Introduction/Administrative News The Industrial Hygiene/Occupational Safety Special Interest Group (IH/OS SIG) Steering Committee met on March 18, 2008 through a conference call meeting. IH/OS SIG Steering Committee Chair Ralph Hinterman, Argonne National Laboratory (Argonne), facilitated the meeting in which the following Steering Committee members and guests participated:
Tom Cornell, Fluor Hanford Inc.,
Dan Field, DOE, National Nuclear Security Administration, Livermore Site Office,
Phil Grogin, Los Alamos National Laboratory (LANL),
Ralph Hinterman, Argonne,
Bob Kapolka, Oak Ridge Institute for Science and Education (ORISE),
Ben Keen, DOE, Strategic Petroleum Reserve,
Ed Kvartek, Savannah River Site,
Daniel Marsick, DOE, HS-11, Office of Worker Safety and Health Policy,
Deborah McFalls, ORISE,
Rob Nicholas, LANL, and
David Weitzman, DOE, HS-11.
The following IH/OS SIG Steering Committee members notified the IH/OS SIG Coordinator that they could not participate in the meeting:
Deana Colley, Pacific Northwest National Laboratory
Lowell Howard, PNNL
Mike Hurshman, S.M. Stoller, and
John Peters, Brookhaven National Laboratory.
4th Annual Laser Safety Officer Advanced Training Workshop
Deborah McFalls reminded meeting participants that the 4th Annual Laser Safety Officer Advanced Training Workshop was scheduled for July 15-17, 2008, hosted by Sandia National Laboratories in Albuquerque, New Mexico. Details of the workshop are posted at: http://www.sandia.gov/lasersafety/LaserSafety.html.
Safe Handling of Engineered Nanoscale Materials Workshop News
Ralph Hinterman reported that the Nanotechnology Safety and Health Workshop will be held at Argonne, July 7-9, 2008. The five DOE Nanoscale Science Research Centers and internationally recognized experts will meet to discuss hazards and best practices for the management of nanoscale materials in research and development environments. The workshop topics include:
Safe Nanotechnology: Setting the Stage for Safe Handling,
HSS Expectations for Nanoscale Safety and Health,
Safe Handling of Engineered Nanoscale Materials: DOE Office of Science Expectations,
Nano Risk Management: Evolution of Guidance,
Principles of Nanomaterials Toxicology,
Focus on Carbon Nanotubes,
Understanding Cell-Nanoparticle Interactions: Making Nanoparticles More Biocompatible,
Exposure Assessment: Exposure Assessment: Air Sampling Study,
Operational Exposure Guides for the Assessment and Control of Nano Materials at CNMS,
Overview of the DOE Nanoscale Science Research Centers "Approach to Nanoscale Safety" Guidance Document,
Aerosol Characterization, Interpretation, and Application of Data,
Good Practices Wiki,
Effectiveness of PPE and Engineering Controls,
Nanoscale Materials and Risk Communication,
Market, Society, and Communicating About Things "Nano,"
Medical Surveillance and Nanotechnology Workers,
Four Approaches to the Environmental Issues of Nanotechnology,
Environmental Impacts and Controls Associated with Work Involving Nanomaterials,
Pharmaceutical Industry's Approach to Safe Handling of New Molecular Entities, and
NIOSH Nanotechnology Field Research Team – A Brief Summary and Update of Activities.
Overheads of presentation materials from the workshop will be posted at: http://nano.anl.gov/events/enm/index.html. American Board of Industrial Hygiene (ABIH) certification maintenance (CM) points were approved for attendees of the meeting..
Joint EFCOG/DOE Chemical Management 2008 Workshop Briefing
Dan Marsick briefed the Steering Committee on information shared about the EFCOG/DOE Chemical Management 2008 Workshop that was held March 4-6, 2008 at the DOE Forrestal Headquarters building. About 280 people registered to participate in the workshop either on site or through video conference format. The 2008 workshop topics included:
“Looking at the Whole Picture: Chemical Life-Cycle Management,”
“Safety Culture for Chemical Safety Management,”
Potential Globally Harmonized System (GHS) Effects,
Chemical Strategies Partnership – Transferring the Load,
Chemical Safety Board Presentation,
Cylinder Storage, Use and Lifecycle Management,
“10 CFR 851 – Chemical Experiences” (followed by a video),
ORISE and 851 support,
Executive Order 13423, Strengthening Federal Environmental, Energy, and Transportation Management and Project 2007B report,
Control Banding,
Chemical Inventory Systems Benchmarking and Accuracy Assessment,
Integration of Chemical Management with Emergency Management – Panel,
DOD Chemical Management System,
Training on:
Developing, Testing, and Deploying Bio-based Substitutes for Toxic Chemicals
Chemical Storage: Myths and Realities, and
Beryllium:
Status of 10 CFR 850 “Chronic Beryllium Disease Prevention Program” Amendment Rulemaking
Closed Face Cassette Wall Deposits Impact on Beryllium Sample Results
Laboratory Detection and Reporting Limits for Beryllium Samples
Statistical Analysis of Beryllium Sample Results with Many Non-detects
Beryllium Health Risk Communication at Y-12
Guidance for Sampling Surfaces for Beryllium Contamination.
