In August 2017, the Toxics Use Reduction Institute (TURI), a research, education, and policy center established by the Massachusetts Toxics Use Reduction Act of 1989, published a nanomaterials fact sheet. The fact sheet is part of a series of chemical and material fact sheets developed by TURI that are intended to help Massachusetts companies, community organizations, and residents understand the use of hazardous substances and their effects on human health and the environment. The fact sheet also includes information on safer alternatives and safer use options. According to the fact sheet, TURI researchers have started a blueprint for design rules for safer nanotechnology. The design rules include five principles, which together follow the acronym SAFER, as shown below. The principles focus on aspects such as modifying physical-chemical characteristics of the material to diminish the hazard, considering alternative materials, and enclosing the material within another, less hazardous, material. The fact sheet notes that other researchers have proposed other more specific design rules, which include avoiding chemical compositions of engineered nanomaterials that contain known toxic elements, and avoiding nanomaterials with dimensions that are known to possess hazardous properties.
Design Principles for SAFER Nanotechnology
- Size, surface, and structure: Diminish or eliminate the hazard by changing the size, surface, or structure of the nanoparticle while preserving the functionality of the nanomaterial for the specific application;
- Alternative materials: Identify either nano or bulk safer alternatives that can be used to replace a hazardous nanoparticle;
- Functionalization: Add additional molecules (or atoms) to the nanomaterial to diminish or eliminate the hazard while preserving desired properties for a specific application;
- Encapsulation: Enclose a nanoparticle within another less hazardous material; and
- Reduce the quantity: In situations where the above design principles cannot be used to reduce or eliminate the hazard of a nanomaterial, and continued use is necessary, investigate opportunities to use smaller quantities while still maintaining product functionality.
The fact sheet provides a summary of regulations concerning nanomaterials. Massachusetts currently has no regulations specifically governing the use or release of nanomaterials. At the federal level, the U.S. Environmental Protection Agency (EPA) primarily regulates nanomaterials under the Toxic Substances Control Act. The fact sheet notes that as of 2017, companies using or manufacturing nanomaterials that have not been subject to premanufacture notices or significant new use rules will be subject to a one-time reporting and recordkeeping rule. More information regarding the rule and its final guidance is available in our August 14, 2017, blog item.