The Massachusetts Office of Technical Assistance (MOTA) will post this week a Technology Guidance Document entitled “Nanotechnology — Considerations for Safe Development,” which includes recommendations intended to enhance the safety of nanotechnology. According to MOTA, it is providing the Guidance for “the express purpose of assisting in the development of this technology, as failure to prevent exposures or releases will not just risk harm to health or the environment — it will also impede the common interest in realizing the benefits that nanotechnology can provide.”
The Guidance notes that several organizations have developed recommendations for good management practices for facilities (companies, public and private research institutions, including educational facilities) handling engineered nanoparticles (ENP). According to the Guidance, facilities that handle ENPs should develop a risk reduction program with the goal of preventing exposures and releases that may cause harm, even though that risk may not be fully understood now. MOTA states that risk reduction plans can be thought of as having two contextual levels: one, the direct and immediate, which protects personnel in the workplace where ENPs are handled, and prevents the release of ENPs from the workplace into the environment; and two, the eventual potential impact of ENPs, after they have left the facility, considering possible releases during transport, use, and disposal. MOTA suggests that risk reduction plans address both contexts. At the facility, safety measures could include preventive materials selection and process design; containment; and proper personal protective equipment. To reduce risks outside the facility, MOTA recommends making preventing facility releases an integral part of the program. Risk reduction plans should also address cleanup, storage, and transfer; waste shipments; and employee involvement.
MOTA also suggests evaluation of the impacts of use and post-use disposition, to protect consumers and others, as well as the organization itself from potential product, contract, tort, or other liability. MOTA notes that the British Standards Institute recommends providing labeling when “any different handling, maintenance, cleaning, storage or disposal of the product is advised as a consequence of nanoparticle content.” Facilities should consider potentially affected entities, including consumers, workers who use materials containing ENPs, and workers who will come in contact with wastes containing ENPs; practice proactive compliance, through communication with agencies that have regulatory authority over the risks the product could cause; maintain an open and transparent program for testing; recognize the value of preventing harm; and realize the value of nanotechnology.