# Presentation: 563936

## Nanotechnology: Hazard Communication Issues2006 NRT Worker Safety and HealthTechnical ConferenceMay 31, 2006This copy approved for distribution through the DOE IH/OS SIG

**Bruce Lippy, Ph.D., CIH, CSP**
**Environmental Profiles, Inc. Baltimore, MD 21228, 410.744.0700**

## A comment for the NEHI subcommittee

**Good work! An impressive example of the federal government being proactive and cooperative on H&S issues**

**Notes:**
I want to say something to the NEHI committee while I have the forum. You are doing important work. It is the most impressive example of the federal government being proactive on a health and safety issue and it is going to be a major issue. After the sad history of  toxins asbestos, vinyl chloride, berrylium and other toxins in the workplace, it is great to see this. As Nigel Walker pointed out, “It was kind of where dioxins and PCBs were in the '60s," said Nigel Walker, a staff scientist with the National Toxicology Program (NTP) of his initiation into nanotechnology about three years ago. NTP, part of the National Institutes of Health's environmental sciences division, has launched a program to evaluate potential health hazards of nanomaterials. Dioxins, a byproduct of combustion processes, and polychlorinated biphenyls, an industrial chemical, were found to be cancer-causing pollutants that required costly cleanups once their toxicity was discovered. 
"We introduced a technology without understanding the implications and then spent 30 years trying to eliminate or reduce the risk," Walker said. He recognized that with nanotechnology he and other scientists had an opportunity to spot troublesome nanoparticles early in the commercial process, before they cause damage. "Now we can make sure we can prevent that. We can choose the kinds of experiments that reduce the risk. We can be at the forefront." 

## Objectives At the end of this session, I would like you to be able to:

**List several reasons that the standard MSDS format may prove inadequate for nanomaterials**
**Describe findings from the Hazcom literature that may prove useful in creating effective communication strategies for nanomaterials**
**Describe several findings from research on Technology Safety Data Sheets that may have implications for nanotechnologies.**

**Notes:**
Learning Objectives
At the end of this module, the peer-trainers will 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 efforts

**Bought “Nanotech for Dummies”**

**Got 30% off**

**Notes:**
I got that information from my research effort. I bought “Nanotechnology for Dummies” It was 30% off. Now who’s the dummy?

## The promise is impressive, but let’s address the following:

**Is it too soon to talk about Hazcom?**
**Who are the exposed worker populations? What do we know about their demographics?**
**Will the current approach to Hazcom be sufficient for nanomaterials?**

## Is it too soon to talk 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 about Hazcom?

**Nanotech Product Recalled in Germany**
- Rick Weiss, Washington Post Thursday, April 6, 2006

**CPSC recall of spray grout sealer 8-2005**

**Notes:**
The April 6th Washington Post carried an article about a nanoproduct recall in Germany. The article made it sound like respiratory problems caused by the nano-sized particles were the reason for the recall. However, similar products have been documented in the literature, going back to the 70s as a source of similar health complaints. The CPSC in this country actually recalled a spray grout sealer in August of 2005.  This journal article by Vernez et al. (JOEH May 2006) noted that waterproofing agents are widely used to protect leather and textiles in both domestic and occupational activities. An outbreak of acute respiratory syndrome following exposure to waterproofing sprays occurred during the winter 2002– 2003 in Switzerland. About 180 cases were reported by the Swiss Toxicological Information Centre between October 2002 and March 2003, whereas fewer than 10 cases per year had been recorded previously. Outbreaks of respiratory failure following the use ofwaterproofing sprays occurred in Germany between 1979 and 1983,(2,3) and in the United States, Canada, and Japan in 1992–1993.(4−6)

**Courtesy Andrew Maynard**
**Wilson Center for Scholars**
**Around 200 consumer products:**
** **

- _[www.](http://www.nanotechproject.org/consumerproducts)__[nanotechproject](http://www.nanotechproject.org/consumerproducts)__[.org/](http://www.nanotechproject.org/consumerproducts)__[consumerproducts](http://www.nanotechproject.org/consumerproducts)_

**Notes:**
This is the most complete database of consumer products. The criterion they used: 
1) Readily purchased by consumers
2) Identified as nano-based by the manufacturer OR another source, and 
3) The nano-based claims for the product appear reasonable.

