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Abstracts
Risk management and institutional emergence in nanotechnologies: looking at public engagement experiences
Claire Auplat, Ph.D.
The purpose of this paper is to explore new dynamics in risk management around the development of nanotechnologies. The development of any new technology raises issues relating to the process of measuring or assessing risk and developing strategies to manage it. Nanostructures are at present difficult to measure or assess. Indeed, a consideration of the possible risks presented by these emerging technologies is taking place at the very early stages of their trajectories, in many cases before commercialization and large-scale production. We first outline what makes nanotechnology applications different from previous innovations, particularly in terms of metrology and risk assessment. Then, we analyse two public engagement experiments undertaken in the last five years in the nanotechnology field and how these relate to the emergence of new dynamics in risk management. We show that the development of nanotechnologies appears to have engendered an aggregation of the expectations of the various stakeholders which is shaping the institutional responses to challenges posed by these technologies.
Local Disclosure Ordinances as Regulatory Catalysts: Early Insights from the Berkeley, California Nanoscale Materials Ordinance
Javiera Barandiaran, M.A.
In this paper, we analyze the Berkeley Manufactured Nanoscale Material Health and Safety Disclosure Ordinance (“Nano Ordinance”) as an example of a local disclosure ordinance (LDO). LDOs are a type of targeted transparency regulation that recent research documents is increasingly prominent in U.S. policy (Fung et al. 2007). Mandatory disclosure laws have been particularly important in California risk policy; examples include the Alquist-Priolo Special Studies Zones Act of 1972, the California Safe Drinking Water and Toxic Enforcement Act of 1986 (also known as Proposition 65), and the 1997 Los Angeles County restaurant hygiene law.
By adopting the Nano Ordinance in December 2006, the Berkeley City Council became the first government entity in the U.S. to approve a specific law requiring the reporting of nanomaterials used in local facilities. The ordinance amends the municipal hazardous materials code to compel “facilities that produce or handle manufactured nanoscale materials” within city limits to report what nanoscale materials they are working with, describe any known toxic effects, and give a plan for how the materials will be handled safely. The ordinance defines manufactured nanoscale materials as “manufactured chemicals that are engineered and have one dimension less than 100 nanometers.” The first wave of reporting is due to occur in June 2007.
The Berkeley Nano Ordinance reflects societal ambivalence and uncertainty about the risk-benefit tradeoffs involved in the development of nanotechnology. Nanomaterials have the potential to improve currently available technologies and new applications in areas such as environmental remediation, sensors, manufacturing, energy production and delivery, drug delivery, and optics (Roco 2005). On the other hand, research related to the fate and transport, exposure, and toxicity of nanoparticles, both natural and engineered, indicates that nanotechnology may pose important environmental and human health-related risks (Dunphy-Guzman et al. 2006; EPA 2007, Biswas and Wu 2005). A consensus exists that these research efforts need to be greatly increased (Roco 2005; Maynard et al. 2006; Renn and Roco 2006; Sherman 2006; EPA 2007). Factors other than mass such as size, surface area, surface chemistry, solubility and possibly shape may determine the potential risk, although the most important risk-related characteristics are not yet determined (Oberdörster et al. 2005).
Numerous examples exist in the history of the environmental implications of new technologies in which opportunities were missed to act upon early warnings of environmental and health risks (Harremoës et al. 2001). Awareness of this fact has prompted a number of calls for proactive risk management regarding the rapidly evolving set of nanotechnologies. Key priorities include creating knowledge to inform risk assessment and management, establishing scientifically and legally usable definitions and categorizations for nanomaterials, and disseminating accurate information about nanotechnology to the public (Maynard et al. 2006).
Professional societies, national government agencies, intra-national governmental bodies, non-governmental organizations, and international institutions are all engaged in different parts of an important dialogue concerning the nomenclature, metrology, and relevant technical attributes that would support the creation of nanotechnology standards. What is unusual about the Nano Ordinance is that it is not a deliberative body that slowly works toward the development of technological standards (e.g., the ASME standard setting process); it is instead an externally imposed change on standard operating procedures for organizations involved in nanotechnology science and commerce that may help create important knowledge artifacts for later technological standards. The Nano Ordinance imposes new costs on compliers above and beyond whatever voluntary knowledge organizing efforts by industry and scientists cost.
