Ames Laboratory Plan: 10200.035 Office: Environment, Safety, Health & Assurance Revision: 3 Title: Nanomaterials Safety Implementation Plan Effective Date: 4/15/2009 Page: 1 of 8 Review Date: 4/15/2010

NANOMATERIALS SAFETY

IMPLEMENTATION PLAN

Comments and questions regarding this plan should be directed to the contact person listed below:

Name: Jim Withers Industrial Hygienist

Address: G40 TASF

Phone: 294-4743

Sign-off Record:

Approved by: ______________________________________ Date: _______________ Tom E. Wessels, Manager, Envi ronment, Safety, Health & Assurance

Approved by: ______________________________________ Date: _______________ Dr. Bruce Harmon, Deputy Director

Approved by: ______________________________________ Date: _______________ Dr. Alex King, DirectorAmes Laboratory Plan: 10200.035 Office: Environment, Safety, Health & Assurance Revision: 3 Title: Nanomaterials Safety Implementation Plan Effective Date: 4/15/2009 Page: 2 of 8 Review Date: 4/15/2010

1.0 REVISION/REVIEW LOG

Environment, Safety, Health & Assurance (ESH &A) will review this document once every two years at a minimum:

Revision Effective Contact Pages

Number Date Person Affected Description of Revision

0 4/15/08 J. Withers All Initial Issue 1 10/1/08 J. Withers All New requirements

2 12/31/08 J. Withers All G:/DOCS&RECS/DCP/ revision descriptions/

Plan 10200.035 rev 2 revdesc.doc
3 4/15/09 J. Withers All G:/DOCS&RECS/DCP/ revision descriptions/

Plan 10200.035 rev 3 revdesc.doc

2.0 PURPOSE AND SCOPE

Ames Laboratory has limited activities involving na nomaterials. Potential hazards associated with

nanomaterials work are addresse d through the Laboratory’s Integrat ed Safety Management System (ISMS) and specifically the Read iness Review process. Readiness Review provides the identification and evaluation of pot ential hazards and establishes effective control mechanisms to ensure protection of the employee and the environmen t. To date, hazards associated with projects involving nanomaterials have been determined to be amenable to conventional controls such as ventilation and use of personal protective e quipment. The Laboratory recognizes that nanotechnology is an emerging field and that many of the associated ES&H concerns related to work with these materials are still being invest igated. Ames Laborator y safety professionals monitor professional sources of information to id entify new control strate gies associated with

nanomaterials research.

The DOE Notice 456.1, Statement of Nanoscale Safe ty, is part of the DOE-ISU contract for operation of Ames Laboratory. Specifically, DOE N 456.1 delineates requirements in the areas of training, exposure assessment, medical surveillan ce, controls, posting and labeling, transportation, and waste management of nanoscale materials. In addition, Ames Laboratory utilizes the Department of Energy Nanoscale Science Research Centers Approach to Nanomaterial ES&H(Revision 3a – June 2008) document as a resource for eval uating health and safety risks

associated with use of nanoscale materials.

The following information outlines the Laboratory’s implementation of DOE N 456.1, the Approach document, and lessons learned from other faci lities and through review of audit reports.

3.0 RESPONSIBILITIES

3.1 LABORATORY DIRECTOR – The Laboratory Director is ultimately responsible for ensuring compliance with DOE N 456.1 and the Approach document and assuring that the Laboratory’sAmes Laboratory Plan: 10200.035 Office: Environment, Safety, Health & Assurance Revision: 3 Title: Nanomaterials Safety Implementation Plan Effective Date: 4/15/2009 Page: 3 of 8 Review Date: 4/15/2010

environment, safety and health programs adequate ly address the hazards associated with use of nanomaterials. The Director delegates this responsibility through the line management structure of the Laboratory.

