Perspectives and interests in the construction of occupational health standards: the case of silver nanoparticles

Introduction: The regulation of chemical substances involves a difficult negotiation between social actors, and requires the articulation between scientific analysis and its conversion into a legal norm. Objective: The article addresses the discussion elicited by a public consultation on a voluntary regulation guide on silver nanoparticles (AgNP) in workplaces. It examines the comments made from 2016 to 2018 by diverse social actors - business representatives, non-governmental organizations (NGO) and independent researchers - to two successive draft versions of a Recommended Exposure Limit (REL) in working environments with AgNP. The REL is a voluntary guideline on permissible exposure limits elaborated by the NIOSH in the United States. A guideline of this kind combines scientific information with its legal adjustment. Method: The methodology used was a content analysis of the comments, structured upon a historical and sociotechnical contextualization of nanotechnologies carried out through literature review and documental analysis. Results: The article shows how different social actors position themselves in the controversy over the risks of nanosilver, revealing a pattern of behavior consistent with their position in the research, production and commercialization of this new nanomaterial. While a group of actors, aligned with the interests of AgNP producers, proposed the restriction of mandatory and AgNP-specific regulation, another group of more heterogeneous actors, identified with the interests of workers and consumers, demanded for more scientific and technical information and stricter health protection measures. Conclusions: Within these divergent stands, the regulatory agency behaved in a transparent and receptive manner while conducting the public consultation and substantively modified the originally proposed exposure limits to AgNP.