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|Lynn L. Bergeson
Bergeson & Campbell, P.C.
On March 29, 2017, the American Industrial Hygiene Association (AIHA) announced the availability of nanomaterial stewardship guidance sponsored by the AIHA Nanotechnology Working Group.
April 4th, 2017
AIHA Publishes Nanomaterial Stewardship Guidance
On March 29, 2017, the American Industrial Hygiene Association (AIHA) announced (see https://www.aiha.org/publications-and-resources/TheSynergist/AIHANews/Pages/New-Documents-on-Nanotechnology,-VOCs-Available-from-AIHA-Volunteer-Groups.aspx ) the availability of nanomaterial stewardship guidance (see https://www.aiha.org/government-affairs/PositionStatements/Nanomaterial%20Stewardship%20Guidance.pdf ) sponsored by the AIHA Nanotechnology Working Group. The guidance addresses stewardship considerations for nanomaterials and nanoproducts based on the evolving state of the science for human health hazard, exposure, and risk assessment. The guidance promotes a life cycle approach and safer design principles for particles, production, and products; reviews the regulatory landscape; and provides practical suggestions to help determine the presence of nanoscale ingredients in raw materials from suppliers. According to the guidance, a whole life cycle approach ensures that potential environmental, health, safety (EHS), and regulatory impacts are:
1. Considered early in product and process design and development;
2. Addressed in product design, raw material selection, manufacture (including distribution operations), use (including maintenance), re-use, recycle, and disposal; and
3. Reassessed periodically and when new information becomes available.
The guidance recommends that product stewards and other EHS professionals: (1) identify which regulations apply to nanomaterials and nanoproducts for which they are responsible, including state, local, and country regulations; (2) understand the requirements in detail; and (3) closely monitor the regulatory landscape for changes and new requirements potentially affecting commercialization. The guidance describes challenges to consistent and meaningful hazard communication and understanding of exposure potential. The guidance states that studies have indicated there is room for improvement regarding the quality and completeness of nanomaterial safety data sheets, including:
1. Identifying which ingredient(s) is nanoscale, and including size/size range information;
2. Including known physical-chemical properties, such as nanoparticle shape, density, and solubility; and
3. Indicating implications if the hazard classification, toxicity data, or occupational exposure limit provided was not derived from nanoscale material.
The guidance includes literature references and links related to nanomaterial stewardship compiled by the authors.