## Product categories

**Product categories**

**Notes:**
This is how the Wilson Center characterized the 200+ products in March of this year. Note that health and fitness was by far the major category with 125 products, the next category was electronics and computers with 30 and then home and garden with 21. Food and beverage was next, I assume we are taking the microbrewery kick to the nano level.

## Health and Fitness Subcategories

**Health and Fitness Subcategories**

**Notes:**
When you break down the health and fitness category, you see that clothing, sporting goods, cosmetics and personal care dominate.

## Region of Origin

**Region of Origin**

**Notes:**
Good news in regions of origin, the U.S. produced more of these products then the other regions combined.

## Major Materials

**Major Materials**

**Notes:**
Of particular importance to health and safety, carbon was the leading material reduced to nano size, followed by silver and then silica

##  Review of Products in the Database

**Selected 10% of the 200 using a random number table**
**Searched their website for safety information, particularly MSDSs**
**Submitted written request for MSDSs through website or called.**
**Found 1 MSDS out of 20 sites**

**Notes:**
My firm conducted a review of the products in this database. We randomly selected 10% (20) of these products. Why only 10%? It was pro bono work.

##  My favorite nanoproduct: Anti-graffiti PaintDeletum 3000+

## My Guess: used to remove nano-graffiti

**Image courtesy Justin Kumar, Ph.D., Indiana University**

**Notes:**
This is my best guess on the purpose of Deletum 3000: removing nano-graffiti like this computer simulation of graffiti on the head of this milkweed bug, Oncopeltus fasciatus 

## Example MSDS Received

**Advanced Nanotechnology’s**
**	****ZinClear (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: NanoWax

**Notes:**
Here is another example: a product called NanoWax. The finer particles apparently fill in scratches and swirl marks in the paint and reflect light better. I don’t wash my car, so I can’t vouch for this product.

## NanoWax MSDSSection 8: Exposure Controls/PPE

**WAX 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?**

**Notes:**
 If we look at the chemicals in the  product, there is no indication which component is nano-sized. I have highlighted aluminum silicate as a likely candidate.  I also ask if it is important in this application because it is a wax.

SECTION 8: EXPOSURE CONTROLS/PERSONAL PROTECTION 
WAX 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 VPEL 50.000 ppm - Ceiling  
  ACGIH TLV 100.000 mg/m3 - Ceiling as an aerosol  
No indication which component is nano-sized. Is it important in this application? I assume the aluminum silicate, but since I never seem to wash my car, I don’t know.

## MSDS for Multi-walled Carbon Nanotubes

**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**

** **

**Notes:**
Here is an MSDS for Mult-walled carbon nanotubes

## MSDS for Multi-walled Carbon Nanotubes, Section 11 Toxicology

**“****To the best of our knowledge the chemical, physical, and toxicological properties have not been thoroughly investigated.”**

**Cambridge University, **
**Department of Metallurgy**

**Notes:**
May be harmful if absorbed through the skin or swallowed
“To the best of our knowledge the chemical, physical, and toxicological properties have not been thoroughly investigated.”

Refreshingly honest, but is it helpful?
Must the toxicology be thoroughly investigated to warn of possibly greater risk?

## Toxicology 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**

**Notes:**
“To the best of our knowledge the chemical, physical, and toxicological properties have not been thoroughly investigated.”
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.”

Nanotoxicology: An Emerging Discipline Evolving from Studies
of Ultrafine Particles
Günter Oberdörster,1 Eva Oberdörster,2 and Jan Oberdörster 3
Environmental Health Perspectives • VOLUME 113 | NUMBER 7 | July 2005

Multiwalled carbon nanotubes (MWNTs) showed proinflammatory effects and were internalized in keratinocytes (Monteiro-Riviere et al. 2005). Again, the relatively high doses applied in these
studies need to be considered when discussing the relevancy of these findings for in vivo exposures. A most recent study in macrophages comparing SWNTs and MWNTs with C60 fullerenes found a cytotoxicity ranking on a mass basis in the order SWNT > MWNT > C60. Profound cytotoxicity (mitochondrial function, cell morphology, phagocytic function) was seen for SWNT even at low conc.

