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U.S. Department of Energy 

Office of Inspector General 

Office of Audit Services 

Audit Report 

Nanoscale Materials Safety at the 

Department's Laboratories 

DOE/IG-0788 February 2008 
Department of Energy 

Washington, DC 20585 

February 28, 2008 

MEMORANDUM FOR 

FROM: 

Inspector General 

SUBJECT: IhTFORMATION: Audit Report on "Nanoscale Materials 

Safety at the Department's Laboratories" 

BACKGROUND 

The National Nanotechnology Initiative was established as a multi-agency research and 

development program in 200 1. As a part of the Initiative, the Department of Energy 

(Energy) is in the process of constructing Nanoscale Science Research Centers at six 

national laboratories. In addition to funding the construction and operation of these 

facilities, the Department funds nanotechnology projects at six other national 

laboratories. 

Since the field of nanoscale materials research is relatively new, the health and safety 

risks associated with these materials are still emerging. Health and safety risks include 

possible pulmonary inflammation and lung tumors resulting from the inhalation of 

nanoscale materials as well as an increased potential for explosion and fire due to 

nanoscale attributes that are not present in the same materials at larger sizes. 

The Department established DOE P 456.1, Secretarial Policy Statement on Nanoscale 

Safety in September 2005. This policy stipulates that the Department and its contractors 

should use best practices and national consensus standards when establishing safety 

policies to protect workers. IUational consensus standards have not yet been established 

as the scientific community studies safety and health risks posed by nanoscale materials. 

The Centers for Disease Control and the National Institute of Occupational Safety and 

Health (CDC/NIOSH) have taken a leading role among Federal agencies conducting 

research on the safe handling of nanoscale materials. In October 2005, CDC/NIOSH 

distributed, for peer review, information regarding precautionary measures for the safe 

conduct of nanoscale work, including medical surveillance, workplace monitoring, 

training, and engineering controls. Given the absence of consensus standards, we used 

the CDCAVIOSH information to determine whether the Department's laboratories were 

employing appropriate safety measures specifically tailored for working with nanoscale 

materials. 

RESULTS OF AUDIT 

We found that the Department and its laboratory contractors had not always employed 

precautionary measures as outlined by the CDC/NIOSH. While some laboratories had 

established work practices concerning the safe handling of nanoscale materials, the 

Department's laboratories we reviewed generally had not: 

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2

• Performed medical surveillance on individuals working with these materials; 

• Monitored the workplace environment for exposure to airborne nanoscale 

materials; 

• Provided specific training in the safe handling of nanoscale materials; and, 

• Required that nanoscale materials research be performed in facilities equipped 

with all of the suggested engineering health and safety controls. 

In addition, the Department had not established a mechanism to disseminate nanoscale 

materials safety information. Management told us that existing mechanisms, such as 

Departmental working groups, adequately performed the dissemination function for 

nanoscale safety information. However, at the time of our audit, neither the Department 

nor the working group had disseminated lessons learned and other information developed 

by the group to other laboratories working with nanoscale materials. 

Department officials indicated that they were waiting for the development of national 

consensus standards before issuing additional guidance in the areas of medical 

surveillance, exposure rate monitoring, training, and use of engineering controls. 

Similarly, officials at several laboratories indicated that they were waiting for more 

definitive agency standards to be available before establishing specific safety policies 

locally. However, CDC/NIOSH has encouraged the establishment of interim standards 

until more definitive consensus standards are developed for nanotechnology. 

We concluded that the Department should adopt a proactive approach to ensuring that its 

laboratories follow best practices in conducting nanoscale-related work. In this way, the 

Department increases the chance that workers will be protected from potential health and 

safety risks, some of which experts acknowledge may not be fully understood for years. 

