A Best Practices Approach to Minimizing EHS Risk in Nanotechnology Manufacturing

In an industry that appears to be growing faster than federal oversight can keep up, several stakeholders from the private and public sectors have pointed to the "NanoSAFE" management program on display at a symposium poster session as a potential best practices template for companies engaged in nanotechnology-related enterprises.

NanoSAFE was developed by Luna Innovations Inc. a small, Blacksburg, Va.-based think tank that creates products and spin-off companies from emerging, high-risk technologies in collaboration with NIOSH and Virginia Tech University.

The program, which was created for a Luna division called Luna nanoWorks, organizes what Luna Innovations sees as the important EHS issues associated with nanotechnology into five components:

1. Employee Health Assurance
2. Workplace Safety Technologies
3. Toxicological Studies
4. Environmental Impact Assessment
5. Management of Facility and Products

Matthew Hull, a research scientist with Luna Innovations who spearheaded NanoSAFE, said the five-point management paradigm "organizes our thought processes into the different areas we feel are important to address not only the safety of the workers but the health and safety of the people living around the plant and, ultimately, of the end user."

The abstract for NanoSAFE cautions that this approach "should in no way be construed as official guidelines on the subject," but it adds that the program "demonstrates how entities engaged in nanotechnology-related enterprises, particularly small manufacturers of engineered nanoparticles, can proactively manage human and environmental health and safety risks."

The proactive aspect of NanoSAFE is as much about good business sense as it is about environmental and human health and safety. Hull explained that NanoSAFE is driven by the business need to prepare for the federal safety and environmental nanotechnology standards that are sure to come sooner or later.

For those companies that aren't ready when federal regulators get a handle on nanotechnology, the cost of compliance could be steep.

Said Hull: "We have a lot at stake and we don't want to lose it."

Nanomaterial Manufacturing Requires 'Stringent Safeguards'

Luna nanoWorks, based in Danville, Va., was born from the research of Virginia Tech physical chemistry professor Harry Dorn, whose work in the area of carbon-based fullerene materials includes the discovery of a new class of metallofullerenes that Luna is marketing as "trimetaspheres."

According to Luna Innovations' Web site, "Luna has exclusive rights to these unique, soccer ball-shaped molecules made of pure carbon, which can enclose up to three metal or rare-earth atoms." Luna has identified applications for trimetaspheres that include "improving communication devices, producing energy, increasing the sensitivity of MRI scans and simultaneously identifying and attacking individual cancer cells."

Hull, in an interview with Occupational Hazards.com, detailed some of the concepts in Luna nanoWorks' five-point program designed to provide safeguards for workers, surrounding communities and end-users. (In the poster session, the five-point program was represented, graphically, by a pentagon.) He mentioned that this is by no means a finished product; rather, NanoSAFE involves making "incremental progress" toward creating an EHS program that "errs on the side of overprotection" when it comes to anticipating the promulgation of federal standards.

Employee Health Assurance - Hull explained that every employee of Luna nanoWorks will be required to participate in baseline health screenings similar to those in the coal mining industry. The purpose of these screenings is to monitor employees' health over time to look for "red flags." However, Hull admitted that determining how the company addresses those health red flags "will be part of the evolutionary process."

Workplace Safety Technologies - Researchers from Virginia Tech, in consultation with NIOSH, are conducting "routine air monitoring." Additionally, Luna Innovations is leveraging its own experience in the field of sensor development to try to create more effective air monitoring technologies, Hull said.

Other safety technologies are more basic. For example, Hull said he attended a presentation in which the speaker discussed the potential hazard of nanoparticle soot penetrating the hinged area of the wrist an area that sometimes can be exposed. He proposed a "simple fix" for employees of Luna nanoWorks: either pulling up their safety gloves or their shirt sleeves or both to ensure the wrist area is covered. In general, the rule for workers at the Danville facility is "no exposed skin."

Toxicological Studies - Luna nanoWorks is conducting voluntary toxicological studies of the soot from the raw nanomaterials before and after they are purified. Such testing currently is not required by any safety and health regulations, Hull said.

Management of Facility and Products and Environmental Management Through this component of the five-point paradigm, Luna nanoWorks has been able to take a "cradle-to-grave type of strategy," Hull said.

The company has converted a 19th century tobacco warehouse in Danville, Va., into a manufacturing and product development facility for carbon nanotubes and trimetaspheres, allowing the company to "look at the raw materials from the start to the end-users' hands," Hull explained.

"Since we built the facility, we had the opportunity to minimize hazard exposures from the start," Hull said.

For example, the company hopes it has taken a pre-emptive strike against inhalation exposures by designing custom hoods in collaboration with Virginia Tech that reduce or eliminate particulate exposures. It also has implemented safeguards for the surrounding communities and the environment: All excess nanoparticles and other airborne waste go through a collection and filtration unit "so they're not flowing into the environment."

But how do you quantify acceptable levels of inhalation exposure when you're dealing with materials that have no permissible exposure limits? Hull again answered that Luna nanoWorks is erring "on the side of overprotection" the company has determined that the level of nanoparticles in ambient air is its PEL.

"Hopefully when those [PELs] are identified, we'll be below them," Hull said. In areas near the hoods where the nanomaterials are manipulated, air monitoring indicates that nanoparticle pollution is similar to everyday, ambient air. We can't do any better than that."

Discussion Among Stakeholders is Key

The syposium abstract for NanoSAFE points out that "the exchange of information among technical experts from industry, academia and federal agencies" has been an important part of this voluntary management program.

The need for communication and interdisciplinary cooperation in managing the EHS risks of nanotechnology has been a common theme at this year's nanotechnology symposium, one that Hull echoed in his poster session.

"What we'd like to do now is scale up our interaction with the federal government and larger companies hopefully to take our model and fill in the details," Hull said.

For more on Luna Innovations or Luna nanoWorks, visit www.lunainnovations.com.

The Second International Symposium on Nanotechnology and Occupational Health concludes today in Minneapolis.