist use different methods and chem-       or more. REACH has often been criticised for
discussion of results is controversial. Rain-
                                                      ical solvents which may, in turn, influence the      failing to take sufficient account of nano-spe-
bow trout (oncorhynchus mykiss), for instance,
                                                      test results. In addition, as has already been       cific properties25. In principle, substances that
were exposed to high SWCNT concentrations
                                                      emphasised, CNTs manifest great diversity,           seem to be of particular concern can be sub-
(0.1; 0.25 or 0.5 mg per litre of water) for
                                                      with differences in structure, size distribution,    ject to restrictions under Art. 57 of REACH. Be-
up to ten days. After this period, the fish
                                                      surface chemistry and charge, agglomera-             fore the European Chemicals Agency (ECHA)
showed pathological modifications of their
                                                      tion behaviour and purity. These differences         can apply such restrictions, however, a com-
gills as a function of the dosage20. Larvae
                                                      have a decisive impact on their reactivity and,      prehensive procedure of comments and con-
of the African clawed frog (Xenopus laevis)
                                                      thus, also on their toxicity. Another critical is-   sultation must be conducted and the approval
were exposed to a concentration of 10 to
                                                      sue is the often unrealistically high dosages        of the Member State Committee sought. In
500 mg of double-walled CNTs per litre of
                                                      used in ecotoxicity tests. Given their prop-         the summer of 2010, ECHA published a new
water. Acute toxicity was found in all concen-
                                                      erties, CNTs would be expected to agglom-            Candidate List of Substances of Very High
trations giving rise to a blocking of the gills
                                                      erate (bunch together) and sediment (settle)         Concern (SVHC) with almost forty substances
and/or digestive tract. Under the micro-
                                                      in the water. In ecotoxicity tests, however, the     – none of them a nanomaterial. Owing to



                                                                              3
                                                                                                                           No. 024en • February 2012




