nanotechnology: hazard communication issues nanotechnology: hazard communication issues 2006 nrt...
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Nanotechnology: Hazard Nanotechnology: Hazard Communication IssuesCommunication Issues
2006 NRT Worker Safety and HealthTechnical Conference
May 31, 2006
This copy approved for distribution through the DOE IH/OS SIG
Nanotechnology: Hazard Nanotechnology: Hazard Communication IssuesCommunication Issues
2006 NRT Worker Safety and HealthTechnical Conference
May 31, 2006
This copy approved for distribution through the DOE IH/OS SIG
Bruce Lippy, Ph.D., CIH, CSPEnvironmental Profiles, Inc. Baltimore, MD
21228, 410.744.0700
A comment for the NEHI A comment for the NEHI subcommitteesubcommittee
Good work! An impressive example of the federal government being
proactive and cooperative on H&S issues
Objectives Objectives At the end of this session, I would At the end of this session, I would
like you to be able to:like you to be able to:
1. List several reasons that the standard MSDS format may prove inadequate for nanomaterials
2. Describe findings from the Hazcom literature that may prove useful in creating effective communication strategies for nanomaterials
3. Describe several findings from research on Technology Safety Data Sheets that may have implications for nanotechnologies.
Research effortsResearch efforts
Bought “Nanotech for Dummies”
Bought “Nanotech for Dummies”Got 30% offGot 30% off
The promise is The promise is impressive, but let’s impressive, but let’s
address the following:address the following:
1. Is it too soon to talk about Hazcom?
2. Who are the exposed worker populations? What do we know about their demographics?
3. Will the current approach to Hazcom be sufficient for nanomaterials?
Is it too soon to talk Is it too soon to talk Hazcom?Hazcom?
Several at NEHI meetings felt that there was insufficient toxicological data
Over 200 consumer products listed on the Wilson Center for Scholars website
National Nanotechnology Initiative (NNI) is maintaining a list of about 600 commercial materials, many just for research.
Hazcom expert at OSHA suggested this is an area where they clearly have regulatory authority.
Is it too soon to talk Is it too soon to talk about Hazcom?about Hazcom?
Nanotech Product Recalled in Germany
Rick Weiss, Washington Post Thursday, April 6, 2006
CPSC recall
of spray
grout sealer
8-2005
Courtesy Andrew MaynardCourtesy Andrew MaynardWilson Center for ScholarsWilson Center for ScholarsAround 200 consumer products:Around 200 consumer products:
www.nanotechproject.org/consumerproducts
Product categories
Health and Fitness Subcategories
Region of Origin
Major Materials
Review of Products in the Review of Products in the DatabaseDatabase
1. Selected 10% of the 200 using a random number table
2. Searched their website for safety information, particularly MSDSs
3. Submitted written request for MSDSs through website or called.
Found 1 MSDS out of 20 sites
My favorite nanoproduct: My favorite nanoproduct: Anti-graffiti PaintAnti-graffiti PaintDeletum 3000+Deletum 3000+
My Guess: used to remove My Guess: used to remove nano-graffitinano-graffiti
Image courtesy Justin Kumar, Ph.D., Indiana UniversityImage courtesy Justin Kumar, Ph.D., Indiana University
Example Example MSDS MSDS
ReceivedReceived Advanced
Nanotechnology’sZinClear (ZnO 58-62%)
Formulated for sunscreens, dispersed in carrier fluid
Uses ANSI Z400.1 format Cites OSHA PEL for
nuisance dust for ZnO– 5 mg/m3 respirable– 15 mg/m3 total dust
Another example: Another example: NanoWaxNanoWax
NanoWax MSDSNanoWax MSDSSection 8: Exposure Section 8: Exposure
Controls/PPEControls/PPEWAX EMULSION: No exposure limits established (NLE)
ALIPHATIC PETROLEUM DISTILLATES (64741-66-8): NLE
ALUMINUM SILICATE (66402-68-4): NLE
POLY(DIMETHYLSILOXANE) (63148-62-9): NLE
ALKYL QUATERNARY AMMONIUM BENTONITE (68953-58-2) : NLE
TETRAGLYCERYL MONOOLEATE (9007-48-1): NLE
GLYCOL (107-21-1)
OSHA PEL 50 ppm - Ceiling
ACGIH TLV 100 mg/m3 - Ceiling as an aerosol
No indication which component is nano-sized. Is it important in this application?