Overheads of the presentation materials from the 2008 workshop are posted at: http://www.hss.energy.gov/HealthSafety/WSHP/chem%5Fsafety/ws2008/. Dan reported that the 2009 workshop would include an EFCOG Industrial Hygiene/Industrial Safety Group meeting on the 3rd day of the meeting along with the normally scheduled Beryllium Group meeting that is held at the end of the workshop.
DOE Nanotechnology Safety and Health News
DOE Office of Inspector General Office of Audit Services Audit Report for Nanoscale Materials Safety at the Department's Laboratories was released in February 2008 (www.ig.energy.gov/documents/IG-0788.pdf). In a February 28, 2008 memo from the Inspector General to the Secretary, it was note:
BACKGROUND
The National Nanotechnology Initiative was established as a multi-agency research and development program in 200 1. As a part of the Initiative, the Department of Energy (Energy) is in the process of constructing Nanoscale Science Research Centers at six national laboratories. In addition to funding the construction and operation of these facilities, the Department funds nanotechnology projects at six other national laboratories.
Since the field of nanoscale materials research is relatively new, the health and safety risks associated with these materials are still emerging. Health and safety risks include possible pulmonary inflammation and lung tumors resulting from the inhalation of nanoscale materials as well as an increased potential for explosion and fire due to nanoscale attributes that are not present in the same materials at larger sizes.
The Department established DOE P 456.1, Secretarial Policy Statement on Nanoscale Safety in September 2005. This policy stipulates that the Department and its contractors should use best practices and national consensus standards when establishing safety policies to protect workers. IUational consensus standards have not yet been established as the scientific community studies safety and health risks posed by nanoscale materials. The Centers for Disease Control and the National Institute of Occupational Safety and Health (CDC/NIOSH) have taken a leading role among Federal agencies conducting research on the safe handling of nanoscale materials. In October 2005, CDC/NIOSH distributed, for peer review, information regarding precautionary measures for the safe conduct of nanoscale work, including medical surveillance, workplace monitoring, training, and engineering controls. Given the absence of consensus standards, we used the CDCAVIOSH information to determine whether the Department's laboratories were employing appropriate safety measures specifically tailored for working with nanoscale materials.
RESULTS OF AUDIT
We found that the Department and its laboratory contractors had not always employed precautionary measures as outlined by the CDC/NIOSH. While some laboratories had established work practices concerning the safe handling of nanoscale materials, the Department's laboratories we reviewed generally had not:
Performed medical surveillance on individuals working with these materials;
Monitored the workplace environment for exposure to airborne nanoscale materials;
Provided specific training in the safe handling of nanoscale materials; and,
Required that nanoscale materials research be performed in facilities equipped with all of the suggested engineering health and safety controls.
In addition, the Department had not established a mechanism to disseminate nanoscale materials safety information. Management told us that existing mechanisms, such as Departmental working groups, adequately performed the dissemination function for nanoscale safety information. However, at the time of our audit, neither the Department nor the working group had disseminated lessons learned and other information developed by the group to other laboratories working with nanoscale materials.
Department officials indicated that they were waiting for the development of national consensus standards before issuing additional guidance in the areas of medical surveillance, exposure rate monitoring, training, and use of engineering controls. Similarly, officials at several laboratories indicated that they were waiting for more definitive agency standards to be available before establishing specific safety policies locally. However, CDC/NIOSH has encouraged the establishment of interim standards until more definitive consensus standards are developed for nanotechnology.
We concluded that the Department should adopt a proactive approach to ensuring that its laboratories follow best practices in conducting nanoscale-related work. In this way, the Department increases the chance that workers will be protected from potential health and safety risks, some of which experts acknowledge may not be fully understood for years.