## 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?

**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?  *****We don’t know***

**Notes:**
The chemical and semiconductor industries formed CBAN Consultative Boards for Advancing Nanotechnology. Their spokesperson at the October 2005 NEHI meeting was unable to characterize the population doing this work among their members. Andrew Maynard indicated he thought it was safe to assume this is a more highly educated workforce. NNI
The Georgia Tech-NNIN (GIT-NNIN) site will especially emphasize the application of nanofabrication to bioengineering and biomedicine. Much of the GIT-NNIN activity is carried out in the Microelectronics Research Center (MiRC). The MiRC is housed in its own 100,000 sq. ft. building that includes an 8,500 sq. ft. cleanroom (75% class 100, 25% class 10). The major fabrication facilities in the cleanroom include thin film deposition, plasma processing, optical and electron beam lithography (100 keV / 4nm spot size JEOL JBX 9300FS), thermal processing, electroplating, wafer lapping, polishing, dicing, bonding and sawing, wire bonding, flip chip bonding, III-V MBE growth, and a 2-metal/2-poly CMOS and MEMS line (ion implantation outsourced

## Who is exposed in 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)**

**Notes:**
No information has been identified about workers exposures to nanoparticles in the
university/research sector or in the new nanoparticle particle companies in the UK.
Only very limited information is available for existing chemical, pharmaceutical and
refining companies. Information from other powder handling process indicates that
exposures may be significant.
 Approximately 2000 people are currently employed in the university/research sectors
and new nanoparticle companies in activities in which they may potentially be
exposed to nanoparticles in some form. A maximum of 500 workers are considered to
potentially exposed to nanoparticles through existing ultrafine, manufacturing
processes, mostly the manufacture of carbon black. Around 100,000 individuals may
potentially be exposed to fine powders through various powder handling processes,
including the pharmaceutical industry. It is not possible to say what proportion of
these may be exposed to nanoparticles. More that 1,000,000 workers in the UK may
be exposed to nanoparticles via incidental production in processes such as welding
and refining.
 The number of people in the university/research sector, and in new nanoparticle
companies may double over the next five years. The proportion of those involved in
existing chemical and pharmaceutical companies and in other powder handling
activities who are exposed to nanoparticles is likely to increase.
In summary, we conclude that there is little evidence to suggest that the exposure of workers
arising from the production of nanoparticles has been adequately assessed.

## Will the current approach to Hazcom be sufficient for nanomaterials?

## Current 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 current regulations?

**“****New law may be required to manage potential risks of nanotechnology.” **
**(Davies, Wilson Center**
***Managing the Effects of***
***Nanotechnology*****) **

##  Sampling Issues,Courtesy Andrew Maynard, Wilson Center

**Notes:**
I am an industrial hygienist. I love the smell of calibration in the morning. It is the smell of victory. But what do we sample in this case? 

## ISO TC 229 Working Group on Health, Safety and the Environment

**Developing 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**

**Notes:**
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ISO Nanotechnologies TC 229 Meets in LondonU.S. to convene Working Group on Health, Safety, and the EnvironmentNew York  November 15, 2005 
The inaugural meeting of the International Organization for Standardization (ISO) Technical Committee 229, Nanotechnologies, was held in London, November 9-11, 2005. The American National Standards Institute (ANSI) assembled an impressive U.S. delegation led by Dr. Clayton Teague, chair of the ANSI-accredited U.S. Technical Advisory Group (U.S. TAG), and including representatives of industry, government, academia and the legal profession. 
During the meeting it was decided that rather than employing a subcommittee structure, ISO/TC 229 will approach the development of International Standards for nanotechnology within three working groups: terminology and nomenclature; metrology and characterization; and health, safety and the environment. The working groups will be convened by Canada, Japan, and the United States, respectively. The U.S. delegation spearheaded preferred modifications to the committee’s technical scope of activity and secured a position on a key formative task force. 
“The combination of excellent leadership, active participation by a broad base of nanotechnology experts, and ANSI’s collective expertise, ensured that the U.S. was able to successfully assume the international leadership role set as a goal at the onset of this activity just earlier this year,” said ANSI president and CEO Mark W. Hurwitz. 
According to the committee’s scope, ISO/TC 229 will produce standards for classification, terminology and nomenclature, basic 