3.2 PROGRAM DIRECTORS / DEPA RTMENT MANAGERS – Program Directors / Department Managers are responsible for ensuring that a ll research with nanomat erials conducted within the program is done in accordance with esta blished policies and procedures. Program Directors/Department Managers delegate th is responsibility through the line management structure of the Program.

3.3 GROUP / SECTION LEADERS – Group / Section L eaders are responsible for ensuring that all research with nanomaterials within their gr oup is conducted in accordan ce with established policies and procedures as described later in this document. Responsibilities include participation in the Readiness Review process, day-to-day management of laboratory activities, ensuring that laboratory pers onnel are trained and feel empo wered to report unsafe work conditions or other safety concerns related to wo rk with nanomaterials.

3.4 EMPLOYEES – Ames Laboratory employees are required to work with nanomaterials in accordance with established policies and pro cedures. Employees shall interact with supervisory personnel, Safety Coordinators / Representatives and ESH&A personnel on

concerns and issues that relate to work with nanomaterials.

3.5 ENVIRONMENT, SAFETY, HEALTH and ASSU RANCE – The ESH&A office shall assist research staff on the effective implementation of nanomaterials safety programs that ensure protection of the worker and environment. ESH&A staff will stay current on environment, safety and health best practices as they relate to nanomaterials and communicate that

information to research staff.

4.0 PROGRAM ELEMENTS

4.1 REFERENCES & STANDARDS

Ames Laboratory recognizes that information on the safe use of nanomaterial s is constantly being updated. Literature published by organizations su ch as the National Institute for Occupational Safety and Health (NIOSH), the American Indus trial Hygiene Associatio n (AIHA), the National Research Council, the American Chemical Society and the International Council on Nanotechnology and other organizations will be evaluated by ESH&A pers onnel and communicated to research staff as deemed appropriate. As of this writing, the Laboratory’s program is primarily based on the following publication: Department of Energy Nanoscale Science Research Centers - Approach to Nanomaterial ES&H - Revision 3a – June 2008

.Ames Laboratory Plan: 10200.035 Office: Environment, Safety, Health & Assurance Revision: 3 Title: Nanomaterials Safety Implementation Plan Effective Date: 4/15/2009 Page: 4 of 8 Review Date: 4/15/2010

4.2 IDENTIFICATION & MANAGEMENT OF NANOMATERIAL HAZARDS

4.2.1 Proposal Review

ESH&A personnel review all funding requests. Proposals with nanomaterials work are closely

scrutinized for assurance that the work does not fall outside of the “safety envelope” established during Readiness Review (see below) . Any identified concerns are communicated to research staff and followed up if funding is received.

4.2.2 Readiness Review

Nanoscale work is identified via Readiness Review (Proced ure 10200.006). Specifically, the physical hazard of nanomaterials is addressed on the ES&H Hazard Identification Checklist by the following statements:

Section A – Chemical & Biological Concerns : A14 Nanoscale materials.

For each identified hazard, the Activity Supervis or develops associated Hazard Management Statements that explain what controls are in place to minimize exposure potential. Standard Operating Procedures (SOPs) are also reviewed for adequacy along with a check of training records.

4.2.3 Hazard Inventory

The Hazard Inventory form is completed by all Am es Laboratory employees. “A”-listed hazards are located on the first page of the form and are th ose agents that have spec ial requirements such as

medical surveillance. Hazard “A265” denotes use of nanoscale materials. When an employee checks A265, a Hazard Information Request Form is generated and sent to the employee for completion. Questions for nanoscale materials are as follows:

• What type(s) (e.g., carbon na notubes) of nanomaterial ( ≤ 100 nanometer) do you use?

• What task(s) are you performing when poten tial nanomaterial exposure may occur?

• What is the greatest quantity you use at any given time?

• How frequently do you use it (e .g., daily, once a week, etc.)?

• How long do you use it during any given day (e.g., minutes, hours, etc.)?

• Is the material ever used outside of a glove box or fume hood? Is yes, how is it used?

