If an American in New York forwards the formulation of a corrosion inhibitor containing a nanomaterial to a Canadian co-worker in California, this may be regarded as an export to Canada.
The global economy and new technologies, such as nanotechnology, have created a number of product stewardship challenges for industrial hygienists. IHs evaluate and then develop and implement programs to protect employees. Because of their technical knowledge, IHs are commonly involved in nanomaterial stewardship activities including those ensuring compliance with United States and international product safety regulations. Businesses must fully understand the health, safety, and environmental implications of nanotechnology and how they impact business decisions. Often these responsibilities involve a certified industrial hygienist because he or she has no potential conflict of interest, as opposed to a manager or executive whose compensation may be tied to sales or profit margins.
However, product stewardship goes beyond health, safety, and environmental requirements. It also involves ensuring products are being utilized by customers for their designated uses and other legitimate purposes. Nanotechnology regulatory compliance begins with proper product classification. That classification determines which national and international regulations apply. Nanomaterials, for example, can be utilized as chemicals, pesticides/antimicrobials, food, drugs, or cosmetics, or in a variety of devices.
Nanotechnology also has implications for national security. According to the Department of Commerce’s Bureau of Industry and Security (BIS), nanotechnology is targeted for theft from U.S. entities via export activities. The dangers of illicit technology transfers via export and import activities include proliferation of weapons of mass destruction, acts of terrorism, industrial espionage, and adverse impacts to the U.S. economy due to the loss of proprietary research and development information. In August 2015, the Department of Justice published the “Summary of Major U.S. Export Enforcement, Economic Espionage, Trade Secret and Embargo Related Criminal Cases,” which details multiple thefts of high-tech carbon fibers from U.S. companies to sell in China and Iran and the thefts of trade secrets related to aerospace-grade titanium, titanium dioxide production, and surface coatings. For example, in one case, a research chemist from a U.S. chemical company accepted a position at a university department of nanotechnology in China and attempted to transfer trade secret information from his former employer to his academic office. The report also briefly overviews export security regulations that affect nanomaterials and recommended practices and resources related to compliance. Applicability of export regulations to nanomaterials depends on their end use. U.S. EXPORT REGIMES Four primary U.S. agencies—the Departments of State, Commerce, Treasury, and Homeland Security—regulate the export of American goods and services, including technology. The term “technology” includes nanotechnology and nanomaterials. Table 1, based on information from the BIS website, summarizes related U.S. legislation, administering agencies, and corresponding regulatory citations.
Where Product Stewardship Meets Global Commerce and National Security
A New Role for IH
Export Compliance:
Disadvantages of being unacclimatized:
  • Readily show signs of heat stress when exposed to hot environments.
  • Difficulty replacing all of the water lost in sweat.
  • Failure to replace the water lost will slow or prevent acclimatization.
Benefits of acclimatization:
  • Increased sweating efficiency (earlier onset of sweating, greater sweat production, and reduced electrolyte loss in sweat).
  • Stabilization of the circulation.
  • Work is performed with lower core temperature and heart rate.
  • Increased skin blood flow at a given core temperature.
Acclimatization plan:
  • Gradually increase exposure time in hot environmental conditions over a period of 7 to 14 days.
  • For new workers, the schedule should be no more than 20% of the usual duration of work in the hot environment on day 1 and a no more than 20% increase on each additional day.
  • For workers who have had previous experience with the job, the acclimatization regimen should be no more than 50% of the usual duration of work in the hot environment on day 1, 60% on day 2, 80% on day 3, and 100% on day 4.
  • The time required for non–physically fit individuals to develop acclimatization is about 50% greater than for the physically fit.
Level of acclimatization:
  • Relative to the initial level of physical fitness and the total heat stress experienced by the individual.
Maintaining acclimatization:
  • Can be maintained for a few days of non-heat exposure.
  • Absence from work in the heat for a week or more results in a significant loss in the beneficial adaptations leading to an increase likelihood of acute dehydration, illness, or fatigue.
  • Can be regained in 2 to 3 days upon return to a hot job.
  • Appears to be better maintained by those who are physically fit.
  • Seasonal shifts in temperatures may result in difficulties.
  • Working in hot, humid environments provides adaptive benefits that also apply in hot, desert environments, and vice versa.
  • Air conditioning will not affect acclimatization.
Acclimatization in Workers