## Review of Hazcom Literature  (Sattler, Lippy & 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 behavioral studies and appropriate test populations

**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?***

**Notes:**
This was one of the key findings from our review of the literature. There were precious few actual behavioral studies, observing what people do after receving an MSDS, warning label, etc. Instead they were asked what they would do. The populations tneded to be

## These are students. Do they look like workers?

## Nano lesson: assumptions can 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**

**Notes:**
Studies of the ANSI Z535.3-1991 protocol for testing found that the standard slash recommended by ANSI was not as effective as an "X" for warning consumers of prohibited uses. 

## The most shocking finding! (Sattler, Lippy & Jordan, 1997)

**	****Women more likely than men to look for and comply with warnings. **

**Notes:**
If safety information is perceived as familiar or redundant, it may simply be dropped from short-term memory, and have no further effect on behavior. Alternatively, if the information is perceived as inconsistent with existing knowledge and beliefs, it may be rejected as not credible. Even if the information is previously unknown and is accepted as true, the recipient may be insufficiently motivated to alter behavior. 

## Comparison of MSDS formats

**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**

**Notes:**
There has been little research comparing formats of safety data sheets but where comparisons have been made, the International Chemical Safety Cards have been ranked more effective than the other formats tested, including the recent ANSI format that is being promoted by industry and OSHA

##  Critical Finding on Comprehensibility

**	****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**

**Notes:**
On average, literate workers only understood about 60% of the health and safety information on sample MSDSs in three different comprehensibility studies This percentage was remarkably similar across the studies. 