• Do you wear a lab coat, protective eyewear and gauntlet or forearm length gloves when handling the free or open nanom aterial? If not, why?

• Do you wear a respirator during your nanomateria l use? If yes, desc ribe what type of respirator and activity involved?

The employee completes the form, gets a signature from a supervisor and sends the form to the ESH&A Industrial Hygienist (IH) fo r review. The IH reviews the information in conjunction with completion of a Nanomaterials Hazard Assessmen t (described below). A recommendation for medical surveillance is then made to Occupational Medicine by the IH.Ames Laboratory Plan: 10200.035 Office: Environment, Safety, Health & Assurance Revision: 3 Title: Nanomaterials Safety Implementation Plan Effective Date: 4/15/2009 Page: 5 of 8 Review Date: 4/15/2010

4.2.4 Nanomaterials Hazard Assessment

The IH utilizes Form 10200.187 – Nanomaterials Hazard Assessment to conduct a risk-based hazard assessment. Questions of the form are as follows:

1. Specific Usage

• What type(s) (e.g., carbon na notubes) of nanomaterial ( ≤ 100 nanometer) do you use?

• What task(s) are you performing when poten tial nanomaterial exposure may occur?

• What is the greatest quantity you use at any given time?

• How frequently do you use it (e .g., daily, once a week, etc.)?

• How long do you use it during any given day (e.g., minutes, hours, etc.)?

• Is the material ever used outside of a glove box or fume hood? Is yes, how is it used?

• Do you wear a lab coat, protective eyewear and gauntlet or forearm length gloves when handling the free or open nanom aterial? If not, why?

• Do you wear a respirator during your nanomaterial use? If yes, what type of respirator do you use and during what activity?

2. MSDS Review

3. Standard Operating Procedure (SOP) Revi ew: Are the following items specifically

addressed in the SOP

• Health & safety information

• Hazard control measures (e.g. PPE) usage

• Waste disposal practices

• Decontamination procedures

• Spill/release containment & clean up

• Authorized personnel

• Designated use area

• Transportation of samples

4. Labeling of Containers

5. Posting of Laboratory

6. Training

7. Hazard Inventory Verification: Is A265 denoted for every nanomaterial user?

8. Medical Surveillance Industrial Hygiene Comments

4.2.5 Medical Surveillance

Laboratory employees with an A265 hazard will be offered a baseline medical exam at Occupational Medicine (G11 TASF). The baseline ex am will consist of a general physical, general blood work, pulmonary function test and x-ray. R ecall frequency will also be determined by the physician.

4.2.6 Training

Laboratory personnel identify work with nanomaterials via co mpletion of a Training Needs Questionnaire (TNQ). The TNQ question on nanomaterials work is as follows:Ames Laboratory Plan: 10200.035 Office: Environment, Safety, Health & Assurance Revision: 3 Title: Nanomaterials Safety Implementation Plan Effective Date: 4/15/2009 Page: 6 of 8 Review Date: 4/15/2010

“Do you work with nanoscale materials (particl es with diameters less than 100 nanometers)?”

If answered “yes”, the employee’s training profile is updated and refl ects the need for completion of the Lab’s nanomaterials safety module entitled “Nanotechnol ogy Awareness (AL-208)”. This course is computer-based, takes 30 minutes to complete and require s an 80% or higher score on a Learning Assessment Tool. Subjects c overed in the training module include:

• Introduction to Nanomaterials

• Definitions

• Overview of inhalation, dermal, ingestion routes of exposure

• Safety precautions including engineer ing controls, respiratory protection

• Work practices including spill clean up

• Waste management

• Transportation

• Training

• Medical surveillance

• Lab postings and labeling

• Points of contact

New health and safety information related to nanos cale materials is emerging on a regular basis. By necessity, training will need to be assessed for ade quacy on a regular basis. Any new or refresher information will be provided to all employees w ho have previously completed the module in a timely manner.

