Yes. Nanotechnology is not a carve-out and there is no separate regime for it in Great Britain: where an engineered nanomaterial is a substance hazardous to health used in or arising from work, the ordinary duties apply and the assessment is the ordinary assessment. What is different is the evidence. For most engineered nanomaterials there is no workplace exposure limit, the toxicology is thinner than for the same substance in bulk form, and the particle size that makes the material commercially interesting is the property that makes it behave differently in the lung. An assessment written for the bulk form of a substance is the wrong assessment for its nanoform, and that is the mistake this page is about.
Why it is in scope without being named
The definition of a substance hazardous to health is written by effect rather than by product list, and its final limb catches anything that creates a comparable hazard to health by its nature and the way it is used. A nanoparticle generated in a reactor, a nanofibre handled as a powder, and ultrafine particles thrown off by a process are all substances arising from the work. The absence of the word nanomaterial from the regulation is not an absence of duty; it is the reason the regulation was written that way in the first place.
The evidence gap, and what it should change
A substance that is well characterised in bulk can have a different hazard profile at the nanoscale, because surface area per unit mass rises sharply, some forms are biopersistent, and high-aspect-ratio nanofibres raise questions the bulk material never did. A safety data sheet written for the bulk form will often carry none of that. The right reading of a thin evidence base is that the uncertainty is a reason for a more precautionary control, not a reason to treat the hazard as unproven and therefore absent.
Controlling something you cannot compare to a published limit
Where there is no workplace exposure limit, adequate control cannot be demonstrated by measuring against one, so it has to be demonstrated by the hierarchy and by the integrity of the containment. In practice that means handling nanomaterials in a closed system or under local exhaust ventilation designed for fine particulate, keeping the quantity in the open as small as the work allows, preferring liquid suspensions and pastes over dry powders where the process permits, controlling cleaning and spillage so a settled powder is not re-entrained, and treating maintenance, filter changes and waste as exposures in their own right rather than as afterthoughts.
What the assessment has to record when the numbers do not exist
Name the nanoform specifically rather than the parent substance. Record what is known and, explicitly, what is not: no exposure limit, limited toxicological data, the form the material is handled in. Record the control chosen and the reason it was chosen given that uncertainty. Record the review trigger, because the evidence on these materials moves and an assessment written against a gap should be re-read when the gap closes. An assessment that simply omits the unknowns reads as though somebody checked and found nothing, which is the opposite of what happened.
Other questions people ask
Are nanomaterials and technology covered by COSHH?
Yes. Where an engineered nanomaterial is a substance hazardous to health used in or arising from work, the same duties apply as to any other such substance: assess, prevent exposure or adequately control it, maintain the controls, and review. There is no separate nanotechnology regime in Great Britain and no exemption for novel materials.
Does a safety data sheet for the bulk substance cover its nanoform?
Not reliably. Hazard information written for the bulk form may not reflect the behaviour of the same substance at the nanoscale, where surface area, particle shape and biopersistence can change the picture. Treat a bulk data sheet as a starting point and record in the assessment what it does not tell you.
How do you show adequate control with no workplace exposure limit?
By the hierarchy rather than by measurement against a limit: containment or enclosure first, local exhaust ventilation designed for fine particulate where enclosure is impossible, minimal quantities handled in the open, controlled cleaning and waste handling, and respiratory protection only as the last layer. Record the reasoning, because it is the reasoning that has to stand up rather than a number.