During our review, an Environment, Health and Safety (ES&H) working group 

representing the Department's Nanoscale Science Research Centers (NSRC), issued 

safety guidance for nanotechnology, entitled Approach to Nanomaterial ES&H. The 

policy suggestions in this guide conform to the CDC/NIOSH precautionary measures on 

medical surveillance, exposure rate monitoring, worker training, and engineering 

controls. Management stated that all of the Directors of the national laboratories have 

accepted the guidance and endorsed them as the best collection of safety and health 

information concerning nanoscale activities. While the development of this guidance is a 

positive development, the use of the guide is voluntary on the part of the laboratories. 

Accordingly, we recommended the Department adopt and issue the NSRC working 

group's guidance until national consensus standards can be established. 

MANAGEMENT REACTION

Management did not concur with our recommendation. Management felt it was 

unnecessary to develop any additional policy or guidance in this area at this time. 
3

Management also stated that it had asked Laboratory Directors to provide an update on 

their progress in the development and implementation of requirements for 

nanotechnology activities. 

We disagree with management's position. After we received management's response, we 

followed up with several laboratories and found varying degrees of action on the policy 

suggestions in the NSRC guidance. Our review found that none of the laboratories had 

fully adopted the NSRC suggestions. One official stated that his laboratory was awaiting 

formal direction from the Department before acting. 

During the course of our audit, we noted a concern regarding the Department being 

overly prescriptive about how contractors should achieve mission objectives and its 

impact on economy and efficiency. However, the disparity in precautionary measures we 

found warrants that the Department clearly establish expectations for such measures at its 

laboratories. In addition, the Department's adoption of the NSRC guidance would not 

involve the establishment of new requirements since the laboratory directors have agreed 

to adopt and operate in a manner consistent with them. 

Given the potential health consequences, we believe it is important that the Department 

adopt and disseminate the best available guidance on nanoscale safety in order to protect 

workers in this important and emerging field of research. Management's comments and 

our response are discussed in more detail in the body of the report. 

Attachment 

cc: Deputy Secretary 

 Under Secretary of Energy 

 Under Secretary for Science 

 Administrator, National Nuclear Security Administration 

 Chief of Staff 

 Chief Health, Safety and Security Officer 

 Director, Policy and Internal Controls Management, NA-66 
REPORT ON NANOSCALE MATERIALS SAFETY AT THE 

DEPARTMENT'S LABORATORIES 

TABLE OF 

CONTENTS 

Nanoscale Materials Safety Polices

Details of Finding 1 

Recommendation and Comments 4 

 

Appendices

1. Objective, Scope, and Methodology 7 

2. Management Comments 9 
NANOSCALE MATERIALS SAFETY POLICES 

Page 1 Details of Finding 

Best Practices The Department of Energy (Department) established DOE P 456.1, 

Secretarial Policy Statement on Nanoscale Safety in September 

2005. This policy stipulates that the Department and its 

contractors should use best practices and national consensus 

standards when establishing safety policies to protect workers. 

Although consensus standards have not been established, we 

benchmarked the safety practices of the Department's laboratories 

against the Centers for Disease Control and National Institute for 

Occupational Safety and Health (CDC/NIOSH) guide Approaches 

to Safe Nanotechnology (issued in October 2005 and reissued in 

July 2006 for peer review). CDC/NIOSH are the leading Federal 

agencies conducting research on health and safety issues of 

nanoscale materials. 

 While 12 of the Department's laboratories reviewed had 

established some work practices concerning the safe handling of 

nanoscale materials, they generally had not implemented all of the 

procedures suggested in the CDC/NIOSH guide. These procedures 

were in the areas of medical surveillance, exposure rate 

monitoring, worker training, and engineering controls. In addition, 

the Department had not established a mechanism to disseminate 

nanoscale materials safety information. 

Medical Surveillance

Of the 12 labs, 11 did not perform medical surveillance of 

individuals working with nanoscale materials. Medical 

surveillance involves establishing an initial health baseline of those 

who work with hazardous materials and scheduling subsequent 

periodic medical examinations. These subsequent exams track

deviations from the baseline and help identify any adverse health 

effects arising from exposure to nanoscale materials. CDC/NIOSH 

guidelines state that the unique properties of nanoscale materials, 

together with information suggesting these materials may pose 

health and safety hazards to workers, underscore the need for 

medical surveillance. 