## Potential lessons from Technology Safety Data Sheets

## Health and Safety in DOE’s innovative technologies program

**Health and Safety in DOE’s innovative technologies program**

**Several serious incidents**
**Small firms were the drivers**
**No hazard analysis and communication to workers**

**Robotic CO2 blaster**

## Concept of Technology Safety 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

**Available at:**
- _[www.](http://www.wetp.org/)__[wetp](http://www.wetp.org/)__[.org](http://www.wetp.org/)_

## Applicability to NanotechnologyPlasma Hearth Example

**There have been explosions at two separate facilities: one fatality, several injuries**

**Notes:**
The PHP is a high-temperature, thermal process developed for the treatment of mixed wastes. The process produces a reduced-volume, highly stable, vitreous product. Mixed wastes consist of sludge and miscellaneous debris that are lightly contaminated with radionuclides. This waste has been generated throughout the DOE complex for decades, packed into drums or boxes, and stored above ground or buried in shallow pits. An attractive feature of the PHP is that intact containers can be fed to the process without the need for opening, sorting, or sizing, thereby potentially reducing handling requirements, costs, secondary wastes, and worker exposures. Typical feed to a production-size PHP would be 208 liter drums, in which much of the accumulated mixed waste is stored. 
The PHP benchscale project features a reduced-scale system, fully configured for operation with radioactive waste materials. This system complements nonradioactive PHP systems that have been constructed and tested elsewhere using surrogate wastes. The benchscale project will determine the behavior and fate of radionuclides for comparison with the surrogate test results and assess the performance of the PHP from a broader perspective than has been done. 
 Figure 4. A schematic of the PHP. 1N2: 3 SCFM, 2propane: 10 SCFM, 3burner air: 35 SCFM; 4combustion air: 0-20 SCFM, 5N2 purge: 10 SCFM, 6feed: 5-14 kg/h, 7propane: 10-30 SCFM, 8burner air: 35-105 SCFM, 9combustion air: 0-40 SCFM, 10nozzle air: 20 SCFM, and 11nozzle water 0.2-0.4 GPM.The PHP uses an ultrahigh temperature plasma (in excess of 5,000°C) generated by a direct current, inert-gas-stabilized electric arc from a movable torch. The plasma torch is remotely directed at containers of waste materials that are fed into the refractory-lined, 1 m diameter by 1.3 m high processing chamber in a controlled atmosphere. The extreme temperatures produce chemical and physical alterations in the waste materials. Several processes occur, including oxidation, pyrolysis, and volatilization. Combustible pyrolysis gases generated in the primary process are oxidized in a propane-fired secondary combustion chamber. The remainder of the off-gas system consists of high-efficiency particulate air (HEPA) filtration, acid-gas scrubbing, temperature controls, and induced-draft machinery, with discharge of the clean gases to a stack (Figure 4). The main equipment components are shown in Figure 5. 
Metals, ash, and inert materials that do not volatilize, but remain in the plasma chamber, are melted and produce a molten pool of metal and various oxidized materials that form a slag. The molten material is captured in a shallow, refractory-lined hearth, from which it would be periodically removed by a drain or pour spout to canisters for placement in a waste repository. The pool tends to separate by gravity into a molten-metal layer underneath the molten slag. By limiting the quantity of air that is allowed into the plasma chamber, the molten metal can largely be kept from oxidizing. The benchscale system does not currently have a means for draining the molten materials. Rather, the system is operated in a batch mode, processing up to nine 4 l containers of waste (scaled-down 208 l drums) and retaining all molten materials in the hearth where it solidifies after shutdown of the system. Following cool-down, the plasma chamber is opened, and the solidified residues are extracted from the hearth. 
 Figure 5. The PHP benchscale test facility.Key aspects of any waste-treatment technology are the performance of the final product in terms of waste retention and long-term durability and the minimization of secondary wastes created in the treatment process. Waste retention is normally considered in terms of resistance to leaching by groundwater and is evaluated by the U.S. Environmental Protection Agency's (EPA's) Toxicity Characteristic Leaching Procedure (TCLP).13 The TCLP is a controlled test in which the sized waste form is immersed in water, and the measured concentrations of particular hazardous materials in the leachate are compared to allowable maximum concentrations. 
Long-term durability determinations are less defined, but typically include the Product Consistency Test (PCT),14 which is similar to the TCLP but may reveal more about the waste form following a longer exposure. Other parameters, such as compressive strength, may be relevant to specific waste forms. The DOE mixed wastes typically have a sufficient quantity of glass-forming materials (e.g., sand) to produce a glass-like slag in the PHP. These vitreous slags have been shown to have excellent waste-retention and durability characteristics.

## Plasma operation for NanoPPG Industries, Lisa Morrison

- 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!**

**Notes:**
Lisa Morrison presented information at the DOE Chemical Management conference that PPG already produces nanoparticles as colorants for their glass products. They use a plasma reactor to do that. They are building a large pilot plant to handle this process and will be conducting a comprehensive HAZOP to ensure the safety of all parts of the system. They are not letting the uncertainty about the health effects of nanoparticles obscure the well-known safety hazards associated with high energy plasma operations. The most ironic point is that, given the small quantity of nanomaterials they will be producing, the operation wouldn’t  reach a trigger quantity to be covered under the OSHA Process Safety Management standard.

## TSDS Phase Analysis

- Risks vary during life cycle of a technology
- Particularly appropriate for nanoproducts (Holman, 2006)

**Notes:**
Carbon nanotubes might be a concern, but tennis rackets – the final product – aren’t.

## Risks: Maintenance Versus OperationMachinery fatalities 1997, Etherton, NIOSH

**Maintenance**
** ****48%**

**Operations**
**45%**

**Other**
**7%**

**Notes:**
Data reported by the National Institute for Occupational Safety and Health indicated that for 1997, 48 percent of workers fatally caught in machinery were performing maintenance while only 45 percent were actually operating the equipment when killed, even though a far greater proportion of time is spent operating the equipment.[2] Taylor found specific accident rates for similar equipment varied by a factor of over 100, due to differences in maintenance practices and routine inspections.[1] 
[1] Taylor, J.R. (1994). Risk analysis for process plant, pipelines, and transport. London: Chapman & Hall. 411.

