1.0 PURPOSE/SCOPE To establish EHS Use Guideline and required EHS controls on the use of nanomaterials. This guideline applies to R&D and Manufacturing facilities that handle and or process nanomaterials.
3.0 CHANGE CONTROL PROCESS
Proposed revisions to this Guideline shall be submitted to the stakeholders prior to change. Final review and approval is the responsibility of the Nanotechnology EHS Management Committee.
Nanomaterials are defined as process materials that contain particles which at their greatest dimension are less than 100 nanometers. Nanomaterials may exhibit unique chemical/physical properties due to their small size.
5.0 POLICY The organization will manage and handle nanomaterials in a safe and environmentally responsible manner using state of the art exposure control technologies and currently available toxicology information
Currently there may be limited toxicological information available on specific nanomaterials. The organization will responsibly conduct appropriate EHS due diligence for nanomaterials before using them in research & development, process operations or products. In accordance with the organizations policies on the use of materials with limited toxicology information, a conservative approach has been established for the handling and processing of nanomaterials. As additional toxicity testing and environmental fate information becomes available, EHS will modify the required EHS controls accordingly.
6.0 ROLES AND RESPONSIBILITIES
All nanomaterial use and experimentation shall be reviewed by the EHS organization to ensure adequate EHS controls are implemented. Personnel should follow existing Chemical Use Approval Guidelines. The EHS organization should provide specific EHS controls on the proposed use of the nanomaterials based on EHS risk evaluations, toxicological assessments of the materials involved and potential for personnel exposure.
All nanomaterial use and experimentation shall be reviewed by EHS to ensure adequate EHS controls are implemented. Sufficient EHS controls will be implemented to preclude the potential inhalation and/or skin contact with nanomaterials. Enclosed processing systems and or engineering controls will be utilized to prevent the release of nanomaterials into the work environment. At a minimum, operations with a potential for inhalation of nanomaterials shall be performed within ventilated enclosures or local exhaust systems. EHS will evaluate the effectiveness of nanomaterial exposure controls by conducting industrial hygiene evaluations of processing and handling activities using state of the art testing methodologies.
Release of nanomaterials into the environment, both air emissions and or solid waste stream generation will be reviewed for approval by the EHS organization during nanomaterial Review/Approval Process. Appropriate emission controls will be identified during this approval process to mitigate potential environmental impacts. Industry standard waste characterization processes will be employed to determine applicable solid waste disposal methodologies for specific nanomaterial uses. As new analytical methods and techniques are developed for nanomaterials they will be utilized to perform additional waste stream characterizations and hazard analysis as appropriate.