The question, therefore, is what a low-cost LDO adds to the dialog that may be different than what is contributed by other entities interested in effective proactive risk management of this emerging technology. The hypothesis is that the small number of actors in the local industry and government will facilitate practical learning about nanomaterial risk-related data collection. In particular, we theorize that the Nano Ordinance will change the dialogue about nanomaterial risk in the following ways: (1) it will engage new participants; (2) it will change the focus of the discussion to more practical concerns such as cost and implementation; and (3) it will develop key concepts and categorizations as well as identify gaps in our risk understanding at a faster pace than other extant standard-setting processes.
We test these three hypotheses using qualitative data, including the content analysis of public records and applicable multi-media accounts (including online blogs) as well as stakeholder interviews with actors embedded in relevant policy networks, including city council staff, entrepreneurs, environmental health services personnel, organizational spokespersons, and scientists. Our overall aims in doing this are to: (1) document and understand the emerging landscape of nanotechnology governance even as the science, commerce and public perceptions of nanotechnology continue to evolve, and (2) to use the Nano Ordinance case to shed light on the feasible and appropriate roles that LDOs can play in shaping risk policies more generally.
Current Respiratory Protection Standards and Devices: Can They Meet the Needs for Nanoparticle Exposures?
Jeff Birkner
This lecture will review the current respiratory protection standards including OSHA’s 29CFR1910.134. It will also briefly review NIOSH certifications and the types of respiratory protective devices that are currently available on the market. Discussed will be some of the basic concepts of aerosol science with relation to filtration and what has been seen as a “most penetrating particle size shift” towards a particle more in the range of nanoparticles rather than the currently accepted 0.3 μm. Addressed will be the types of devices which may meet the needs of nanoparticle exposures. Finally, research needs will be addressed with regard to filters, respiratory protection, release of particles from filters, and handling, care and disposal of respiratory protection devices.
Whatever the regulations – Will there be any real enforcement?
Garrett Brown, MPH, CIH
When nanotechnologies make the leap to mass production, among the places they will surely land are developing countries like China and Mexico. These two nations actually have an adequate framework of occupational safety and health regulations and governmental agencies empowered to enforce the laws. But in both countries there is zero enforcement of workplace safety regulations. This non-enforcement is due to several related factors: the desperate need of foreign investment for economic growth to reduce poverty and/or pay off foreign debts; widespread governmental corruption, particularly at a local level; and lack of human, financial and technical resources to implement health-protective laws. The health and well-being of high-tech workers in China, Mexico and elsewhere in the “nano era” will depend on recognizing and addressing the real-world constraints of regulating imperfectly-understood hazards, especially in mass production centers in the developing world.
Agency on a Chip? Problems and Prospects of Nanotechnologies in the Workplace
Lawrence Busch, Ph.D.
The world of Occupational Health and Safety (OSH) is changing rapidly. The global socioeconomic environment for OSH is shifting as a result of increased trade. The boundaries and limits of risk analysis are shifting as national and sectoral differences become more apparent and legal frameworks are modified. Similarly, the tools and techniques of risk analysis are not themselves static but are in flux. In addition, the technologies of governance are changing as much of the world moves from direct government regulation to certification and accreditation with government oversight. Furthermore, the new nanotechnologies pose a number of critical issues for OSH in that they (1) are largely novel and as yet ill-defined, (2) demand the creation of new or modified measurements and measuring devices, and (3) are peculiarly reflexive in the sense that they may be used to enhance measurement of and testing for OSH, and perhaps to improve OSH even as they pose OSH issues. Finally, these technologies raise important issues of control over testing: As nanotechnologies shrink the size and reduce the cost and time involved in testing – as agencies can be put on a chip – who will control which tests will likely be highly contested. An informed policy would be based in part on the expectation that the current tools, organization, and division of labor for OSH is likely to change, perhaps in some unpredictable ways.
Critical Toxicity Parameters for Nanoparticles vs. Conventional Particles
Vincent Castranova, Ph.D.
Nanotechnology is a system of innovative methods to control and manipulate matter at the near-atomic scale to produce new materials, structures, and devises. Nanoparticles are a specific class or subset of these new materials, having at least one dimension that is less than 100 nanometers. Nanoparticles exhibit unique physical and chemical properties due to their nanoscale dimensions. Nanotechnology offers the potential for tremendous improvements and advances in many areas that may benefit society, such as integrated sensors, semiconductors, medical imaging, drug delivery, structural materials, sunscreens, cosmetics, coatings, environmental remediation, and many other uses. Nanotechnology is one of the most rapidly growing industries across the world. By 2015, the global market for nanomaterials and nanotechnology-related products is expected to reach $1 trillion and employ 1 million workers in the United States alone.
