Feedback from Scott Rickert

NanoFilm

Posted on: March 26, 2007

Companies under $100 million in sales will not be able to fill out sections 2A, 2B, 2C or 3. Their project managers will not have the time or ability to do so. They certainly can fill out sections 1, 2 and 4.

I suggest that sections 2A through 3 be made optional at this time, based on company size.

The problem with leaving it in, and telling smaller companies to "do their best", or "do it only if the potential exposure is large" is that it leaves the project managers in an untenable state. They can't really gather the information requested, yet they are being held accountable to provide such information. The tendency of such managers might be to "guess", or rely on sketchy advice received from suppliers. This would be worse than skipping these sections in the first place.

Once NIST, or someone else, provides a central database of nanomaterial exposure tests, it would be fair to ask that smaller company project managers reference these studies, as a way to at least partially answer sections 2A-3.

It also would be great if larger companies would provide their results of sections 2A-3 so that smaller companies could refer to the larger company's results. However, I imagine the larger companies would not like to take on that liability, either.