MSDS for Multi-MSDS for Multi-walled Carbon walled Carbon
NanotubesNanotubes Uses ANSI Z400.1 format Eye irritation is primary
warning Available on web,
undated, an OSHA violation
Written in all caps, against ANSI Z400 recommendations
MSDS for Multi-walled Carbon MSDS for Multi-walled Carbon Nanotubes, Section 11 Nanotubes, Section 11
ToxicologyToxicology“To the best of our knowledge the
chemical, physical, and toxicological properties have not been thoroughly investigated.”
Cambridge University,
Department of Metallurgy
Toxicology on Carbon NanotubesToxicology on Carbon Nanotubes
Lam et al. (2004) Toxicological Sciences: “On an equal-weight basis, if carbon nanotubes reach the lungs they can be much more toxic than carbon black and more toxic than quartz.”
Oberdörster (2005) Environmental Health Perspectives: “Profound cytotoxicity seen for SWNT…” On a mass basis, toxicity:
SWNT>MWNT>C60
Who is being exposed?Who is being exposed?
Spokesperson for CBAN at Oct 2005 NEHI meeting unable to characterize the population
More educated population (Maynard, 3/06) NNI spokesperson unaware of any study
characterizing workforce (4/06) Toured Georgia Tech Microelectronics
Research Center Dec 2004. Are these average nanoworkers?
Who is exposed? Who is exposed? We don’t We don’t knowknow
Who is exposed in Who is exposed in England?England?
Aitken, Creely, & Tran, 2004, Inst. of Occupational Medicine, HSE,
UK Found no info on workers exposed in
unv/research sector or in companies. Est. 2,000 people currently employed in
univ/research and private companies in UK.
100,000 exposed to fine powders in industry, including pharmaceuticals
>1,000,000 may be exposed to nanoparticles via incidental production (welding and refining)
Will the current approach Will the current approach to Hazcom be sufficient to Hazcom be sufficient
for nanomaterials?for nanomaterials?
Current ApproachCurrent Approach ANSI Z400.1 is universally used. Is it
appropriate? Sufficiently flexible? ANSI Section 16 holds promise Regulatory exposure limits are required to be
listed in MSDSs. Are they pertinent? Given the importance of surface area over
mass, what role should sampling play? No specific OSHA Hazcom regulatory
requirements for nano (Silk, 2006) Strong movement in global harmonization
Is it enough to tweak Is it enough to tweak current regulations?current regulations?
“New law may be required to manage potential risks of nanotechnology.” (Davies, Wilson Center
Managing the Effects of
Nanotechnology)
Sampling Issues,Sampling Issues,Courtesy Andrew Maynard, Wilson Courtesy Andrew Maynard, Wilson
CenterCenter
ISO TC 229 Working ISO TC 229 Working Group on Health, Safety Group on Health, Safety
and the Environmentand the EnvironmentDeveloping international standards for
nanotechnology within three working groups: – terminology and nomenclature
(convened by Canada)– metrology and characterization (Japan) – health, safety and the environment.
(U.S.) Clayton Teague is leading
Review of Hazcom Review of Hazcom Literature Literature (Sattler, Lippy & (Sattler, Lippy &
Jordan, 1997)Jordan, 1997) Conducted by the University of
Maryland Medical School for OSHA Looked at peer-reviewed literature on
labels, warnings and MSDSs Last major review of Hazcom
literature (Silk, 4-06)
Key Finding: major lack of Key Finding: major lack of behavioral studies and behavioral studies and
appropriate test appropriate test populationspopulations
Studying behavior is much better than asking people’s preferences, but more difficult to do
Preferential studies dominated behavioral studies
Populations tended to be those of convenience: students not workers!
