Tag Archives: US National Institute of Occupational Health and Safety

Designing nanomaterials for safe handling

I’ve long been interested in ‘good’ design, i.e., designing systems and products for success not failure. How many times have you had to use a device that was designed for failure? Take for example the keypad at the Automatic Teller/Banking Machines. I used one recently where the first line of digits (1, 2, 3) was hidden by a rubber mat intended to shield the code from prying eyes. Being busy and agitated, I didn’t notice and kept keying in the wrong code. That was a nonfatal failure but other bad design can cost lives.

The US National Institute of Occupational Health and Safety (NIOSH) is co-sponsoring an August 2012 workshop on designing nanomaterials and safety at the University of Albany in New York state (from the July 27, 2012 news item on Nanowerk),

A traditional hierarchy of controls to reduce occupational risks may be applied to advanced nanomaterials. The hierarchy of controls starts with elimination or substitution of hazards. Preventing a potential risk to workers from a particular advanced nanomaterial by eliminating that potential hazard at the design phase of development is the most effective means of risk management and can support the safe progression of nanotechnology from simple to more advanced nanomaterials. Prevention of harm through safe design includes: (1) avoiding incorporating hazardous elements such as lead and other heavy metals into the nanomaterial; (2) designing “safer” nanomaterials, which would disintegrate into non-toxic and easily biodegradable components; and (3) designing safer nanomanufacturing processes.

Safe design of nanomaterials is included in the National Nanotechnology Initiative’s Signature Initiative on Nanotechnology Knowledge Infrastructure (pdf) announced in May of 2012. Specifically, the Signature Initiative states that “a focused national emphasis on nanoinformatics* will provide a strong basis for the rational design of nanomaterials and products, prioritization of research, and assessment of risk throughout product lifecycles and across sectors.” Safe design will be also a focus of an upcoming workshop on Safe Nano Design: Molecule • Manufacturing • Market co-sponsored by NIOSH.

The workshop registration deadline is Aug. 3, 2012. Here’s more about the workshop from the event webpage,

Participants at this workshop will provide input into the safe commercialization of nano products using a Prevention-through-Design approach. Participants will share their knowledge on the efforts to develop safer nano molecules that have the same functionality; process containment and control, based on the considerations of risk of exposure to workers; and the management system approaches for including occupational safety and health into the nanoparticle synthetic process, product development, and product manufacture.

I found this  description on the Prevention Through Design webpage,

One of the best ways to prevent and control occupational injuries, illnesses, and fatalities is to “design out” or minimize hazards and risks early in the design process. NIOSH is leading a national initiative called Prevention through Design (PtD) to promote this concept and highlight its importance in all business decisions.

A growing number of business leaders are recognizing PtD as a cost-effective means to enhance occupational safety and health. Many U.S. companies openly support PtD concepts and have developed management practices to implement them. Other countries are actively promoting PtD concepts as well. The United Kingdom began requiring construction companies, project owners, and architects to address safety and health during the design phase of projects in 1994, and companies there have responded with positive changes in management practices to comply with the regulations. Australia developed the Australian National OHS Strategy 2002–2012, which set “eliminating hazards at the design stage” as one of five national priorities. As a result, the Australian Safety and Compensation Council (ASCC) developed the Safe Design National Strategy and Action Plans for Australia encompassing a wide range of design areas including buildings and structures, work environments, materials, and plant (machinery and equipment).

I appreciate the importance of this concept when applied to occupational health and safety and hope this ‘preventive design ‘ or as I prefer to call it ‘designing for success’ is applied to systems and products of all kinds.

Nanomaterials and toxicology (US Environmental Protection Agency and National Institute of Occupational Health and Safety)

It seems to be ‘toxicology and nanomaterials’ season right now. In addition to the ISO (International Standards Organization) technical report on nanomaterials and toxicology which was released in early June (mentioned in my June 4, 2012 posting), the US Environmental Protection Agency (EPA) and the US National Institute of Occupational Safety and Health (NIOSH) have released new reports.

