The US National Institute of Occupational Health and Safety (NIOSH) is inviting the public (presumably the US public) to comment on “Current Intelligence Bulletin: Occupational Exposure to Carbon Nanotubes and Nanofibers,” a draft document.

From the Dec. 7, 2010 news item on Nanowerk,

For public review and comment, the draft document summarizes current scientific knowledge about the occupational safety and health implications of carbon nanotubes and carbon nanofibers, and recommends an occupational exposure limit and measures for controlling work related exposures to those types of nanomaterials, based on the current state of knowledge. The draft document also suggests areas where further research is vital for more certainty in assessing potential risk of adverse health effects for workers in the manufacture and industrial use of carbon nanotubes and carbon nanofibers.

You can go here (http://www.cdc.gov/niosh/docket/review/docket161A/) to read the document and make your comments.  And,

NIOSH also announced that it will hold a public meeting to discuss and obtain comments on February 3, 2011, in Cincinnati, Ohio.

The news item highlights two recommendations for comment,

The draft document includes, for comment:

# A recommendation that employers minimize work-related exposures until scientific studies can fully clarify the physical and chemical properties of carbon nanotubes and carbon nanofibers that define their potential for adverse occupational health effects through inhalation. The draft document recommends a strategic approach for assessing potential work-related exposures and risks, controlling exposures through a hierarchy of measures, instituting appropriate medical screening programs, and educating workers on sources and job tasks that may expose them to these types of nanomaterials.

# A recommended exposure limit (REL) of 7 micrograms of carbon nanotubes or carbon nanofibers per cubic meter of air as an eight-hour, time-weighted average, respirable mass concentration. This is the concentration that can most reliably be measured with current instrumentation. The draft document states, “NIOSH recognizes that the REL may not be completely health protective but its use should help lower the risk of developing [work-related] lung disease and assist employers in establishing an occupational health surveillance program that includes elements of hazard and medical surveillance.” The draft document recommends that airborne concentrations should be reduced as low as possible below the REL by making optimal use of sampling and analysis.

For more information about NIOSH and nanotech you can go here (www.cdc.gov/niosh/topics/nanotech).

On other matters, both Nanoclast (Dexter Johnson) at his blog on the IEEE (Institute of Electrical and Electronics Engineering) website and Andrew Maynard at his 2020 Science blog have announced/commented on the US National Nanotechnology Initiative’s latest effort, a public consultation on its Environmental Health and Safety (EHS) Research Strategy.

From Dexter Johnson’s Dec. 8, 2010 Nanoclast posting,

In my most recent blog on this subject, the National Nanotechnology Initiative (NNI) used the month of November to collect suggestions from the public on its then current draft of its strategy.

One week now into December and I am not sure what input the NNI collected, but we do know that they have announced a new public engagement scheme this time focused on getting input on its Environmental, Health and Safety (EHS) Research Strategy.

It will be possible to contribute thoughts on the current draft of the EHS strategy from December 6th to January 6th. At least one noted expert on EHS on nanotech will be taking full advantage of this one-month window.

I think this most recent public engagement move by the NNI has changed my attitude about these initiatives from mere intrigue to begrudging respect. I mean you are not going to find a more contentious issue (and one with fewer easy solutions, if any) than determining the course of EHS research and the NNI has just said, “Let us have it.”

Andrew Maynard comments in his Dec. 6, 2010 posting,

You may remember that the previous strategy was given a bit of a hard time by the National Academies of Science – less for its substance than for the way it was – or wasn’t – brought together in a research strategy. It’ll be interesting to see how things have evolved over the past couple of years or so.

I haven’t read the draft strategy yet, but I’m hopeful that this will be a stronger document. For one thing, it builds on input from a wide range of non-government experts. For another, the feds have taken the bold but extremely welcome step of initiating a public review period. This makes a lot of sense – it provides another chance to iron out those niggling mistakes that everyone makes while writing documents, and it helps a broader community to be a part of the process, rather than just passive recipients.

I’ll be posting comments on the draft over the next few weeks – within the constraint that I am currently also working on the National Academies panel developing a complementary strategy.

A blog maintained by Sally Tinkle, Coordinator for Environmental, Health, and Safety Research and Deputy Director for the National Nanotechnology Coordination Office notes this,

Starting Monday, December 6, public comment is being invited on the draft National Nanotechnology Initiative Environmental, Health, and Safety Research Strategy (“NNI EHS research strategy”). The draft NNI EHS research strategy includes a scientific framework that incorporates the research needed to assess the environmental, health and safety of nanomaterials. It describes the NNI EHS research investment by research need, the state of the science, and an analysis of the gaps and barriers to achieving that research as part of the NNI’s adaptive management process. It updates and replaces the NNI EHS Strategy of February 2008.

The strategy aims to ensure the responsible development of nanotechnology by providing guidance to the Federal agencies that produce the scientific information for risk management, regulatory decision-making, product use, research planning, and public outreach. The core research areas providing this critical information are measurement, human exposure assessment, human health, and the environment, in order to inform risk assessment and risk management.

The draft NNI EHS research strategy is here (http://strategy.nano.gov/blog/generic/page/draft-nni-ehs-strategy). You must be able to log in to the NNI portal (this means you need to register) to leave comments from Dec. 6, 2010 – Jan. 6 ,2011.