Feedback from Dee Woodhull

Organizational Resource Council

Posted on: March 30, 2007

Detailed instructions for dealing with nanomaterial risk. A good effort. However, its premise is that sufficient information is or can be made available for materials currently in use. Without toxicity or health effects testing or experience data for most (not "many") nanomaterials, the document is ahead of its time, in some ways.

The Framework can be improved by:

1. Taking the position that all efforts should be made right now to protect people from any or all exposure to materials for which hazards are unclear or unknown. Hazard information on the vast majority of nanomaterials is unknown, and initial testing indicates that there is potential for serious health effects. Practical exposure sampling technology is in its infancy, therefore it is very difficult for most employers to conduct meaningful exposure assessment to nano materials. This means that human and environmental exposure must be prevented while data on health effects are being developed for materials in use.
2. Keeping the framework clear of any implication that epidemiology or human health studies will be the primary basis for determining whether a material should be regarded as hazardous to humans and if engineering controls are needed.
3. Incorporating recommendations for HSE cost/benefit analysis of hazard control into the decision making process for the types of controls that would be appropriate for given nano materials.
4. Dispelling the assumption that engineering controls are the least cost effective approach to protecting people from potential hazards of nano materials. The framework document implies that engineering controls are only to be used where absolutely necessary, and that personal protective equipment is an acceptable alternative. In ORC's experience with examining the financial aspects of various methods of hazard control,the cost/benefit equation is unique to each combination of material and application. We have found, however, that engineering controls are very often more cost-effective than personal protective equipment (including respirators). There is no economic harm in taking the position that the primary objective is to protect the health and safety of people.(We can provide examples of cost analysis data for industrial hygiene controls in pharmaceutical operations if you wish to include it in the framework.) 5. Reversing the assumption that an application of a nano material could require the release of the material to the workplace or the environment. Processes that use or produce nano materials should be planned so as to avoid release. The framework should include some process for evaluation as to the wisdom or appropriateness of release in the absence of information about health effects of the material in question.
5. Qualifying the statement that early screening data could be useful. At this time and place they cannot provide assurances of safety.
6. Re-examining the wisdom of "reasonable worst-case default assumptions." A simpler scenario– use engineering controls to eliminate exposure first and ask questions later–makes sense at this time. Again, the economics of each situation should be an inherent part of determining the best means of preventing exposure.
7. On page 62 is a table which identifies "Safety Officer" as a critical team member. Any facility working with complex technologies and manufacturing/research activities needs a Certified Industrial Hygienist or Certified Safety Professional. Such professionals would have relevant education, training, and experience to qualify for such a position.