Yesterday (July 2, 2012), the EPA posted a notice on the US Federal Register about a report, a commenting period, and a public information exchange meeting for “Nanomaterial Case Study: A Comparison of Multiwalled Carbon Nanotubes and Decabromodiphenyl Ether Flame-Retardant Coatings Applied to Upholstery Textiles.”

As I noted in an Aug. 27, 2010 posting, the EPA has adopted a very interesting approach to studying possible toxicological effects due to nanomaterials (and other materials),

Such case studies do not represent completed or even preliminary assessments; rather, they are intended as a starting point in a process to identify and prioritize possible research directions to support future assessments of nanomaterials.

Part of the rationale for focusing on a series of nanomaterial case studies is that such materials and applications can have highly varied and complex properties that make considering them in the abstract or in generalities quite difficult. Different materials and different applications of a given material could raise unique questions or issues as well as some issues that are common to various applications of a given nanomaterial or even to different nanomaterials. After several individual case studies have been examined, refining a strategy for nanomaterials research to support long-term assessment efforts should be possible. (p. 19 PDF, p. 1-1 in print version of a  US EPA silver nanomaterials draft report)

The July 3, 2012 news item on Nanowerk offers more detail about this latest case study (Note: I have removed a link),

EPA announces the release of the draft report, Nanomaterial Case Study: A Comparison of Multiwalled Carbon Nanotube and Decabromodiphenyl Ether Flame-Retardant Coatings Applied to Upholstery Textiles (External Review Draft), for public viewing and comment. This was announced in a July 2, 2012 Federal Register Notice  along with information about the upcoming public Information Exchange Meeting scheduled for October 29, 2012. The purpose of this meeting is to receive comments and questions on the draft document, as well as provide information on the draft document and a workshop process that it will be used in, which is being conducted independently by RTI International, a contractor for EPA. The deadline for comments on the draft document is August 31, 2012. [emphases mine]

The notice on the EPA website offers details and extensive links to satisfy your information needs on this matter,

The draft document is intended to be used as part of a process to identify what is known and, more importantly, what is not yet known that could be of value in assessing the broad implications of specific nanomaterials. Like previous case studies (see History/ Chronology below [on the EPA website]), this draft case study on multiwalled carbon nanotubes (MWCNTs) is based on the comprehensive environmental assessment (CEA) approach, which consists of both a framework and a process. Unlike previous case studies this case study incorporates information about a traditional (i.e., “non-nano-enabled”) product, against which the MWCNT flame-retardant coating applied to upholstery textiles (i.e., the “nano-enabled” product) can be compared. The comparative element serves dual-purposes: 1) to provide a more robust database that facilitates identification of data gaps related to the nano-enabled product and 2) to provide a context for identifying key factors and data gaps for future efforts to evaluate risk-related trade-offs between a nano-enabled and non-nano-enabled product.

This draft case study does not represent a completed or even a preliminary assessment of MWCNTs; rather, it uses the CEA framework to structure information from available literature and other resources (e.g., government reports) on the product life cycle, fate and transport processes in various environmental media, exposure-dose characterization, and impacts in human, ecological, and environmental receptors. Importantly, information on other direct and indirect ramifications of both primary and secondary substances or stressors associated with the nanomaterial is also included when available. The draft case study provides a basis for the next step of the CEA process, whereby collective judgment is used to identify and prioritize research gaps to support future assessment efforts that inform near-term risk management goals.

Meanwhile, NIOSH has released a safety guide (from the June 29, 2012 news item on Nanowerk),

The National Institute for Occupational Safety and Health (NIOSH) has published “General Safe Practices for Working with Engineered Nanomaterials in Research Laboratories” (pdf).

With the publication of this document, NIOSH hopes to raise awareness of the occupational safety and health practices that should be followed during the synthesis, characterization, and experimentation with engineered nanomaterials in a laboratory setting. The document contains recommendations on engineering controls and safe practices for handling engineered nanomaterials in laboratories and some pilot scale operations. This guidance was designed to be used in tandem with well-established practices and the laboratory’s chemical hygiene plan. As our knowledge of nanotechnology increases, so too will our efforts to provide additional guidance materials for working safely with engineered nanomaterials.