Because of their small size and large surface area, engineered nanoparticles may have chemical, physical, and biological properties distinctly different than fine particles of the same composition. Such properties may include a high rate of pulmonary deposition, the ability to translocate from the lung to systemic sites, the ability to penetrate dermal barriers, and a high inflammatory potency per mass.
The National Institute for Occupational Safety and Health has developed a Nanotechnology Safety and Health Research Program in 2004. This Program involves multi-disciplinary research in development of methods to measure and characterize nanoparticles, exposure assessment, hazard identification, and risk assessment. This presentation will describe NIOSH research concerning the pulmonary, cardiovascular, central nervous system, and dermal effects of exposure to various nanoparticles.
Health and Safety Practices in the Nanotechnology Workplace: Results from an International Survey
Joseph Conti, M.A.
This presentation reports key findings of an international survey of nanomaterials organizations regarding environmental health and safety (EHS) training, engineering controls, personal protective equipment (PPE), exposure monitoring, waste disposal, product stewardship practices, and risk characterization. While many organizations reported disbelief that the nanomaterials they either handle or produce pose special risks, most organizations reported implementing some nano-specific safety measures. Further, while there were some reports of innovation in nano-specific EHS, the details of reported nano-specific health and safety workplace protocols appeared mostly derived from conventional practices when compared to existing industry and government EHS recommendations and conventional chemical hygiene practices. Justifications for employing reported practices ranged from strictly precautionary to nano-specific concerns for workplace hazards. The overwhelming majority of organizations expressed a need for greater information and guidance from researchers and governments towards improving health and safety and product stewardship practices for handling nanomaterials. The study reaffirms calls for research on nanotoxicology and best EHS practices, including examination of novel nano-specific EHS practices identified in this study, and the degree to which conventional chemical hygiene protocols are protective in the workplace and beyond.
Risk Governance and Risk Dialogue – an Insurer’s View
Thomas K. Epprecht, Ph.D.
Nanomaterials are opening up opportunities that seem as limitless as the nanometre is minuscule. Enthusiasm has spread beyond the small group of nano-experts to growing numbers in the business and scientific communities who claim that a real industrial revolution is under way, embracing one sector after another.
Some of this is hype; much is not – and great opportunity is always accompanied by risk. Insurers, as risk-carriers, must be able to recognize and understand emerging risks; only in that way will they be in a position to safeguard their clients over the long term against the financial consequences of adverse events, and so enable economy and society to take the risks that allow them to move forward.
Always Read the Small Print: Economics of Risk Assessment in Nanotech OSHA Issues
Richard Freeman, Ph.D.
There are two fears about the interrelation between nano-technology and occupational health and safety. The first is that some currently unforseen risk will surface and cost worker health and huge expenses to firms, per asbestos. Imagine the impact of a headline "sperm count down because of reproductive toxicity of metal oxide nanoparticles. The second is that unfounded fear of the technology will reduce its spread and investments of firms. Five decision-making groups will determine social response to these fears: firms, and insurers; workers and union organizations representing them; regulators and administrators; consumers; and scientists and engineers. Economic analysis applies benefit-cost calculations to these issues. In addition to the basic knowledge/estimates of benefits and costs of health, the analysis highlights the potential that nano-particles can affect social behavior, per the contribution of lead to crime. It depends critically on the discount rate applied to benefits and costs (per debates over the economics of global warming) and of risk aversion that depends on the whole distribution. The big problem is that most distributions of risk have fat tails. I propose that analyses focus on worst case scenarios and that betting markets be used to combine the disparate information of various experts for risk assesment.
What the Field of Nanotechnology Can Learn from the Nuclear Power Experience
William R. Freudenburg, Ph.D.
Nanotechnology currently occupies a position with more than a little resemblance to a status that nuclear technologies once enjoyed. This may seem surprising, given that nuclear power may offer the 20th Century’s clearest illustration of the loss of scientific credibility, but for decades after the splitting of the atom, nuclear technologies enjoyed widespread and even enthusiastic support, being endorsed not just by the scientific elite, but also by many of the leading environmental activists of the day, including the Sierra Club. Nuclear technology was also supported by a “public education” budget that present-day proponents of nanotechnology can only envy —- all duing the pre-Watergate years when the government enjoyed considerably more credibility than it does today.