[2] Etherton, J. (2001, July 19). Machine tool safety research 2001, the injury data. Paper presented at the meeting of the American National Standards Institute’s B11 committee, San Diego, CA.

## Research Findings, Lippy, 2003 DOE Technology Developers

- Survey through the Institute for Regulatory Science (62% return, 50/80)
**74% agreed or strongly agreed with statement: “****This document format is quite valuable**”

**Notes:**
Eighty firms were mailed questionnaires and individuals from fifty responded, representing a 62 % return. The self-reported information from the individuals who responded indicated that the target population had been reached: the majority were engineers, had graduate degrees, had been with their current firm for more than ten years, and had been working in the environmental field for more than 10 years.  Experience with the current firm is an important indicator of likely involvement in key technology projects within the firm. Table 14 indicates that 76 % reported having been with their firms at least six years and none had been with the company less than one year.

## RESULTSFocus Group of State Environmental 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?”*

**Notes:**
unanimous agreement by the participants that receiving a TSDS as part of a permit application for an innovative technology would significantly increase the likelihood of approving the permit.
They expressed a preference for the Navy’s approach, however. The critical feature for the regulators was the Navy’s process: using a team working from a checklist for the inspection, generating a “Technical Safety Data Sheet” from the checklist, and then making both documents available – in paper and on their website.  This transparency greatly appealed to regulators, they wanted to be able to review the checklist worksheets along with the final document. It was also critical for them to see the names and qualifications of the assessment team, so they could judge the credibility of the team. Several thought they would have more use for the worksheet but would give the shorter, less complex TSDS to their boss, to workers, and to the public living near a hazardous waste site being remediated.

Regulators, like developers, generally preferred including a rating system for the risk posed by the hazards (SSEB, 2001, p. 3).  They also felt it important to try to categorize the technologies that were being evaluated because there are real differences in risk among classes of cleanup technologies:

None of the regulators had direct access to an industrial hygienist or safety specialist in their own immediate governmental organization. 

## RESULTSSurvey 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**

**Notes:**
original mailing of 935 questionnaires, a total of 475 workers replied to the survey, representing a 50% response. For comparison, Zimmerman et al. (1997, p. 676) reported a 38% response from a mailing of 1075 questionnaires to operating engineers at their homes. The survey included a potential to win $100 by returning the questionnaire. The authors indicated that local union officials typically experience only 25% return for their mailings.  By a two to one ratio, the majority had worked at a hazardous waste site but most (63%) had worked for five or less years. 

A significant portion of workers in this survey, however, had no experience in environmental work (35%) or had worked for less than one year (17%).  In contrast, all of the developers had at least one year’s experience and nearly half (46%) had worked with environmental remediation technologies for more than ten years, compared to 16% for workers.  
Almost all (95%) of those who responded to the question about union membership indicated they were members of a union. Not surprisingly, the overwhelming majority of these (97%) were members of the International Union of Operating Engineers, coming from 45 different local unions. 

Nearly half of the respondents (46%) were 50 or more years old (see Figure 8). This is comparable to the results reported by Zimmerman et al. (1997, p. 671) who also administered questionnaires to operating engineers and found the average age was 45.9 years old.  For reference, the average age of construction workers was reported as 37.2 years by the Bureau of  Labor Statistics (2000).

The overwhelming majority (89%) did not have a college degree, as Figure 9 indicates, compared to the 72% of developers who had advanced degrees.

## 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**

**Blippy@episervices.com**

**Notes:**
This is the crux of the matter for me. Inherent safety is remembering the worker. This quote from Kurt Vonnegut is great. Feel free to use it. This is a technology that blasts floor surface with dry ice shards. Great idea, but the door for adding the dry ice was held open with a stick. Perfect way to smash your arm.