Here is more information  from the executive summary of the General Safe Practices for Working with Engineered Nanomaterials in Research Laboratories,

Risk Management

Risk management is an integral part of occupational health and safety. Potential expo­sures to nanomaterials can be controlled in research laboratories through a flexible and adaptive risk management program. An effective program provides the framework to anticipate the emergence of this technology into laboratory settings, recognize the po­tential hazards, evaluate the exposure to the nanomaterial, develop controls to prevent or minimize exposure, and confirm the effectiveness of those controls.

Hazard Identification

Experimental animal studies indicate that potentially adverse health effects may result from exposure to nanomaterials. Experimental studies in rodents and cell cultures have shown that the toxicity of ultrafine particles or nanoparticles is greater than the toxicity of the same mass of larger particles of similar chemical composition.

Research demonstrates that inhalation is a significant route of exposure for nanoma­terials. Evidence from animal studies indicates that inhaled nanoparticles may deposit deep in lung tissue, possibly interfering with lung function. It is also theorized that nanoparticles may enter the bloodstream through the lungs and transfer to other or­gans. Dermal exposure and subsequent penetration of nanomaterials may cause local or systemic effects. Ingestion is a third potential route of exposure. Little is known about the possible adverse effects of ingestion of nanomaterials, although some evidence sug­gests that nanosized particles can be transferred across the intestinal wall.

Exposure Assessment

Exposure assessment is a key element of an effective risk management program. The ex­posure assessment should identify tasks that contribute to nanomaterial exposure and the workers conducting those tasks. An inventory of tasks should be developed that in­cludes information on the duration and frequency of tasks that may result in exposure, along with the quantity of the material being handled, dustiness of the nanomaterial, and its physical form. A thorough understanding of the exposure potential will guide exposure assessment measurements, which will help determine the type of controls re­quired for exposure mitigation.

Exposure Control

Exposure control is the use of a set of tools or strategies for decreasing or eliminating worker exposure to a particular agent. Exposure control consists of a standardized hi­erarchy to include (in priority order): elimination, substitution, isolation, engineering controls, administrative controls, or if no other option is available, personal protective equipment (PPE).

Substitution or elimination is not often feasible for workers performing research with nanomaterials; however, it may be possible to change some aspects of the physical form of the nanomaterial or the process in a way that reduces nanomaterial release.

Isolation includes the physical separation and containment of a process or piece of equipment, either by placing it in an area separate from the worker or by putting it within an enclosure that contains any nanomaterials that might be released.

Engineering controls include any physical change to the process that reduces emissions or exposure to the material being contained or controlled. Ventilation is a form of engi­neering control that can be used to reduce occupational exposures to airborne particu­lates. General exhaust ventilation (GEV), also known as dilution ventilation, permits the release of the contaminant into the workplace air and then dilutes the concentration to an acceptable level. GEV alone is not an appropriate control for engineered nano­materials or any other uncharacterized new chemical entity. Local exhaust ventilation (LEV), such as the standard laboratory chemical hood (formerly known as a laboratory fume hood), captures emissions at the source and thereby removes contaminants from the immediate occupational environment. Using selected forms of LEV properly is ap­propriate for control of engineered nanomaterials.

Administrative controls can limit workers’ exposures through techniques such as us­ing job-rotation schedules that reduce the time an individual is exposed to a substance. Administrative controls may consist of standard operating procedures, general or spe­cialized housekeeping procedures, spill prevention and control, and proper labeling and storage of nanomaterials. Employee training on the appropriate use and handling of nanomaterials is also an important administrative function.

PPE creates a barrier between the worker and nanomaterials in order to reduce expo­sures. PPE may include laboratory coats, impervious clothing, closed-toe shoes, long pants, safety glasses, face shields, impervious gloves, and respirators.