The high levels of public support continued for roughly forty years. The support, however, quickly became a matter of history after less favorable kinds of “education” were produced by what Slovic has called “signal” events —- those sending “signals” that nuclear technologies were not being managed with the degree of vigilance that the public saw as being necessary.
As the nuclear experience illustrates, trust is easy to lose, but difficult to build —- even for a field of technology that initially appears to have a nearly boundless future. Given that a small number of unfortunate incidents can create a major problem of credibility, it stands to reason that the persons with the strongest incentives for preventing even “minor” lapses in the protection of human health and the environment would be precisely those who care the most about the long-term future of nanotechnology.
Biased Judgment about Risk as a Regulatory Matter
Barbara Herr Harthorn, Ph.D.
Science, government, and industry are all concerned about the possibilities for social amplification of nanotech risk perception among the US public. Congressional aims for nano societal implications research “to avoid public misunderstanding” and mandated public participation in nanotech R&D reflect such concerns, and the CNS-UCSB is engaged in the study of nanotechnologies’ potential for such amplification.
However, lessons from other worker risk perception research point to a far less frequently discussed problem in hazards research—that of the attenuation of risk. California farmworkers exposed to agricultural chemicals in the workplace display forms of attenuated risk perception (optimistic bias) about their exposures and likelihood of sustaining harm. California’s pesticide regulation system is widely regarded as the best in the country, yet worker exposures are frequent and many go undocumented. Consistent with the privatization of risk in many other spheres of society, strong emphasis has been placed on worker self protection as the preferred method to reduce workplace exposures. However, workers displaying optimistic bias about risks are not going to take self protective measures. Similarly, attenuation of perceived risk is a widespread finding among many kinds of experts. If neither experts nor workers in the nanotech context are likely to engage in adequate self and other protection from workplace exposure risks, then such protection should be a matter for policy makers.
Environmental Considerations in Nanomaterials Health and Safety
Patricia. A. Holden, Ph.D.
The external environment constitutes an important destination for engineered nanomaterials with many and diverse implications for human society. Benefits of nanomaterials and nanotechnology broadly to the environment are in environmental quality and pollution monitoring, pollution cleanup or remediation, clean energy production, energy conservation, and efficient water purification. Such beneficial applications involve deployment of nanomaterials into air, water or soil either as nano-sized particulates or embedded within matrices. As with any manufactured material either deployed or released into the environment, additional considerations regard the spatial extent of either controlled or uncontrolled transmission, physical or chemical modifications, longevity, effects on organisms by either native or modified forms, and society’s ability to manage outcomes when needed. In this presentation, environmental benefits and concerns of engineered nanomaterials are reviewed. Primary data in support of relevant potential biological interactions in the environment are used to exemplify specific nanomaterials fates. Additional environmental considerations, beyond those commonly delineated in the nano-safety and risk literature, are discussed. Needs for new information are suggested against the backdrop of how society already manages analogous concerns with existing, particulate and non-particulate, industrial materials.
Modeling Uncertain Health Impacts and Production Costs of SWNT Manufacturing
Jacqueline A. Isaacs, Ph.D.
As nanotechnology moves from development to commercialization, there has been growing interest in understanding production costs and occupational health risks associated with various nano-manufacturing processes. Recent papers (EPA 2007; Maynard 2006) indicate that engineered nanomaterials may present potential risks to human health. Nanomaterials that are most likely to present health risks include nanoparticles, agglomerates of nanoparticles, and particles of nanostructured material.
Commercialization of nanotechnology continues to progress, however, with limited guidelines on safe work practices (NIOSH 2006). Because it may take several years to generate information and consensus, Monte Carlo (MC) simulation risk models may help explore the potential consequences of and tradeoffs between manufacturing costs and health risks, given the uncertainty about occupational exposure and EHS regulations.
Using classical risk analysis and Bayesian uncertainty approaches, we have developed a preliminary Monte Carlo simulation model to explore the potential range of production costs and health effects associated with various levels of occupational safety requirements (engineered controls, personal protective equipment, etc.). Production costs for alternate manufacturing processes (HiPco, arc ablation, chemical vapor deposition) of single wall carbon nanotubes (SWNTs) were calculated for four alternatives in industrial hygiene practice. Uncertainties in the extent and the timing of possible requirements and the occupational health dose-exposure relationship are represented by probability distributions and chance events. Since the risks for commercializing SWNTs are likely to remain unclear for the foreseeable future, these models allow analysis of various scenarios and economic-safety-health tradeoffs. Preliminary results suggest that in some cases, voluntary adoption of standards higher than initially required can lead to the lowest expected cost with the least uncertainty.
