Nanomaterial Stewardship
Acknowledgment: This article was drawn mainly from Nanomaterial Stewardship Guidance sponsored by the AIHA Nanotechnology Working Group (NTWG) and represents a compilation of information from NTWG members and others. Major contributors were Renae Goldman, CIH, FAIHA, John Baker, CIH, Charles Geraci, PhD, CIH, FAIHA, Michele Shepard, PhD, CIH, John Lowe, CIH, and Christine Knezevich, CIH. Disclaimer: This article represents the views of the author and not 3M Company, and is not intended as legal advice. Nanomaterial regulation is complex and rapidly evolving. Readers should consult their legal and regulatory subject matter experts.

While nanomaterials hold great promise to enhance technologies and products, managing their potential exposures and health risks is challenging, especially since the science and regulation of nanomaterial health risks continues to evolve. Through product stewardship, industrial hygienists and EHS professionals can ensure that potential environmental, health, safety, and regulatory impacts are addressed and responsibly managed throughout the product life cycle. The skills for assessing and managing occupational risk can complement and support product stewardship, including stewardship for nanomaterials and nanoproducts.

One product stewardship activity with much recent emphasis is sustainable product design and development. A life-cycle approach to sustainability ensures potential EHS and regulatory impacts are considered early in product and process design and development; addressed in product design, raw material selection, manufacture (including distribution operations), use (including maintenance), re-use, recycle, and disposal; and reassessed periodically and when new information becomes available.
This iterative review is especially important for emerging technologies since the science and regulations may still be evolving. To address overall sustainability, relevant ethical, legal, and societal aspects should also be considered. RAW MATERIALS FROM SUPPLIERS It’s important to have a process in place to systematically determine whether nanoscale ingredients are present in materials or products received from suppliers. Request that suppliers disclose nano content in their raw materials—for example, ask whether their materials contain any nanomaterials with a primary particle size from 1 to 100 nanometers. Enlist purchasing and product developers to alert the product steward and other EHS professionals, as appropriate, when there is intentional nanomaterial content in new product formulations. Review specification sheets, certificates of analysis, and other technical information for materials with potential for nano-content. Be aware that labels and safety data sheets (SDSs) often do not accurately reflect nanomaterial content or hazards. SAFER DESIGN It may be possible to design (or select) safer nanoparticles by choosing or altering their properties. It may also be possible to reduce the amount of a hazardous nanomaterial needed to obtain the desired functionality. Understanding characteristics of nanomaterials to reduce toxicity is an active field of research, as is the merging of green chemistry concepts with nanoscience.
A producer of nanoparticles, nanomaterials, or nanoproducts may be able to develop safer synthesis or processing techniques or adopt existing methods to reduce material hazard and potential for worker exposure. Approaches that may reduce risk include bottom-up synthesis methods free of hazardous catalysts and the use of nanoparticles in liquid suspension rather than in dry powder form.
If a nanoparticle product is dispersive, it may be possible to reduce dispersion potential either by fixing the nanoparticles to other “support” ingredients or by modifying other ingredients that affect the dispersive nature. If nanoparticles are fixed in a product, the product design could focus on reducing release of those nanoparticles during the product life cycle—for example, from wear, decomposition or corrosion during use, from abrasion during cleaning, or from grinding or shredding during recycling or disposal. REGULATORY LANDSCAPE Regulations that affect stages of the nanoproduct life cycle influence several product stewardship activities. Many countries have relied upon existing regulations to provide oversight for nanoparticles, nanomaterials, and nanoproducts. Some countries have either incrementally amended certain regulations, as the European Union has done for cosmetics, food and food packaging, and pesticides/biocides, or provided guidance for addressing nanomaterials with existing regulations.
Original nano-specific regulations typically require annual reporting of nanomaterials or nanoproducts into national inventories or registries to enable identification and tracking, and sometimes to prioritize future research or regulation. The country-by-country, and sometimes agency-by-agency, approach to regulation can result in complex compliance challenges. This is particularly true for companies whose nanomaterials or nanoproducts are manufactured, imported, distributed, or processed in multiple countries, and for companies whose nanomaterials are used in a variety of applications, markets, and sectors covered by different agency jurisdictions.
RENAE GOLDMAN, MS, CIH, FAIHA, is corporate industrial hygiene specialist at 3M Company in Saint Paul, Minn. She can be reached at (651) 737-3496 or via email.