Insight
ETHICS
Nanomaterials Case Study
What Do We Tell Workers When We Don’t Have the Answers?
BY BRUCE LIPPY
Nanomaterials are widely believed to have begun a promising
new revolution in manufacturing. But as most industrial hygienists are aware, engineered nanoparticles have been shown in animal studies “to reach the alveolar region; avoid macrophage
engulfment; cause oxidative stress, inflammation, and fibrosis;
and translocate into the blood.”1 NIOSH has raised concerns
about which prevention and control actions should be taken
while toxicological research is ongoing.2
Given the incomplete state of toxicological knowledge, a major
ethical question must be posed about what workers manufacturing
these products should be told about the risks they face. As a 2007
article in Professional Safety noted, “Making ethical decisions is
not easy—especially when the situation involves multiple points of
view, conflicting objectives, incomplete knowledge or ambiguity.” 3
With $88 billion worth of products containing nanomaterials reportedly sold in 2007, there are clearly many workers potentially
exposed. 4 Their numbers have been projected by the U.S. government to grow to 2 million worldwide over the next 15 years. 5
Material Safety Data Sheets (MSDSs) are required for nanomaterials that meet the definitions of hazardous chemicals under OSHA’s
Hazard Communication standard. MSDSs from suppliers are the
preferred source of risk information for nanotechnology firms, according to a survey of firms in Massachusetts. 6
NIOSH appears to maintain the most complete collection of
MSDSs for engineered nanomaterials and recently analyzed 60 of
them from 33 manufacturers for technical sufficiency. 7 The researchers only rated 5 percent as “good” while 55 percent were
rated as “in need of serious improvement.” 8 Over half contained
Occupational Exposure Limits (OELs) for the bulk material without
providing guidance that the OEL may not be protective for the
nanoscale material. Eighty percent “failed to recognize the material
as being nano in size or list a particle size distribution showing the
nano size range” and a higher percentage “lacked toxicologic data
specific to the nanomaterials.” Eight percent failed to “suggest any
type of engineering controls or mechanical ventilation.”