Report from the 3rd International Symposium on Nanotechnology, Occupational and Environmental Health, August 2007, Taipei
Nancy Jennerjohn, M.S.
How are researchers in science and industry throughout the world the same and different in how they view their responsibilities for worker health and safety in the nanotechnology workplace, and in their concern over the effect of their industrial activities on their own natural and urban environments? This conference is designed to bring speakers from around the world together for two days of presentations, followed by an all day “industrial forum” on the third and final day. What happened at this conference? Was a consensus reached, or did dialog fail? Find out, as Ms. Jennerjohn summarizes the main events and also shares her perspective on the nanotechnology industry’s response to its workers and the environment in a broader global context.
Local Oversight of Emerging Technologies: The Cambridge Experiment
Sam Lipson, M.S.
The public response to risks introduced by emerging technologies is historically shaped by the novelty of that risk, the perceived benefits associated with that research or manufacturing, and the extent to which that sector is seen as a good-faith participant in efforts to establish reasonable public accountability and assurance in three areas: occupational and public health risk, environmental risk, and consumer risk. The agencies responsible for product and drug safety (federal) or for environmental compliance and management (mostly state and federal) are struggling to address the challenging uncertainties posed by nanomaterials and the products or therapies that utilize these materials. It is widely accepted that there must be a framework for understanding and managing risk and uncertainty from these processes , materials and products that is capable of working around the extensive absence of data for evaluating these risks. Strategic plans for filling in the most critic gaps in toxicological information and occupational exposure dynamics are being plotted as we meet. This is not an easy task and there is a great risk posed by the hydra-headed nature of this enterprise.
Protection of workers and residents from local hazards, unlike consumer protection or environmental enforcement, has been commonly recognized as a responsibility that is shared between state, federal and local officials with public health responsibilities. These agencies include OSHA, NIOSH, EPA, and many state-level enforcement offices. When there is an enterprise that is perceived to have insufficient or absent oversight at the state or federal level some communities have a history of local regulation of these hazards or practices. The decision to take on a vanguard policy to address perceived public risk in an emerging technology sector is familiar to the city of Cambridge, Massachusetts.
In 1977, after a tumultuous debate that resulted in a moratorium on recombinant DNA experimentation or gene-splicing, Cambridge established the first local biological safety regulation in the world. The form of this oversight has evolved from a setting in which this work was rarified and found only in a select number of academic laboratories to the present time, with a large biopharmaceutical sector in the community (over 60 firms or institutions holding permits).
As we are now evaluating local oversight options to address uncertainties around nanomaterials exposures I look back on the lessons learned from the evolution and enforcement of the Cambridge Recombinant DNA Technology Ordinance. I will discuss the mistakes and great successes that accrued to Cambridge by enacting local rules to address risk from the emerging biotech sector and consider the parallels and incongruities with the nanotechnology sector.
‘A Gift of God?’ The Promise and Peril of New Technologies in the 20th Century
Gerald Markowitz, Ph.D.
This presentation will explore cases from the twentieth century where new technologies or substances have been adopted and how public health and industry representatives have struggled over the potential harms and benefits of such changes. It will explore the historical antecedents of the modern arguments over the precautionary principle and specifically, the tension between public health principles and the interests of corporations who have extolled the benefits of new technologies and argued that their economic interested should not be undermined until science has proven that their new product or technology is dangerous.
John Monica, J.D.
This comment will focus on potential legal issues accompanying the use of nanoscale materials in the workplace and how proactive consideration of such issues is necessary for the successful commercial development of nanotechnology. Particular emphasis will be placed on NIOSH's June 2007 nano-workplace report and EPA's July 2007 concept paper for its Nanoscale Materials Stewardship Program. Mr. Monica will also comment on the presentations of speakers from NIOSH and UCLA's Center for Occupational and Environmental Health.
