The Hierarchy of Environmental Health and Safety Practices in the U.S. Nanotechnology Workplace

Abstract

Manufacturing of nanoscale materials (nanomaterials) is a major outcome of nanotechnology. However, the potential adverse human health effects of manufactured nanomaterial exposure are not yet fully understood, and exposures in humans are mostly uncharacterized. Appropriate exposure control strategies to protect workers are still being developed and evaluated, and regulatory approaches rely largely on industry self-regulation and self-reporting. In this context of soft regulation, the authors sought to: 1) assess current company-reported environmental health and safety practices in the United States throughout the product life cycle, 2) consider their implications for the manufactured nanomaterial workforce, and 3) identify the needs of manufactured nanomaterial companies in developing nano-protective environmental health and safety practices. Analysis was based on the responses of 45 U.S.-based company participants in a 2009–2010 international survey of private companies that use and/or produce nanomaterials. Companies reported practices that span all aspects of the current government-recommended hierarchical approach to manufactured nanomaterials’ exposure controls. However, practices that were tailored to current manufactured nanomaterials’ hazard and exposure knowledge, whether within or outside the hierarchical approach, were reported less frequently than general chemical hygiene practices. Product stewardship and waste management practices—the influences of which are substantially downstream—were reported less frequently than most other environmental health and safety practices. Larger companies had more workers handling nanomaterials, but smaller companies had proportionally more employees handling nanomaterials and more frequently identified impediments to implementing nano-protective practices. Company-reported environmental health and safety practices suggest more attention to environmental health and safety is necessary, especially with regard to practices that can cause external effects. Given reported impediments, smaller companies may especially benefit from more attention. However, the manufactured nanomaterial workforce within smaller companies is particularly difficult to identify and hence locate, posing challenges to developing and enforcing appropriate workplace environmental health and safety.

[Supplementary materials are available for this article. Go to the publisher's online edition of Journal of Occupational and Environmental Hygiene for the following free supplemental resource: a file containing Survey of Current Health and Safety Practices in the Nanomaterial Industry and a file containing figures.]

Keywords:

• nanomaterials
• health and safety
• hierarchical approach
• life cycle analysis
• government guidance
• industry survey

ACKNOWLEDGMENTS

This work was supported by Coop. Agreement DBI-0830117 from the U.S. National Science Foundation (NSF) and the EPA to the University of California Center for Environmental Implications of Nanotechnology; and by Coop. Agreements SES 0531184 and SES 0938099 from the NSF to the Center for Nanotechnology in Society at the University of California, Santa Barbara.

The authors appreciate the editorial and anonymous reviewer comments and suggestions. The authors sincerely thank the anonymous survey participants who made this study possible and S. Anderson, R. Appelbaum, J. Conti, M. Delmas, S. Frederick, Y. Motoyama, and J. Youtie for their contributions to this study. Representatives from government and industry also provided helpful feedback on the survey instrument and references for participation: M. Ata, C. Geraci, M. Hull, F. Klaessig, K. Kulinowski, R. Lally, K.W. Lee, and M. Sekiya. Y. Ge, S. Werth, and Q. Yang provided translation services.

Any opinions, findings, and conclusions or recommendations expressed in the material are those of the authors and do not necessarily reflect the views of the NSF or the EPA. This work has not been subjected to EPA review and no official endorsement should be inferred.