Workplace Exposure Monitoring

Nine of the 12 laboratories had not initiated monitoring for 

exposure rates in the workplace. Exposure monitoring involves the 

sampling of air at various locations in the workplace to measure 

the amount of airborne particles. Although the toxicity of 

nanoscale materials is unknown, the CDC/NIOSH suggests 

monitoring the workplace environment for exposure to nanoscale 

materials. CDC/NIOSH states that it is critical that background 
Page 2 Details of Finding 

exposure measurements be conducted in order to determine 

whether there has been an increase in exposure due to production 

and processing activities. 

Training

Only two of the laboratories required that workers receive training 

specific to handling nanoscale materials. Since nanoscale 

materials can have different qualities than the same materials at a 

larger size, and since knowledge of the safety aspects of the 

nanoscale materials is largely unknown, it is important that 

workers receive more specific training in working with these 

materials. Accordingly, CDC/NIOSH suggests educating and 

training workers in the safe handling of nanoscale materials. Most 

of the laboratories we reviewed relied on standard chemical safety 

training provided to laboratory workers, as well as training on the 

hazards of the specific materials led by principal investigators.

However, standard chemical safety training usually did not include 

content related to potential hazards of working with nanoscale 

materials. Further, the training led by principal investigators was 

not standardized and was limited to the hazards of the specific 

materials being used on a particular experiment. While both types 

of training are useful, they should be used in tandem with specific 

training in the safe handling of nanoscale materials to ensure 

workers are aware of potential hazards and good work practices. 

Finally, two principal investigators at one laboratory told us that 

they did not require students who were part of their research teams 

to take the standard chemical safety training required of laboratory 

personnel. 

Engineering Controls

Only two laboratories required that nanoscale materials research be 

performed in facilities equipped with all of the suggested 

engineering health and safety controls. For example, one 

laboratory identified a potential inhalation hazard with an 

experiment but did not require use of available HEPA filtered 

exhaust ventilation because very little particle loss was anticipated. 

Another laboratory without HEPA filtered ventilation systems 

stated they may allow on-site preparation of nanomaterials 

samples. Such action could increase the inhalation risk of 

nanomaterials. Engineering controls such as exhaust ventilation 

systems which include high efficiency particulate air (HEPA) 

filters can effectively remove nanoscale particles. CDC/NIOSH 
Page 3 Details of Finding 

suggests the use of engineering controls, including exhaust 

ventilation systems with HEPA filters, to remove nanoscale 

particles. 

Management pointed out engineering controls should be tailored to 

the potential hazard. It stated that high-efficiency particulate air 

filters such as HEPA filters are appropriate when nanomaterials 

might become airborne, but may not be necessary in all areas 

where nanomaterials research is being conducted. We agree that 

engineering controls should be tailored to potential hazards. As 

noted in the above examples, potential inhalation hazards exist that 

may require the use of engineering controls. 

Dissemination of Information

The Department also had not established a formal process for 

disseminating nanoscale materials safety information to all of the 

laboratories. Although several Departmental working groups had 

been formed to discuss issues related to nanoscale materials 

research, none of these groups had been tasked with disseminating 

safety and health information or lessons learned throughout the 

Department. For example, the Department encouraged the six 

Nanoscale Science Research Centers (NSRC) to establish an 

Environment, Health and Safety working group. Management told 

us that existing mechanisms, such as Departmental working 

groups, interagency working groups, and various websites, 

adequately performed the function of dissemination for nanoscale 

safety information. However, neither the Department nor the 

working group had disseminated lessons learned and other 

information developed by the group to the other laboratories 

working with nanoscale materials. Such information is useful to 

organizations in ensuring that the best current knowledge is 

reflected in the identification and control of potential hazards, as 

required by the Secretarial Policy Statement and encouraged by the 

CDC/NIOSH. 