Predictive Toxicological Paradigms for the Assessment of Nanoparticle Toxicity
Andre Nel, M.D., Ph.D
Because of the large number of new nanomaterials that are being produced, it is of increasing importance to develop a platform for safety and risk assessment. It is probably not advisable to follow the example of chemical industry where the production of more than 80,000 industrial chemicals has overwhelmed toxicological screening capabilities. Toxicity testing has only been achieved for a few hundred chemicals and as a result, new examples of chemical toxicity show up every year, often with devastating consequences to humans and the environment. One of the principal stumbling blocks in assessing chemical toxicity has been the cost and the logistics to perform animal and in vivo studies. An intuitively more enlightened approach for nanotechnology would be to develop high throughput screening methods that incorporate a relevant toxicological injury mechanisms that can be related to the physicochemical properties of nanomaterials. I will discuss the emerging paradigms of toxicity that can be linked to the physicochemical properties of engineered nanoparticles with a view to outlining scientific principles that originate at the nano/bio interface and could determine whether interactions fail to occur, are biocompatible or injurious in nature. The major toxicological paradigm that have emerged from nanoparticle toxicity relates to the semiconductor, electronic, UV activation, and redox cycling chemistry of the particles, which allows them to induce tissue damage through the generation of oxygen radicals, electron-hole pairs and oxidant injury. It is possible to follow the oxygen radical generation and oxidant stress injury by abiotic methods as well as a set of hierarchical cellular responses that reflect protective, pro-inflammatory, mitochondrial damaging and pro-apoptotic outcomes. An oxidant injury pathway could translate into adaptive, pro-inflammatory or pro-apoptotic cellular effects in the lung, cardiovascular system, skin and the brain. Another important paradigm relates to the ability of nanoparticles to absorb circulatory or cellular proteins as a function of particle size, surface area, functionalized surface groups, charge, hydrophobicity/hydrophilicity etc. This could induce protein unfolding, protein fibrillation, thiol crosslinking and loss of function, which could lead to neurotoxicity, loss of enzymatic activity, and generation of immunological responses. The thermodynamic properties and free surface energy of nanoparticles as a function of particle size, composition, phase and crystallinity could be responsible for particle dissolution in a biological environment, leading to the generation of cytotoxicity through the release of toxic ions or chemicals. Data are also emerging that indicate that cationic nanoparticles exert toxicity through the so-called proton sponge hypothesis, which postulates that particle uptake via acidifying endosomes leads to cellular toxicity through endosomal rupture, cytosolic deposition and mitochondrial targeting. The particle size, state of aggregation/dispersion, functional surface groups and hydrophobicity also plays an important role in determining the route of cellular uptake, subcellular localization and targeting of subcellular organelles. I will demonstrate that it is possible to devise high throughput screening methods to capture each of these toxicological mechanisms, which can then be used to classify nanoparticles into potentially hazardous and potentially safe. If used as a preliminary screen for newly emerging nanomaterials, these predictive science-based approaches can help to determine which materials should undergo priority testing in animal and in vivo exposure models. The knowledge gained from this approach will also reveal which nanomaterial properties are useful to promote biocompatibility.
DuPont-Environmental Defense Nanorisk Framework and the Nanoparticle Occupational Safety and Health Consortium
Michele L. Ostraat, Ph.D.
This presentation will discuss two collaborative efforts, including i) the development of a versatile and flexible Nanorisk Framework for evaluating and addressing the potential risks of nanoscale materials and ii) the findings from a multi-stakeholder consortium that focuses research on occupational safety and health associated with aerosol nanoparticles and workplace exposure protocols.
Environmental Defense, an environmental advocacy organization, and DuPont, a science-based products and services company, have developed a comprehensive, practical, and flexible framework for evaluating and addressing the potential risks of nanoscale materials. The intent of this framework is to define a systematic and disciplined process for identifying, managing, and reducing any environmental, health, and safety risks of engineered nanomaterials across all stages of a product’s lifecycle. Our framework offers guidance on the key questions an organization should consider in developing applications of such materials, and on the key information needed to make sound risk-evaluation and risk-management decisions. The framework allows users to move ahead despite areas of incomplete or uncertain information, by using reasonable assumptions and by compensating for knowledge gaps with appropriate risk-management practices. Further, the framework describes a system to guide information generation and update assumptions, decisions, and practices with new information as it becomes available. The framework also offers guidance on how to communicate information and decisions to key stakeholders. The framework is intended to be relevant to a broad range of materials and applications, so that it can be accepted, endorsed, and adopted or adapted for use internationally by a wide range of stakeholders, including other companies, other public interest groups, academia and government agencies.
The Nanoparticle Occupational Safety and Health (NOSH) Consortium of international industrial, government and non-governmental organizations has focused research during the last two years upon generating science-derived knowledge on occupational safety and health questions associated with aerosol nanoparticles and workplace exposure monitoring and protocols. The technical goals of the NOSH Consortium include 1) generating well-characterized aerosols of solid nanoparticles and measuring aerosol behavior as a function of time; 2) developing an air sampling method that can be used to conduct worker exposure assessments in workplace settings; and 3) measuring barrier efficiency of filter media to specific engineered aerosol nanoparticles. With the completion of the main phase deliverables, several technical advances have contributed significant understanding of the synthesis and behavior or aerosol nanoparticles, the monitoring of aerosol nanoparticles in the workplace, and the performance of specific filter media upon exposure to aerosol nanoparticles.
