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Organizational NanoEHS Control Systems

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.

2.0 OWNERSHIP/STAKEHOLDERS

2.1 The Nanotechnology EHS Management Committee

  • The Nanotechnology EHS Management Committee is the owner of the Nanomaterial Use Guideline

2.2 The Stakeholders of the Nanomaterial Use Guideline include:

  • Organization Management
  • The EHS Organization
  • Nanotechnology EHS Management Committee
  • Researchers
  • Practitioners (Students, Technicians, Operators, etc.)
  • Emergency Responders
  • Waste Management

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.

4.0 DEFINITIONS

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

6.1 EHS Nanotechnology Management Committee

6.2 EHS Nanotechnology Management Committee shall ensure that the organization responsibly manages nanomaterials, and is responsible for;

  • 6.2.1 EHS Policy on Nanotechnology EHS Management Procedures
  • 6.2.2 EHS Standards
  • 6.2.3 Communication
  • 6.2.4 Establishment of EHS Research Direction on nanotechnologies
  • 6.2.5 External Consortia Engagements
  • 6.2.6 Oversight of the Nanotechnolgy EHS Procedure Effectiveness
  • 6.2.7 Periodic review of Nanotechnology EHS Research to identify potential modifications to procedures
  • 6.2.8 Coordinate all EHS activities related to nanotechnology
  • 6.2.9 Form and direct WGs to address key EHS issues including but not limited too;
  • 6.2.10 Internal EHS practices including development of Internal EHS Guidelines on the use of nanomaterials including both occupational exposure controls and environmental management of nanomaterials.
  • 6.2.11 External EHS research including identification of EHS research needs including toxicological assessments of nanomaterials
  • 6.2.12 Review, track and monitor all activities (research and/or manufacturing) that involve nanomaterials.

6.3 EHS Organization Responsibilities

  • 6.3.1 Track and maintain records and documentation for nanomaterial requests and follow up periodically to make sure new toxicology or environmental impact findings are incorporated into EHS controls
  • 6.3.2 Conduct Industrial Hygiene Health Hazard Evaluations of operations involving nanomaterials

6.4 Management Responsibilities

  • 6.4.1 Ensure that this guideline is followed for all operations by establishing the proper management and oversight mechanisms
  • 6.4.2 Ensure that all materials containing nanomaterials are reviewed and approved by EHS prior to use

6.5 Employee or Practitioner Responsibilities

  • 6.5.1 Perform all operations and handling procedures in accordance with approved procedures.
  • 6.5.2 Ensure required EHS controls are in place and utilized.

7.0 REQUIREMENTS

7.1 Approval of nanomaterial usages

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.

7.2 Health and Safety Controls

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.

7.3 Environmental Controls

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.