Other Considerations

Control verification or confirmation is essential to ensure that the implemented tools or strategies are performing as specified. Control verification can be performed with traditional industrial hygiene sampling methods, including area sampling, personal sampling, and real-time measurements. Control verification may also be achieved by monitoring the performance parameters of the control device to ensure that design and performance criteria are met.

Other important considerations for effective risk management of nanomaterial expo­sure include fire and explosion control. Some studies indicate that nanomaterials may be more prone to explosion and combustion than an equivalent mass concentration of larger particles.

Occupational health surveillance is used to identify possible injuries and illnesses and is recommended as a key element in an effective risk management program. Basic medical screening is prudent and should be conducted under the oversight of a qualified health-care professional. (pp. 9 – 11 PDF or pp. vii – ix in print)

The guidance as per the executive summary seems to rely heavily on what I imagine are industrial hygiene practices that should be followed whether or not laboratories are researching nanomaterials.

US government call for proposals for studies of nanomaterials and occupational health & safety

The US National Institute of Occupational Health and Safety (NIOSH) has put out a call for Nanotechnology Studies proposals. From the March 8, 2012 news item on Nanowerk,

The National Institute for Occupational Safety and Health (NIOSH) invites applications from small businesses to conduct innovative research in three high-priority areas, including studies relating to the occupational health and safety aspects of nanotechnology. Applications for competitive funding through the U.S. Department of Health and Human Services’ Small Business Innovative Research (SBIR) program are due by April 5, August 5, and December 5 each year.

So April 5 is the next deadline for a proposal. The wording for the call is a little misleading as two of the three proposed areas of research are nanotechnology-oriented while the 3rd is focused on motor vehicle accidents and incidents. From the March 6, 2012 notice,

The proposed areas for NIOSH research include:

  • Control Technology and Personal Protective Equipment for High Risk Occupations: Research is needed to develop and evaluate control strategies and personal protective equipment for specific hazards and to assure their practicality and usability in workplaces in all industrial sectors with high risk for potentially hazardous exposures. One of the goals of this research area is to evaluate the effectiveness of personal protective equipment in reducing occupational exposures to engineered nanomaterials.
  • Exposure Assessment Methods for High Risk Occupations: Exposure assessment provides strategies and methods to anticipate, recognize, evaluate, control, and confirm effective management of occupational health stressors, exposures to those stressors, and resulting health risks. One of the goals of this research area is the need to support effective assessment of worker exposure to engineered nanomaterials.
  • Occupational Traumatic Injuries from Motor Vehicle Crashes and Incidents: Motor vehicle-related incidents are consistently the leading cause of work-related fatalities in the United States. Priorities include developing new design concepts and standards, enhancing effective interventions for driver education, evaluating intervention strategies for their effectiveness in reducing the number or severity work-related motor vehicle incidents and crashes, and enhancing engineering controls for the prevention of crashes and incidents or reducing the severity of traumatic injury associated with such crashes and incidents.

There is more funding information here (I looked at it briefly but the whole thing seems a bit confusing as I gather it’s part of a ‘ginormous’ government programme, the sort of thing that usually requires hours of patient reading if you’re planning on making a submission). Good luck!

US NIOSH (National Institute of Occupational Health and Safety) nano consultation mystery

I am mystified by the NIOSH public consultation on its nanotechnology strategic plan (Approaches to Safe Nanotechnology; Managing the Health and Safety Concerns Associated with Engineered Nanomaterials).

Here are the clues in the order in which I found them:

(a) An April 14, 2011 posting on EnvironmentalExpert.com. (Apparently these people are lawyers so my attempt to cut and paste the first paragraph of their posting resulted in a notice that I don’t have permission. I gather the text these lawyers have provided about the announcement and NIOSH’s history regarding its nanotechnology plans is considered proprietary. Accordingly, I’ve removed the paragraph and, in an excess of caution, I have removed the link I would have provided to their site. I trust it’s acceptable to refer to the website by name.) According to this posting, NIOSH announced their nanotechnology public consultation on March 7, 2011. (Note: This consultation is separate from the NIOSH consultation on carbon nanotubes and nanofibers mentioned in my Dec. 9, 2010 posting.)