The Developing Nanotechnology Occupational Safety and Health Landscape
Jaideep Raje, M.S.
While the spotlight on nanotech’s impact on the end user and the environment continues to wax and wane, the discussion around its impact on the workforce is just starting in earnest. Despite growing interest, however, limited progress has been made. Uncoordinated research hasn’t clarified the picture on real risks significantly, while interest groups are driving perceptual risks in contrary directions. Regulatory agencies are reaching out to the nanotechnology community for data, but the process of formulation regulations will take years to draw to a conclusion. In the interim, nanotechnology firms should escalate efforts to understand real risks of the nanomaterials they produce and use – and aim to be free with their findings to both the public and regulators. The resulting data can contribute to shaping a balanced regulatory environment, and enable a more informed public dialogue which balances benefits of nanotechnology with the risks.
The talk will establish a framework whereby nanotech EHS and OSH issues can be studied, review the global nanotechnology-related safety and health initiatives surrounding different nanomaterial classes, delve into the key outstanding issues and propose a path forward.
Potential Workplace Hazards of Nanotechnology
Paul A. Schulte, Ph.D.
In the workplace, the primary health concern about nanotechnology pertains to exposure to engineered nanoparticles. The basis for the concern derives from two bodies of evidence. One is a history of human and animal research on fine and ultrafine incidental particles that demonstrates pulmonary and cardiovascular effects from exposure. The second is the relatively recent experimental investigations of engineered nanoparticles in various animal models that show a variety of serious pulmonary and cardiovascular effects and the capability of entering the systemic circulation and reaching various organ systems. The body of scientific evidence suggests that the biological activity and potential toxicity of nanoparticles are greater than larger particles of the same material (on an equivalent mass basis)l. However, the impact of particle size on biological activity may be influenced by other parameters such as surface reactivity, functional group attachments, and other physico-chemical characteristics of the particles. Although much more research is needed to identify and characterize hazards, extent of exposures and degree of risk, there is sufficient information to warrant that exposures be strictly controlled. In general, airborne nanoparticles appear to conform to the laws of classic aerosol physics and should be amenable to control by conventional dust control measures; however, the limits of these controls and other mitigating factors still need to be determined. Additionally, the potential for skin exposure and absorption of engineered nanoparticles is not well understood but preliminary research indicates that nanoparticles can penetrate some protective clothing and the skin. Also, studies of neuronal translocation of nanoparticles to the brain require further investigation. All of these findings and conclusions pertain to the first generation of passive nanoparticles. It is not known if the ensuing generations of engineered nanoparticles which will have various interactive capabilities will present additional hazards.
Vivian Weil, Ph.D.
The focus on occupational health and safety must include attention to workplace practices. Standards of care announced or embedded in workplace practices are especially important in the face of rapidly advancing nanotechnology commercialization. These standards are even more crucial when, as now, there is little government regulation and little is known about health effects on humans. Workplace safety policies express standards of care and levels of commitment to responsible practice in the workplace. Hence, such policies should be looked at with regard to two related concerns: occupational health and safety and responsible workplace practices.
A major contribution from the Illinois Institute of Technology component of the Harvard/UCLA CNS NSEC is the creation of NanoEthicsBank (NEB), an innovative, selective database of ethics-related material. In the course of developing NEB, the librarian of the IIT Center for the Study of Ethics in the Professions conducted a survey of nanotechnology businesses to learn about their workplace safety policies. Questionnaires prepared in consultation with social scientists were sent to 300 companies (76% U.S., 24 % international) selected from the NEB and a directory of firms and startups on Nanotechnology Now Web site. Companies ranged from large multinationals to small startups, chosen neither by type of product nor size of company.
The response rate of 12% requires caution in interpreting results, but responses nevertheless merit attention. 40% of the companies surveyed reported frequently carrying on discussions about potential problems and 46 % reported having adopted workplace safety guidelines. Yet, 30% included written comments explaining that their nanotechnology was unlikely to pose health or environmental risks. Respondents worried that the entire field of nanotechnology might become over-regulated because, as one respondent stated, “We’re concerned that guidelines will be developed for nanotechnology that are narrowly applicable to nanoparticles.”