Can we do better with nano?
These are students. Do These are students. Do they look like workers?they look like workers?
My Son
Nano lesson: assumptions Nano lesson: assumptions can be dangerouscan be dangerous
Studies of the ANSI Z535.3-1991 protocol: standard ANSI slash not as effective as an "X" for warning consumers.
Subject randomly chosen by computer
Subject randomly chosen by computer
The most shocking The most shocking finding! finding! (Sattler, Lippy & Jordan, (Sattler, Lippy & Jordan,
1997)1997)
Women more likely than men to look for and comply with warnings.
Comparison of MSDS Comparison of MSDS formatsformats
Little research comparing formats of MSDSs
Where comparisons have been made, the International Chemical Safety Cards have been ranked more effective than the ANSI 400 format that is being promoted by industry and OSHA
ICSCs are on the NIOSH webpage
Critical Finding on Critical Finding on ComprehensibilityComprehensibility
On average, literate workers only understood about 60% of the health and safety information on sample MSDSs in three comprehensibility studies (Kolp et al. 93; Phillips et al., 99; Printing Industries of America,
90).
Readability is not comprehensibility
Potential lessons from Potential lessons from Technology Safety Data Technology Safety Data
SheetsSheets
Health and Safety in DOE’s Health and Safety in DOE’s innovative technologies innovative technologies
programprogram
Several serious incidents Small firms were the
drivers No hazard analysis and
communication to workers
Robotic CO2 blasterRobotic CO2 blaster
Concept of Technology Concept of Technology Safety Data SheetsSafety Data Sheets
Conceived in 1994 as a tool for informing users of technologies about hazards
Patterned on Material Safety Data Sheets Developed through 4 DOE and NIEHS
National Technical Workshops Cited by Dr. Sally Tinkle of NIEHS as an
idea to explore with nanotechnologies
Aimed at
workers, unlike
MSDSs
Available at:
www.wetp.org
Applicability to Applicability to NanotechnologyNanotechnology
Plasma Hearth ExamplePlasma Hearth Example
There have been explosions at two separate facilities: one
fatality, several injuries
Plasma operation for Plasma operation for NanoNano
PPG Industries, Lisa PPG Industries, Lisa MorrisonMorrison PPG produces nanoparticles as colorants for
glass in a plasma reactor in Allison Park, PA They are commissioning a large pilot plant by
conducting Hazard and Operability Study (HAZOP) of:– powder feeder system– plasma torch– reactor– bag filters
Not technically covered by OSHA PSM!
TSDS Phase AnalysisTSDS Phase Analysis Risks vary during life cycle of a
technology Particularly appropriate for
nanoproducts (Holman, 2006)
Risks: Maintenance Versus Risks: Maintenance Versus OperationOperation
Machinery fatalities 1997, Etherton, Machinery fatalities 1997, Etherton, NIOSHNIOSH
Maintenance
48%
Operations
45%
Other
7%
Research Findings, Research Findings, Lippy, Lippy, 2003 2003
DOE Technology DOE Technology DevelopersDevelopers Survey through the Institute for Regulatory
Science (62% return, 50/80) 74% agreed or strongly agreed with
statement: “This document format is quite valuable”
RESULTSRESULTSFocus Group of State Focus Group of State
Environmental RegulatorsEnvironmental Regulators Conducted through Southern States
Energy Board in 2000 Agreed that a TSDS as part of a
permit application would significantly increase the likelihood of technology approval
“Will it run in the rain and will it kill the neighbors?”
RESULTSRESULTSSurvey of WorkersSurvey of Workers
Heavy equipment operators 935 mailings, 475 responded (50%) 91% agreed with statement,
“This document is quite valuable
83% agreed that the similarity to MSDS increased ease of use
Questions?Questions?
“If it weren’t for the people, the damned people always getting tangled up in the machinery. If it weren't for them, earth would be an engineer’s paradise.”
Kurt Vonnegut, Player Piano