the high quantity thresholds of the regime          able only for a few types of CNTs (see above),
– a tonne per year or more for registration         health and safety and risk-minimisation                 Conclusions
and ten tonnes per year or more for the             measures should be guided by the precau-                There are indications that high concentra-
mandatory submission of a chemical safe-            tionary principle and apply to all types of             tions of very specifically structured CNTs
ty report – many nano-scale chemicals are           CNT materials. To the extent that the han-              (needle-shaped, long, thin, biopersistent)
not subject to any registration.                    dling of CNTs cannot be avoided entirely, a             have an adverse pulmonary effect. In or-
                                                    high level of protection and control needs              der to make meaningful statements on the
Chemicals legislation in the EU and in the
                                                    to be ensured28. When the British Standards             risk involved, the mechanisms of action
USA (TSCA; Toxic Substances Control Act) us-
                                                    Institution (BSI) submitted a draft standard,           and dose-effect ratio have to be clarified.
es as its defining criterion exclusively the
                                                    HSE pointed out the particular difficulties in-         To avoid potential risks, the recommenda-
“molecular identity” of a substance, i.e. its
                                                    volved in measuring the extremely thin and              tion of many publications – endorsed by
chemical composition, but does not take the
                                                    light-weight CNT materials. The BSI pro-                this dossier – is to avoid contaminations
particle size or nano-specific properties in-
                                                    posed an exposure limit of 0.01 fibres/ml,              with and, if possible, the use of pathogen-
to account. That this is a problem has be-
                                                    but very time-consuming investigations by               ic needle-shaped CNTs.
come particularly obvious in the regulation
                                                    electron microscope would be required to                Although CNT-optimized materials prom-
of carbon-based materials. In REACH, car-
                                                    monitor this limit.                                     ise environmental benefits through re-
bon was initially considered to be of no con-
cern (“minimum risk because of its intrinsic        In the USA, the National Institute for Occu-            source savings, a comprehensive life cy-
properties”). At the end of 2008, this exemp-       pational Safety and Health (NIOSH) propos-              cle analysis has yet to be conducted.
tion status was removed with an explicit ref-       es an occupational exposure limit of less than          Available data on CNT ecotoxicity are lim-
erence to the nano-scale forms of carbon26.         7 µg CNT per cubic metre of air. In compar-             ited and controversial. There is also a lack
In addition to carbon, carbon black and             ison, the exposure limit fixed by the EU Oc-            of reliable information on exposure that
graphite, C60-Fullerene was also given a            cupational Safety and Health Administration             would be required for environmental risk
separate CAS (Chemical Abstracts Service)           (EU-OSHA) for airborne graphite dust of                 assessment. Neither hazardous chemicals
registration number in line with internation-       5 mg/m3 represents about one thousand                   legislation nor occupational health and
al denomination standards for chemicals,            times as much carbon29. It must be empha-               safety regulations offer specific require-
since these materials were clearly different        sised, however, that dust particles are larg-           ments for the handling of CNTs. Although
from each other despite having the same             er and therefore heavier. The measurement               CNTs, like all other chemicals, are covered
molecular identity. For CNTs, this step has         method proposed by NIOSH is “method                     by the requirements of REACH, the vol-
not yet been taken (Table 1).                       5040” 30;31 which was developed in 1999                 ume-thresholds for registration (1 JT) and
                                                    for ultra-fine carbon dust. In this method, air         the mandatory chemical safety report (10
In contrast to the EU, the USA made CNTs                                                                    JT) have been set at levels that may not
                                                    is aspirated through a quartz filter and the
subject to strict notification requirements with-                                                           include all CNT manufacturers. In addi-
                                                    carbon precipitate captured by the filter is
in the context of the Toxic Substances Con-                                                                 tion, CNT-specific characteristics are not
                                                    measured with a thermal-optical analyser
trol Act in October 2010. Their manufacture,                                                                taken into account. In the field of occupa-
                                                    (EGA-evolved gas analysis). The proposed
import or use (also as a continuation of on-                                                                tional health and safety, efforts are under
                                                    exposure limit of 7 µg CNT per m3 of air is
going activities) has to be notified to the au-                                                             way at international level to fix limits for
                                                    the lowest concentration that can be accu-
thority, which has to decide within 90 days                                                                 occupational airborne CNT exposure.
                                                    rately measured32. Even this concentration
whether the substance may be imported or                                                                    Specific regulations have yet to be adopt-
                                                    is considered as representing an increased
processed. The only exception is granted to                                                                 ed. In addition, there is a significant need
                                                    risk of developing adverse respiratory health
CNTs firmly embedded in a matrix. (For an                                                                   for research and development in the field
                                                    effects by NIOSH. As the definition of a use-
overview of regulations for nanomaterials –                                                                 of analytical and detection methods. In or-
                                                    ful and effective occupational exposure lim-
particularly CNTs – in the EU, the USA and                                                                  der to protect employees, the relevant au-
                                                    it for CNT depends on data about exposure
Australia and Japan see Table 2.)                                                                           thorities suggest that the precautionary
                                                    and, thus, the measuring technology, it is in-
As regards health and safety at the work-           dispensable to promote research in this area.           principle be applied and exposure kept as
place, the EU has not adopted any nano-             Until such time as measurement methods are              low as possible.
specific regulations. The minimum require-          improved, efforts should be made to keep
ments as laid down by the relevant EU di-           airborne CNT to a minimum and below the
rective27 relate to the protection of the health    defined exposure level.                                 4   Poland, C. A., Duffin, R., Kinloch, I., Maynard,
and safety of workers without making explic-                                                                    A. D., Wallace, W. A. H., Seaton, A., Stone,
it mention of nanomaterials. Years ago, the                                                                     V., Brown, S., MacNee, W. and Donaldson, K.,
authority in charge of this issue in the UK –       Notes and References                                        2008, Carbon nanotubes introduced into the
the Health and Safety Executive (HSE) – al-                                                                     abdominal cavity of mice show asbestos-like
                                                     1   Iijima, S., 1991, Helical microtubules of graph-
ready made reference to the “10 Recom-                                                                          pathogenicity in a pilot study, Nature Nanotech-
                                                         itic carbon, Nature 354, 56-58.                        nology 3(7), 423-428.
mendations” concerning the application of            2   Ma-Hock, L., Treumann, S., Strauss, V., Brill,     5   Yamashita, K., Yoshioka, Y., Higashisaka, K.,
nanotechnologies published jointly by the                S., Luizi, F., Mertler, M., Wiench, K., Gamer,         Morishita, Y., Yoshida, T., Fujimura, M., Kaya-
Royal Society and the Royal Academy of En-               A. O., van Ravenzwaay, B. and Landsiedel, R.,          muro, H., Nabeshi, H., Yamashita, T., Nagano,
gineering25. In line with these recommenda-              2009, Inhalation toxicity of multiwall carbon          K., Abe, Y., Kamada, H., Kawai, Y., Mayumi,
tions, the HSE advises precautionary meas-               nanotubes in rats exposed for 3 months, Tox-           T., Yoshikawa, T., Itoh, N., Tsunoda, S.-i. and
ures and the avoidance of risks as far as pos-           icological Sciences 112(2), 468-481.                   Tsutsumi, Y., 2010, Carbon nanotubes elicit
sible. In a document from 2009, HSE viewed           3   Philbrick, M., 2010, An anticipatory gover-            DNA damage and inflammatory response rel-
CNTs as “substances of very high concern”.               nance approach to carbon nanotubes, Risk               ative to their size and shape, Inflammation
Even though detailed test results are avail-             Anal 30(11), 1708-22.                                  33(4), 276-80.




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                                                                                                                                     No. 024en • February 2012



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                                                                                                        No. 024en • February 2012




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