Departmental The Department relied upon each separate laboratory to develop 

Guidance and implement protective measures and had not provided its 

laboratories with guidance on what specific procedures should be 

followed to meet the Secretarial Policy Statement on Nanoscale 

Safety. Based on our discussions, Department officials were 

waiting for definitive standards to be established by consensus 

standard setting organizations before issuing guidance on medical 

surveillance, exposure rate monitoring, and training; ensuring 

laboratories have the suggested engineering controls; or 
Page 4 Recommendations and Comments 

establishing a method of disseminating information. Similarly, 

officials at several laboratories indicated that they were waiting for 

more definitive agency standards to become available before 

establishing specific safety policies locally. Nonetheless, the 

CDC/NIOSH has encouraged the establishment of interim 

standards until the development of more definitive consensus 

standards. 

During our review, the NSRC working group issued suggested 

safety guidance for nanotechnology, entitled Approach to 

Nanomaterial ES&H. The policy suggestions contained in the 

guidance are similar to the CDC/NIOSH guidance in the areas of 

medical surveillance, exposure rate monitoring, worker training, 

and the appropriate use of engineering controls as suggested by 

CDC/NIOSH's guide. Management stated that all of the national 

laboratories have accepted the guidelines and endorsed them as the 

best collection of safety and health information and guidance 

concerning nanoscale activities. However, use of the NSRC 

working group guidance, as well as the CDC/NIOSH guidance, are 

voluntary on the part of the Department' s laboratories involved in 

nanotechnology. 

Risk to Worker One of the Department's stated goals is the safety of its employees, 

Health and Safety the public, and the environment. The Department faces many 

uncertainties about whether nanotechnology materials pose 

occupational health and safety risks as it pursues nanotechnology 

research. Health and safety risks include possible pulmonary 

inflammation and lung tumors resulting from the inhalation of 

nanoscale materials as well as an increased potential for explosion 

and fire due to nanoscale attributes that are not present in the same 

materials at larger sizes. Given the uncertainties about the 

occupational health and safety risk posed by nanotechnology 

particles, it is prudent for the Department to take precautionary 

measures to minimize worker exposure as suggested by the 

CDC/NIOSH and the NSRC guidance. 

RECOMMENDATIONS We recommend that the Chief, Office of Health, Safety and 

Security (HSS), adopt and disseminate the Nanoscale Science 

Research Centers working group's guidance as the Department's 

expectation of safety policies and procedures at the laboratories in 

these areas: 

• Performing medical surveillance on individuals working 

with or around nanoscale materials; 
Page 5 Recommendations and Comments 

• Performing exposure rate monitoring in the laboratories 

where nanoscale materials research is performed; 

• Training employees in the safe handling of nanoscale 

materials when working with and around these materials; 

and, 

• Using appropriate engineering controls, such as HEPA 

filtered external exhaust systems, while performing 

nanoscale materials research. 

MANAGEMENT The Office of HSS did not concur with our recommendation. 

REACTION Specifically, management felt it was unnecessary to develop any 

additional policy or guidance in this area at this time. Management 

found that the NSRC working group's guidance addressed the 

existing Secretarial Policy Statement and provided an appropriate 

approach to health and safety concerns when working with 

nanomaterials. Management also stated that it has asked 

Laboratory Directors to provide HSS with an update on their 

progress in the development and implementation of requirements 

for nanotechnology activities. 

AUDITOR Management's comments were not responsive to our 

COMMENTS recommendation. While we agree that development of the NSRC 

guidance is a positive first step, compliance with the guidelines 

remains voluntary by the laboratories. For example, one national 

laboratory official pointed out that the guidelines were not part of 

the laboratory's contract with the Department, although they were 

applicable to nanotechnology-related work at the laboratory. 

Additionally, although the guidelines have been accepted by the 

Laboratory Directors, subsequent discussions with several 

laboratories found varying degrees of action had been taken on the 

policy suggestions in the NSRC guidance. None of the 

laboratories we contacted had fully adopted the NSRC suggestions. 