(b) It took me a while to get to the notice as I had to click down a couple levels into the NIOSH site to find the March 7, 2011 notice of the public consultation on the US Federal Register. From the notice,

SUMMARY: National Institute for Occupational Safety and Health (NIOSH) of the Centers for Disease Control and Prevention (CDC) seeks comment on the types of hazard identification and risk management research that should be considered for updating the NIOSH 2009 nanotechnology strategic plan.
Public Comment Period: Comments must be received by April 15, 2011.

It seems like a relatively short period to allow for responses but, more puzzlingly, the notice doesn’t seem to have been well publicized. I can’t find mention of it on the Nanowerk website (my usual source for this kind of thing), the University of Michigan’s Risk Science Blog, or on Andrew Maynard’s 2020 Science Blog. (Note: Andrew is also involved with the Risk Science Blog but he is not its sole author.)

(c) I found the public consultation docket about what is now referred to as the NRTC Strategic Plan on the NIOSH website and, as they promise, the responses to the consultation are available for viewing. All two of them, that is.

Nanomaterials and health: the good, the bad, and the ugly?

One of the things I’ve noticed about the nanomaterials safety debate is how quickly it devolves to:  nanomaterials are good (some media reporters, business and corporate lawyers) vs nanomaterials are bad (some media reporters and civil society groups). Unfortunately, we still don’t know much about nanomaterials and their possible effects on health and the environment but there is enough evidence to support a single position if you’re willing discount evidence that doesn’t support your case. There are even people (pro and con) who will use evidence that doesn’t support their case very well unless they leave out details.

Take for example, this interview with Pat Roy Mooney (executive director of the ETC Group) at the Elevate Festival, October 2009 in Austria. Much of what he has to say is quite right (more work needs to be done to ensure safety) but you might get the impression that all this nanotechnology research that’s been talked about has resulted only in consumer products such as sunscreens and cosmetics. At about 4 mins., 15 secs., the reporter challenges Mooney and points out that the research may be very helpful in cleaning water (vital in some areas of the world) and could have other benefits. Mooney concedes the point, grudgingly.

Oddly, Mooney spends quite a bit of time suggesting that gold nanoparticles are a problem. That may be  but the more concerning issue is with silver nanoparticles which are used extensively in clothing and which wash off easily. This means silver nanoparticles are ending up in the water supply and in our fish populations. Studies with zebrafish strongly suggest far more problems with silver nanoparticles than gold nanoparticles. You can check this paper (which compares the two nanoparticles), this paper (about silver only) and this paper (about silver only) or run a search.

Mooney goes on to describe problems with other nanomaterials that I’m unfamiliar with, but I don’t know how far I can trust the information he’s giving me.

Mooney isn’t the only one who likes to remove nuance and shading. In a recent interview on the Metropolitan Corporate Counsel website, one of the interview subjects, William S. Rogers, Jr., essentially dismisses concerns about carbon nanotubes with this:

Rogers: Before the EPA announcement in January, 2010 concerning the proposed SNUR, a series of studies was done beginning in the United Kingdom with a study led by Poland, et al. (2008). That study involved the injection of multi-walled nanotubes into the abdomen of mice, the mucosal lining of which is identical to the mesothelium of the pleura or chest. The injection directly into the abdomen was intended to simulate exposure of the mesothelium in the chest due to inhalation exposure. Approximately 90 days later they examined the biological changes who had taken place as a result of exposure of the abdominal mesolthelial lining to the carbon nanotubes. They reportedly found evidence of inflammation that was consistent with the type of inflammation that had traditionally been recognized in people who had inhalation exposure to asbestos fibers and who later developed mesothelioma. They did not find actual mesothelioma in the mice, but rather what were thought to be precursors to such cancers. The result of publication of these findings was an alarmist reaction that carbon nanotubes posed a danger to humans analogous to that of asbestos fibers. This became headline news.

