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, Environment, Safety, Health & Assurance 

Approved by: ______________________________________ Date: _______________ 

 Dr. Bruce Harmon, Deputy Director 

Approved by: ______________________________________ Date: _______________ 

 Dr. Alex King, Director 
Ames 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 nanomaterials. Potential hazards associated with 

nanomaterials work are addressed through the Laboratory’s Integrated Safety Management System 

(ISMS) and specifically the Readiness Review process. Readiness Review provides the 

identification and evaluation of potential hazards and establishes effective control mechanisms to 

ensure protection of the employee and the environment. 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 equipment. 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 investigated. Ames Laboratory safety professionals 

monitor professional sources of information to identify new control strategies associated with 

nanomaterials research. 

The DOE Notice 456.1, Statement of Nanoscale Safety, 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 surveillance, 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 evaluating 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 facilities 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’s 
Ames Laboratory Plan: 10200.035 

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Title: Nanomaterials Safety Implementation Plan Effective Date: 4/15/2009 

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environment, safety and health programs adequately 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 / DEPARTMENT MANAGERS – Program Directors / Department 

Managers are responsible for ensuring that all research with nanomaterials conducted within 

the program is done in accordance with established policies and procedures. Program 

Directors/Department Managers delegate this responsibility through the line management 

structure of the Program. 

3.3 GROUP / SECTION LEADERS – Group / Section Leaders are responsible for ensuring that all 

research with nanomaterials within their group is conducted in accordance 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 personnel are trained and feel empowered to report unsafe work 

conditions or other safety concerns related to work with nanomaterials. 

3.4 EMPLOYEES – Ames Laboratory employees are required to work with nanomaterials in 

accordance with established policies and procedures. 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 ASSURANCE – 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 nanomaterials is constantly being 

updated. Literature published by organizations such as the National Institute for Occupational 

Safety and Health (NIOSH), the American Industrial Hygiene Association (AIHA), the National 

Research Council, the American Chemical Society and the International Council on 

Nanotechnology and other organizations will be evaluated by ESH&A personnel 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. 
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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 (Procedure 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 Supervisor 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 Ames Laboratory employees. “A”-listed hazards 

are located on the first page of the form and are those agents that have special 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 nanotubes) of nanomaterial (≤100 nanometer) do you use? 

• What task(s) are you performing when potential 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 nanomaterial? If not, why? 

• Do you wear a respirator during your nanomaterial use? If yes, describe 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) for review. The IH reviews the information in conjunction with 

completion of a Nanomaterials Hazard Assessment (described below). A recommendation for 

medical surveillance is then made to Occupational Medicine by the IH. 
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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 nanotubes) of nanomaterial (≤100 nanometer) do you use? 

• What task(s) are you performing when potential 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 nanomaterial? 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) Review: 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 exam will consist of a general physical, general 

blood work, pulmonary function test and x-ray. Recall frequency will also be determined by the 

physician. 

4.2.6 Training 

Laboratory personnel identify work with nanomaterials via completion of a Training Needs 

Questionnaire (TNQ). The TNQ question on nanomaterials work is as follows: 
Ames Laboratory Plan: 10200.035 

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

If answered “yes”, the employee’s training profile is updated and reflects the need for completion of 

the Lab’s nanomaterials safety module entitled “Nanotechnology Awareness (AL-208)”. This 

course is computer-based, takes 30 minutes to complete and requires an 80% or higher score on a 

Learning Assessment Tool. Subjects covered in the training module include: 

• Introduction to Nanomaterials 

• Definitions 

• Overview of inhalation, dermal, ingestion routes of exposure 

• Safety precautions including engineering 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 nanoscale materials is emerging on a regular basis. By 

necessity, training will need to be assessed for adequacy on a regular basis. Any new or refresher 

information will be provided to all employees who have previously completed the module in a 

timely manner. 

4.2.7 Exposure Monitoring 

Quantitative exposure monitoring for nanoscale materials is not feasible because accepted methods 

(instrumentation, exposure limits, etc.) do not currently 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 assessment described previously is used. 

4.2.8 Exposure Controls 

Engineering controls such as a ventilated enclosure or chemical hood are recommended for all work 

with dispersible (able to be inhaled) nanoparticles. If engineering 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. 
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4.2.9 Transportation 

Transportation of nanoscale materials is assessed during the Readiness Review process. Off-site 

transportation is conducted in accordance with DOT regulations. Between lab transportation of 

nanoscale materials will be conducted using methods (e.g. use of shatter proof 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 wastes. Both Ames Laboratory and 

ISU waste management personnel have a documented procedure for managing nanoscale material 

waste. Nanoscale material waste will be classified separately and be associated with a specific 

Satellite Accumulation Area (building, lab). Materials will be packed for disposal by a licensed 

vendor. Documentation will be available that verifies type of waste, quantity and means and 

location of final disposition. 

4.2.11 Annual Self-Assessment 

The IH will conduct an annual review 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 FINDINGS PERTAINING TO NANOSCALE 

MATERIALS 

ESH&A personnel stay abreast 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 professional development 

conferences/meeting sponsored by the American Academy of Industrial Hygiene (Professional 

Conference of Industrial Hygiene), the American Conference of Governmental Industrial Hygienists 

(American Industrial Hygiene Conference & Exposition), DOE (Nanotechnology Centerssponsored courses) and academia (Iowa State University). Internal sources of information include 

proposal reviews, Readiness Review, independent walkthroughs and interactions with researchers 

during training. 

Information gleaned from these sources is utilized to bring about improvements in the way the 

Laboratory anticipates, recognizes, evaluates and controls hazards associated with nanomaterials. 

These improvements include enhanced training and 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 

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4.4. SUPPORTING THE RESOLUTION OF ES&H CONCERNS 

Ames Laboratory has an effective Oversight and 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, evaluating 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 appraisals, internal reviews 

conducted by the Laboratory’s Independent Auditor and external reviews conducted by DOE.