One non-NSRC laboratory official responded that the guidance 

was not mandatory and intended for the NSRCs only. 

We also noted that, in at least two cases, responses to the HSS 

request for an update on nanotechnology safety requirements, 

which were available to us, did not provide assurance that proper 

requirements were in place. Specifically, two laboratories 

responded that they were either still developing procedures or 

reviewing the additional program requirements needed to establish 

strict adherence to the NSRC guide. 
Page 6 Comments 

Accordingly, we believe it is important for the Department to 

adopt and disseminate the guidelines in order to clearly establish 

its expectations for measures that all laboratories need to take in 

order to satisfy the Secretarial Policy Statement on nanotechnology 

safety. 
Appendix 1 

Page 7 Objective, Scope, and Methodology 

OBJECTIVE The objective of this audit was to determine whether the 

Department of Energy's (Department) laboratories were employing 

appropriate measures specifically tailored for working with 

nanoscale materials. 

SCOPE This audit was performed between January and August 2007 at 

Department Headquarters in Washington, DC, and Germantown, 

Maryland; Ames Laboratory in Ames, Iowa; and Sandia National 

Laboratory in Albuquerque, New Mexico. Information was also 

received from Lawrence Berkeley National Laboratory in 

Berkeley, California; Brookhaven National Laboratory in Upton, 

New York; Argonne National Laboratory in Argonne, Illinois; Oak 

Ridge National Laboratory in Oak Ridge, Tennessee; Pacific 

Northwest National Laboratory in Richland, Washington; 

Lawrence Livermore National Laboratory in Livermore, 

California; Los Alamos National Laboratory in Los Alamos, New 

Mexico; Idaho National Laboratory in Idaho Falls, Idaho; the 

National Renewable Energy Laboratory in Golden, Colorado; and 

the Stanford Linear Accelerator Center in Menlo Park, California. 

The scope of the audit included policies and procedures related to 

nanoscale materials safety in effect during Fiscal Year 2007. 

 

METHODOLOGY To accomplish the audit objective, we: 

• Reviewed applicable laws and regulations pertaining to 

nanoscale materials safety; 

• Reviewed industry and governmental standards related to 

industrial hygiene; 

• Reviewed Departmental policies and procedures related to 

nanoscale materials safety; 

• Performed site visits at Ames Laboratory, and Sandia 

National Laboratory; 

• Reviewed safety policies and requirements in effect at 12 

Departmental Laboratories; 

• Reviewed the Government Performance and Results Act 

of 1993 and determined if performance measures had been 

established; and, 
Page 8 Objective, Scope, and Methodology 

• Held discussions with officials and personnel from the 

Office of Health, Safety and Security; the National 

Nuclear Security Administration's Environment, Safety 

and Health Program; Ames Laboratory; Sandia National 

Laboratory; Lawrence Berkeley National Laboratory; 

Brookhaven National Laboratory; Argonne National 

Laboratory; Oak Ridge National Laboratory; Pacific 

Northwest National Laboratory; Lawrence Livermore 

National Laboratory; Los Alamos National Laboratory; 

Idaho National Laboratory; the National Renewable 

Energy Laboratory; and the Stanford Linear Accelerator 

Center. 

This performance audit was conducted in accordance with 

generally accepted Government auditing standards. Those 

standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objective. We 

believe that the evidence obtained provides a reasonable basis for 

our findings and conclusions based on our audit objective. The 

audit included tests of controls and compliance with laws and 

regulations necessary to satisfy audit objectives. Because our 

review was limited, it would not necessarily have disclosed all 

internal control deficiencies that may have existed at the time of 

the audit. We did not rely on computer processed data to 

accomplish our audit objective. Performance measures were not 

established for nanoscale materials safety; however, our 

recommendations were directed at the Department to establish its 

expectations in this area. 

An exit conference was held with Department Officials for the 

Office of Health, Safety and Security, and the Office of Science on 

January 22, 2008. 

. 
Appendix 2 

Page 9 Management Comments 
IG Report No. DOE/IG-0788 

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