4.2.7 Exposure Monitoring

Quantitative exposure monitoring for nanoscale material s is not feasible because accepted methods (instrumentation, exposure limits, etc.) do not curren tly exist. IH personnel continue to monitor progress on the development of monitoring methodology through professional sources of information including DOE and ISU EH&S personnel. In the absence of an accepted quantitative method, the qualitative, risk-based exposure as sessment described previously is used.

4.2.8 Exposure Controls

Engineering controls such as a ventilated enclos ure or chemical hood are recommended for all work with dispersible (able to be i nhaled) nanoparticles. If engine ering controls are not feasible, respiratory protection is recommended with the employee being placed on the Respiratory Protection Program which includes fit-testing and training. Other personal protective equipment

that is recommended as standard issue for work with nanoparticles includes a lab coat and latex gloves with extensions.Ames Laboratory Plan: 10200.035 Office: Environment, Safety, Health & Assurance Revision: 3 Title: Nanomaterials Safety Implementation Plan Effective Date: 4/15/2009 Page: 7 of 8 Review Date: 4/15/2010

4.2.9 Transportation

Transportation of nanoscale material s is assessed during the Readine ss Review process. Off-site transportation is conducted in accordance with DO T regulations. Between lab transportation of nanoscale materials will be conducted using methods (e.g. use of shatter pr oof containers) that

reduce the risk of human or environmental impact caused by an accidental spill.

4.2.10 Waste Management

Waste management practices are assessed during the Readiness Review process. Nanoscale

material wastes will be handled in a fashion similar to RCRA wast es. Both Ames Laboratory and ISU waste management personnel have a documented procedure for managing nanoscale material

waste. Nanoscale material waste will be classifi ed separately and be associated with a specific Satellite Accumulation Area (building, lab). Materi als will be packed for disposal by a licensed

vendor. Documentation will be available that ve rifies type of waste, quantity and means and location of final disposition.

4.2.11 Annual Self-Assessment

The IH will conduct an annual revi ew of nanoscale material usage at Ames Laboratory including programmatic documentation. Results of the annual review will be discussed in the Laboratory’s year-end self-assessment report.

4.3 INTEGRATION OF NEW RESEARCH FI NDINGS PERTAINING TO NANOSCALE

MATERIALS

ESH&A personnel stay abreas t of the latest developments in the safe use of nanomaterials through a variety of external and internal mechanisms:

External sources of information include participation in prof essional development conferences/meeting sponsored by the American Academy of Industrial Hygiene (Professional Conference of Industrial Hygiene), the American C onference of Governmental Industrial Hygienists (American Industrial Hygiene Conference & Exposition), DOE (Nanotechnology Centerssponsored courses) and academia (Iowa State Univers ity). Internal sources of information include proposal reviews, Readiness Review , independent walkthroughs and interactions with researchers during training.

Information gleaned from these sources is utiliz ed to bring about improvements in the way the Laboratory anticipates, recognizes, evaluates and controls hazards a ssociated with nanomaterials. These improvements include enhanced training an d the development of more effective hazard assessment and control strategies.Ames Laboratory Plan: 10200.035 Office: Environment, Safety, Health & Assurance Revision: 3 Title: Nanomaterials Safety Implementation Plan Effective Date: 4/15/2009 Page: 8 of 8 Review Date: 4/15/2010

4.4. SUPPORTING THE RESOLUTI ON OF ES&H CONCERNS

Ames Laboratory has an effective Oversight a nd Assurance Program (Plan 10200.035) that provides immediate feedback on the adequacy of the ES &H program. Feedback on the efficacy on the methods in place for anticipating, recognizing, eval uating and controlling hazards of nanomaterials work is received via a variety of mechanisms including the Independent Walkthrough Program, the employee concern program, Readiness Review (5-year reviews), topical apprai sals, internal reviews conducted by the Laboratory’s I ndependent Auditor and extern al reviews conducted by DOE.