During our review, an Environment, Health and Safety (ES&H) working group representing the Department's Nanoscale Science Research Centers (NSRC), issued safety guidance for nanotechnology, entitled Approach to Nanomaterial ES&H. The policy suggestions in this guide conform to the CDC/NIOSH precautionary measures on medical surveillance, exposure rate monitoring, worker training, and engineering controls. Management stated that all of the Directors of the national laboratories have accepted the guidance and endorsed them as the best collection of safety and health information concerning nanoscale activities. While the development of this guidance is a positive development, the use of the guide is voluntary on the part of the laboratories. Accordingly, we recommended the Department adopt and issue the NSRC working group's guidance until national consensus standards can be established.
MANAGEMENT REACTION
Management did not concur with our recommendation. Management felt it was unnecessary to develop any additional policy or guidance in this area at this time.
Management also stated that it had asked Laboratory Directors to provide an update on their progress in the development and implementation of requirements for nanotechnology activities.
We disagree with management's position. After we received management's response, we followed up with several laboratories and found varying degrees of action on the policy suggestions in the NSRC guidance. Our review found that none of the laboratories had fully adopted the NSRC suggestions. One official stated that his laboratory was awaiting formal direction from the Department before acting.
During the course of our audit, we noted a concern regarding the Department being overly prescriptive about how contractors should achieve mission objectives and its impact on economy and efficiency. However, the disparity in precautionary measures we found warrants that the Department clearly establish expectations for such measures at its laboratories. In addition, the Department's adoption of the NSRC guidance would not involve the establishment of new requirements since the laboratory directors have agreed to adopt and operate in a manner consistent with them.
Given the potential health consequences, we believe it is important that the Department adopt and disseminate the best available guidance on nanoscale safety in order to protect workers in this important and emerging field of research. Management's comments and our response are discussed in more detail in the body of the report.
Dan Marsick noted the Inspector General said that the Department has not concurred with the report. DOE is currently working on a response to the report. Several suggestions have been received but no final decision has been made.
AIHce Expo 08 DOE and DOE Contractors IH Meeting
The DOE and DOE Contractors IH Meeting will be held June 4, 2008 in Minneapolis, Minnesota in conjunction with the AIHce 08 event. Sponsors of the meeting are DOE Office of Health, Safety and Security, DOE Industrial Hygiene Coordinating Committee (IHCC), and IH/OS SIG. The purpose of the meeting is to provide informative safety and health information to the DOE complex. The meeting topics will include:
Addressing Industrial Hygiene Issues Unique to Aging Workforces,
DOE Nanoscale Science Research Centers Safety Committee Activities,
DOE Office of Independent Oversight Review of Nanoscale Activities Health and Safety,
Nanotechnology Safety and Health Information Resources,
Revisions to DOE STD-6005 Industrial Hygiene Practices,
Status of 10 CFR 850 “Chronic Beryllium Disease Prevention Program” Rule Amendments,
Argonne National Laboratory Confined Space Retraining Program, and
10 CFR 707, Workplace Substance Abuse Programs at DOE Sites.
ABIH CM points will be requested for attendees of the meeting.
Open Discussion
Danny Field and others are revising the DOE Industrial Hygiene Practices standard (current standard posted at: www.hss.energy.gov/HealthSafety/WSHP/ihcc/standards.html). The driver for revising the standard comes from the 10 CFR 851 rule. The standard is basically divided into two parts:
IH fundamental program (Chapters 1-7, 17)
IH specific programs (Chapters 8-16):
Chapter 8. Respiratory Protection
Chapter 9. Noise Protection
Chapter 10. Control of Carcinogens, Sensitizers, And Reproductive Health Hazards
Chapter 11. Control of Biohazards
Chapter 12. Control of Nanotechnology Health Hazards
Chapter 13. Control of Non-Ionizing Radiation (Nir) Health Hazards
Chapter 14. Control of Laser Health Hazards (Chapters 13/14 may be combined)
Chapter 15. Control of Confined Space Health Hazards
Chapter 16. Control of Ergonomic Health Hazards
Danny will provide a progress report on revising the IH standard at the DOE and DOE Contractors IH Meeting in June. DOE Officials from the IHCC and HSS will comment informally on the draft prior to it being sent through the DOE Technical Standards Program Office review process (RevCom). The document most likely will become a living document which will continue to grow over time as needed. Inquires about the revisions to the standard should be directed to Danny at: danny.field@oak.doe.gov.
Future Steering Committee Conference Call Meeting
The next Steering Committee meeting is scheduled for May 6, 2008, 1:15 – 2:45 pm EST.
For additional information, please contact: Deborah McFalls, IH/OS SIG Coordinator
Oak Ridge Institute for Science and Education
P. O. Box 117, MS 10
Oak Ridge, TN 37831-0117