Up to this point I could agree with him, but now Rogers goes on to point out the study’s shortcomings,

The problem with the study was that the mice were exposed to massive doses of nanotubes by injection, which is not a natural or likely cause of human exposure. The test methodologies were a poor analog for what likely human exposure would be in any setting. Many commentators criticized the study’s findings and suggested that its conclusions about a potential relationship between carbon nanotubes and asbestos fibers was flawed because it rested largely on their shape similarity (long and thin); however, for the last two years there has been talk in the popular media about whether the risks associated with all nanomaterials are akin to those associated with asbestos fibers. The only similarities between carbon nanotubes and asbestos fibers is their long aspect ratio, unlike other nanomaterials. There has been more focus on carbon nanotube toxicity than on other nanomaterial substances, which has percolated up to the EPA. EPA has now decided to treat carbon nanotubes separately from other nano-objects.

Rogers fails to mention that this was a pilot study which was intended to lay the basis for further research. Dr. Andrew Maynard, one of the authors of the study, noted in a March 26, 2009 posting on his blog (2020 Science) further work had been done,

I’m looking at an electron microscope image of a carbon nanotube – as I cannot show it here, you’ll have to imagine it. It shows a long, straight, multi-walled carbon nanotube, around 100 nanometers wide and 10 micrometers long. There is nothing particularly unusual about this. What is unusual is that the image also shows a section of the lining of a mouse’s lung. And the nanotube is sticking right through the lining, like a needle through a swatch of felt.

The image was shown at the annual Society of Toxicology meeting in Baltimore last week, and comes from a new study by researchers at the National Institute for Occupational Safety and Health (NIOSH) on the impact of inhaled multi-walled carbon nanotubes on mice. [You can find out more about the NIOSH study here]

It’s highly significant because it takes scientists a step closer to understanding whether carbon nanotubes that look like harmful asbestos fibers, could cause asbestos-like disease…

Both the carbon nanotube studies mentioned here are studies of long, multi-walled carbon nanotubes. This distinction is important as substances at the nanoscale can behave differently from each other depending on their shape and size. Both Maynard and the NIOSH researchers suggest that more study is required but clearly the evidence is mounting.

Interestingly, the Good Nano Guide (GNG)* page on carbon nanotubes mentions the Poland study but not the NIOSH Study. The page also notes that at least one study indicates issues with single-walled and multi-walled carbon nanotubes as well as C60 (fullerenes). I wonder if there’s a policy about including only studies that have been published in peer-reviewed journals.

(*a ‘best practices for nanomaterials’ wiki hosted by the International Council on Nanotechnology ETA (April 12, 2010: From Dr. Kristen Kulinowski, “As to your question about our policy for posting information at the GNG, there is no policy that states we only publish peer-reviewed papers.” Dr. KK has offered this and  more information about the GNG in the comments.)

The media also are playing a role in this discussion. I’ve noted before Andrew Schneider’s nanotechnology series for AOL News, from his article Obsession with Nanotech Growth Stymies Regulators,

Separately, the NIOSH team discovered that beyond the well-documented lung damage that comes from inhalation of carbon nanotubes, [emphasis mine] those heavily used carbon structures were causing inflammation of the brain in the test animals.

Except for the fact that “well-documented lung damage that comes from inhalation” is an over statement, Schneider’s article is a good read although as I’ve noted elsewhere I don’t know how far to trust his information. [ETA: April 21, 20010, Schneider also fails to note the the type of carbon nanotube (likely the long, multi-walled ones) on which he bases his unsubstantiated claim. ]

After writing all this, I’m torn. On the one hand,  I do think that if people like Schneider and Mooney had their way, none of us would be eating potatoes, tomatoes, or eggplants. After all, they’re members of the nightshade family and the ill effects of ingesting other members of that family, belladonna (deadly nightshade) and datura (jimson weed), are well documented. On the other hand, folks like William Rogers are all too willing dismiss some very troubling research as their clients strive to bring products to market, seemingly regardless of any consequences.

ETA: Happy Weekend!