Rather than picking up the questionnaire’s slant toward voluntary standards, these respondents voice a familiar business concern about prospective restrictions from government regulation. Applying the famously ambiguous term ‘nanotechnology’ to their enterprises, the responders apparently want to exempt their activities from regulation that they seem to admit is appropriate for nanoparticles. As observers note, the definition of ‘nanotechnology’ is both “contentious and consequential” (Davies, J.C. 2007 EPA and Nanotechnology: Oversight for the 21st Century. Woodrow Wilson International Center for Scholars: Washington, DC. ) There is no settled definition, and how it is defined has consequences for the management, marketing, and oversight of nanotechnology.
Regarding voluntary standards, a future task for NEB is to seek applicable existing statements of good practices (e.g., from the chemical industry) and examples of nanotechnology companies that foster good practices. Regarding the definition of ‘nanotechnology’, the efforts of standards setting organizations may help to produce agreement. Conferences such as this may contribute needed clarification.
John Barlow Weiner
The US Food and Drug Administration regulates a wide range of products, including foods, cosmetics, drugs, devices, and veterinary products. In July, 2007, FDA's Nanotechnology Task Force released a report on oversight for FDA regulated products that use nanotechnology. The Task Force reports that nanoscale materials potentially could be used in most product types regulated by FDA and that those materials present challenges similar to those posed by products using other emerging technologies. The challenges, however, may be complicated by the fact that properties relevant to product safety and effectiveness may change as size varies within the nanoscale. The report concludes that the emerging and uncertain nature of nanotechnology and the potentially rapid development of applications for FDA-regulated products highlight the need for ensuring transparent, consistent, and predictable regulatory pathways. The report recommends consideration of agency guidance that would clarify, for example, what information to give FDA about products, and also when the use of nanoscale materials may change the regulatory status of particular products. In addition, the report calls for assessment of data needs for regulation of products using nanotechnology, including data on biological effects and interactions of nanoscale materials. The report also calls for development of in-house expertise and for the agency to ensure consideration of relevant new information on nanotechnology as it becomes available. In addition, the report recommends that FDA evaluate the adequacy of current testing approaches to assess safety, effectiveness and quality of nanoscale materials. In addition to its internal efforts, FDA is working with other federal agencies, with its foreign counterparts, and multilaterally to address regulatory issues relevant to the agency's mission to protect and promote the public health. This presentation will discuss the Nanotechnology Task Force's report and these other efforts.
Jim Willis
In early 2007 EPA issued a white paper on nanotechnology describing the Agency’s science and research needs to support EPA’s mission to protect human health and the environment. The white paper has provided a springboard for cross-agency engagement in a number of areas, including the review of new chemical nanomaterials before they come onto the market; the development of a nanoscale material stewardship program (NMSP) to get reporting on and testing of nanomaterials currently on the market; the exploration of life-cycle issues associated with nanomaterial manufacture and use; and, international leadership through the Organization for Economic Cooperation and Development (OECD) in advancing international cooperation, harmonization and burden sharing in understanding and mitigating the potential risks of nanomaterials to human health and the environment. The presentation will describe these initiatives and provide a forward-looking report on their status and future development.
Commercial Adoption of Nano-Titanium Dioxide Production
Lynne Zucker, Ph.D.
Michael Darby, Ph.D.
Ali Emre Uyar, Ph.D.
This paper will investigate trends in commercial Titanium dioxide (TiO2) usage in nanotechnology related applications as well as make projections about the rate of adoption as the TiO2 industry transforms from traditional to increasingly nano-based. The purpose is to produce a reasonable upper bound for nano-TiO2 usage in the coming years to be used in toxic risk assessments.
Being an innovation driven field, traces of future trends in commercial nanotechnology applications can be found in the past indicators of knowledge accumulation. Using USPTO patents by application date, articles published in academic journals by affiliated scientists, and awarded government grants, we deduce how the amount of innovative activity in titanium dioxide moves from traditional areas to new, nanotechnology specific uses. Comparing this rate of transformation in innovation to those of other high-tech fields (such as biotechnology) enables us to make estimations about the rate of transformation in production. These estimates are used to produce projections about the share of nano-specific activity within the total TiO2 production. We argue why the estimates provide reasonable upper bounds for future nano-TiO2 usage and how they can provide a reasonable basis for assessing the potential toxic and/or exposure risk in the near future.
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