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SIN List criticism based on misunderstandings

Nature Nanotechnology volume 15, page 418 (2020)Cite this article

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To the Editor — The addition of carbon nanotubes (CNTs) to the SIN (‘Substitute It Now’) List by ChemSec1 made several nanomedicine researchers voice their critique2,3. We would hereby like to address some misunderstandings and better clarify our evaluation process as well as the scope and aim of the SIN List.

First, the SIN List is not based on risk assessment, but hazard identification. In the EU, chemical risk assessment is formalized and consists of hazard identification, dose-response assessment, exposure assessment and risk characterization. Hazard identification is related to the assessment of potential sources of harm that a substance has inherent capacity to cause4. In the Editorial that accompanied the Correspondences criticizing the inclusion of CNTs in the SIN List2,3, the terms ‘fair’ and ‘effective’ were used in relation to the risk assessment of CNTs5. However, the scope and aim of the SIN List is to predict the substances that will or should eventually be added to the Candidate List of Substances of Very High Concern (SVHCs) under the chemical legislation of the EU, known as REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals). Under REACH, these substances would then have to be evaluated for potential authorization or restriction depending on the outcome of a full risk assessment. Adding CNTs to the SIN List — or even to the REACH Candidate List of SVHCs — does not necessarily imply that CNTs will be banned from use in the EU, but it encourages substitution unless safe use can be assured, no alternatives are available or the benefit to society outweigh the risks. The intention of the SIN List is to limit broad and uncontrolled use of very hazardous chemicals. In other words, they should not be used unless risk assessment can prove safe use.

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Authors and Affiliations

  1. Technical University of Denmark, Department of Environmental Engineering, Kongens Lyngby, Denmark

    Steffen Foss Hansen

  2. ChemSec - The International Chemical Secretariat, Gothenburg, Sweden

    Anna Lennquist

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  1. Steffen Foss Hansen
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  2. Anna Lennquist
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Correspondence to Steffen Foss Hansen.

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Hansen, S.F., Lennquist, A. SIN List criticism based on misunderstandings. Nat. Nanotechnol. 15, 418 (2020). https://doi.org/10.1038/s41565-020-0692-7

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