Regulatory and Risk Overview OSHA Perspectives International

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					Regulatory and Risk Overview: OSHA Perspectives
      International Conference on Nanotechnology
   Occupational and Environmental Health and Safety
                   December 6, 2006



                Loretta D. Schuman, Ph.D., D.A.B.T.
               Office of Chemical Hazards - Nonmetals
               Directorate of Standards and Guidance
            Occupational Safety and Health Administration
                       Washington, D.C. 20210
       OSHA’s Mission
To assure the safety and health of
     America's workers by:
  setting and enforcing standards;
  providing training, outreach, and
     education;
  establishing partnerships; and
  encouraging continual
     improvement in workplace
     safety and health.
                 Authority
Occupational Safety and Health Act of 1970
  Covers employers engaged in interstate
     commerce
  Does not cover miners, transportation workers,
     public employees (except in State-Plan
     states) or the self-employed
  Requires employers maintain a safe and
     healthful workplace, “free from recognized
     hazards likely to cause death or serious
     physical harm”
    OSHA Programs
Develop safety and health standards
Enforcement
Respond to employee complaints
Compliance assistance, consultation
    program
Voluntary protection programs to
    encourage best practices
Alliances, partnerships
Administer state OSH plans
Outreach, publications, presentations
OSHA Involvement in Nanotechnology
   Collecting/evaluating information

   Participating in an inter-agency working
      group addressing safety, health, risk
      issues

      Nanotechnology Environmental and Health
      Implications Working Group (NEHI)



   Planning guidance development activities
Health Standards Applicable to
 Nanotechnology Operations

    Hazard Communication
    Respiratory Protection Program
    Personal Protective Equipment
    Laboratory Standard
    Certain substance-specific standards
       and permissible exposure limits

 Standards Contained in 29 Code of Federal Regulations
 (CFR) Part 1910
Hazard Communication Standard (HCS)
             29 CFR 1910.1200

   Requires chemical manufacturers to
      evaluate the hazards of chemicals they
      produce (hazard determination)

    Hazard information and other data to be
       conveyed to downstream users on labels
       and material safety data sheets (MSDS)

   Advanced Notice of Proposed Rulemaking to
      conform to the Globally Harmonized
      System (GHS) for hazard communication
Hazard Communication Issues for Nanomaterials
       What is an appropriate hazard statement when
          little is known?

       Should all nanoscale materials be identified as
          such on MSDSs (e.g., nanoscale TiO2 vs.
          bulk)?

       Should hazard statements reflect generally what is
           known from ultrafine pollutants?

       Should hazard information for a specific
           nanomaterial be conveyed for similar
           materials (Do all buckeyballs have similar
           hazard potentials?)

       Should nanostructured materials having several
           components be treated like mixtures?
Note lack of CAS and PEL/TLV
Carbon Nanotube MSDS
40 nm TiO2
    Examples of Fullerene Structures
(What is needed for hazard determination?)




    C-60                    C-70           C-60 ethylbenzene




 C-60 carbonyl triphenyl conjugate   C-48, N-12 aza-fullerene
Respiratory Protection Standard
           29 CFR 1910.134

Respirators required when necessary to
protect health of employees.

Written respiratory protection program must
address:

  Respirator selection (NIOSH-approved)
  Medical evaluations
  Fit testing procedures
  Proper use, cleaning, storage, and
      maintenance
  Employee training
Personal Protective Equipment Standard
              29 CFR 1910.132

    Covers use of protective equipment and
    clothing against hazards of processes or
    environment, chemical or radiological
    hazards, or mechanical irritants.

    Standard requires:

      Hazard evaluation of workplace with written
         documentation
      Selection and use of PPE appropriate for
         identified hazards
      Employee training
Hazardous Chemicals in Laboratories
           29 CFR 1910.1400

  Applies to laboratory-scale use of hazardous
  chemicals covered under the HCS.

  Standard requires:

    Development of chemical hygiene plan
       containing SOPs, exposure control
       methods, use of PPE
    Assignment of Chemical Hygiene Officer
    Employee training, MSDSs
Substance-Specific Standards
       29 CFR 1910, Subpart Z


Includes about 400 permissible exposure limits
(PELs) and 27 comprehensive standards.

PELs that may legally apply to nanotechnology
operations include cadmium, graphite, titanium
dioxide, nuisance dusts.

Issue is relevance, adequacy for worker
protection
         Other Activities


 Draft guidance for Hazard Communication
  --Not specific to nanomaterials

 NIOSH: Occupational Health Surveillance for
Nanotechnology Workers
  --OSHA is a partner in the NIOSH
  Nanotechnology Research Center
  Surveillance Working Group

 NIOSH/OSHA MOU on control banding for
nanotechnology workplaces
  Contact Information:
schuman.loretta@dol.gov
    (202) 693-2290